Level 2 is gone, Product 3 got more expensive and the merchants most at risk are the ones who think they finished this project in 2025.
On April 17, 2026, Visa retired its Commercial and Small Business Level 2 interchange programs, ending the pricing tier that thousands of B2B merchants had relied on for decades. Only the Fleet-fuel-only Level 2 program survives. Every other merchant that once earned discounted interchange by sending Level 2 data now has one path to lower rates on Visa commercial cards: Product 3 under the Commercial Enhanced Data Program (CEDP).
CEDP, the framework that now determines whether commercial and small business card transactions qualify for discounted interchange rates based on the accuracy and completeness of the transaction data a merchant submits. Verisave covered the CEDP rollout early, and the program has moved faster than most merchants expected. The rules are no longer the story. The 2026 story has moved from surprise and shock to what we are seeing now; a lot of false confidence. Merchants who assume they are covered can still lose Verified status, absorb higher interchange, and miss the problem until it surfaces as a budget variance.
Key takeaway: Level 2 no longer exists as a fallback for most Visa commercial card transactions. If your data does not sustain Product 3 qualification month after month, you are paying more, whether or not anyone has told you.
What changed in 2026, in plain English
Under Visa's January 2026 interchange update, effective Jan. 24, 2026, Product 3 rates for small business cards rose 65 basis points and legacy Level 2 rates rose 75 basis points, bringing Level 2 in line with base rates. Because CEDP transactions also carry Visa's 0.05% program fee, a small business card transaction sent with Level 2 data in early 2026 cost slightly more than one sent with no enhanced data at all. Corporate and purchasing card rates were left unchanged in January.
On April 17, 2026, Visa sunset the Level 2 programs entirely.
| Before 2026 assumptions | 2026 reality |
|---|---|
| Level 2 is a safe fallback if Product 3 fails | Level 2 is retired for all but fleet-fuel transactions |
| Enhanced data always earns a discount | Unverified enhanced data can cost more than none, once the 0.05% CEDP fee applies |
| 2025 was a transition year with room to adjust | Enforcement began Oct. 17, 2025 and repricing hit in January 2026 |
| Compliance is a one-time setup task | Qualification depends on sustained, transaction-level data quality |
Why merchants who think they are compliant still fail
Passing some enhanced data fields is not the same as sustaining Verified-quality submissions across every transaction, every month. Visa evaluates CEDP data at the transaction level, and the most common failure modes are operational. Verisave sees the same problems repeatedly in merchant statement reviews:
- Missing or malformed required fields, most often the Purchase Identifier, sales tax, postal code, country code and order date
- Line-item arithmetic that does not reconcile, so totals fail validation even when every field is populated
- Placeholder or junk values passed by a gateway or processor integration that once slipped through and no longer does
- Data that qualifies one month and fails the next because an ERP update, gateway change or new invoicing workflow quietly broke a field mapping
This is why a merchant can sound compliant in processor conversations and still fail at the transaction level. Verisave CEO Jeremy Layton told Payments Dive in late 2025 that some of the largest B2B companies were in panic mode after losing discounts they had relied on for years, and that some processors were still passing fabricated data, undermining the integrity of the program. Visa's AI-assisted audits are built to catch exactly that.
What this means for budgets and margin
Higher effective interchange does not announce itself. It shows up as a variance between forecast and actual acceptance cost, often months after the underlying data problem began.
| Issue | How it hits the P&L | Who is most exposed |
|---|---|---|
| Verified status slips | Transactions reprice to base commercial rates | Merchants with heavy small business card mix, where the January increases landed |
| Product 3 qualification fails intermittently | Effective rate swings month to month with no volume explanation | Merchants with multiple gateways, channels or invoicing systems |
| Old savings models still in use | Budgets assume discounts that no longer exist at the same depth | Any merchant whose interchange assumptions predate January 2026 |
Extra caution is needed even for fully compliant merchants who should rerun the math. The 0.05% participation fee and the January repricing changed net savings on small business volume, so a model built in 2025 overstates the benefit.
A 5-point CEDP audit for finance leaders
- Pull recent statements and look for effective-rate movement on commercial and small business card volume that volume and card mix do not explain.
- Validate the fields at the source. Confirm the Purchase Identifier, tax, postal code, country code and order date are populated cleanly from your ERP or invoicing system on live transactions, not merely mapped in a configuration document.
- Demand transaction-level proof. Ask your gateway, processor and internal team to show Product 3 qualification performance with real data, not assurances.
- Test for month-to-month variance. Inconsistent qualification is the signature of a data-quality problem, and it compounds quietly.
- Escalate manual workarounds. Any reliance on default values, hand-keyed fields or vendor promises without reporting behind them is a standing risk under AI-assisted audits.
If any of the five turns up a gap, the Visa Verified Merchant Report is the definitive check. It states whether Visa classifies your business as compliant and, if not, returns error codes that identify which processes need fixing.
What to do next
Waiting for the next rule change is the wrong move; the current statements already hold the answer. A statement review connects the 2026 rule changes to what your business is actually paying, identifies which transactions are failing and why, and sequences the fixes. Verisave performs this analysis inside the merchant account a company already has. There is no processor switch, no upfront fee and no payment to Verisave unless savings are realized. For merchants with an ERP-to-gateway data gap, Verisave Connect passes accurate invoice data from the ERP to maintain Verified Merchant status the correct way.
Send a recent merchant statement for analysis, and Verisave will report where you stand.
Frequently asked questions
What is Visa CEDP and how does it affect my rates? CEDP is Visa's Commercial Enhanced Data Program. It replaced the Level 2 and Level 3 interchange programs and ties discounted interchange on commercial and small business card transactions to validated, transaction-level data quality. Merchants that sustain Verified status and qualify for Product 3 earn lower rates; merchants whose data fails validation reprice to base commercial rates, which for small business cards can mean paying 65 basis points or more above the qualified rate.
Is Visa Level 2 still available in 2026? No. Visa sunset the Commercial and Small Business Level 2 interchange programs on April 17, 2026. The only exception is the Fleet-fuel-only Level 2 program, which is excluded from CEDP.
What is CEDP Product 3? Product 3 is the enhanced-data qualification tier under Visa's Commercial Enhanced Data Program. It replaced Level 3 and requires accurate, validated transaction data, including line-item detail, to earn discounted interchange on commercial card transactions. Submissions are subject to AI-assisted audits.
Why did my B2B processing fees go up in 2026? The most common causes are the January 2026 repricing of small business card interchange, the April 2026 retirement of Level 2, or transaction data that fails CEDP validation and reprices to base commercial rates. A statement review can isolate which applies.
How do I know if Visa classifies my business as a Verified Merchant? Request a Visa Verified Merchant Report. If your business is not compliant, the report contains error codes identifying the specific data processes that need to be corrected.
