Visa has implemented sweeping changes to Level 2 and Level 3 interchange qualification under its Commercial Enhanced Data Program (CEDP).
These changes, which were phased in between April 2025 and early 2026, now affect all businesses processing B2B, government, fleet, or commercial card transactions … especially those with significant monthly card volume and a high percentage of commercial transactions.
Important Update: Level 2 interchange programs were retired earlier than the originally announced April 17, 2026 deadline. Businesses that relied on Level 2 as a "middle ground" between standard rates and full Level 3 compliance are now experiencing higher processing costs unless they have migrated to CEDP-compliant Product 3 data standards.
The nature of changes is not complicated: credit card fraud is costly. The industry has long strived to incentivise businesses for helping to prevent fraud. Within commercial interchange (business-to-business credit card processing) this has meant lower processing rates when the proper data has been passed along with the transaction.
Known as Level 2 and Level 3 processing, the program gave a substantial price break when the transaction detail included: PO numbers, tax amounts, line-item detail, and other checks to ensure the authenticity of the transaction.
The problem: many businesses (often with the help of their processing vendor) were faking this data.
The result: Visa tightened the loophole by auditing transactions for fake or inadequate data. Businesses that were receiving Level 2 and Level 3 rates have experienced a significant cost increase if they have not migrated to the new standards.
For official documentation:
Key Changes Now in Effect:
- A permanent 0.05% participation fee on all Level 2/3 volume
- Renaming of programs: Product 2 and Product 3
- Stricter field-by-field data standards with mandatory formatting rules
- Merchant verification status (Verified, Unverified, Non-Participating) impacting rates and fees
- Lagged interchange adjustments for Unverified merchants
- New interchange programs (Product 3) with adjusted rates and MCC exclusions
- Early retirement of Level 2 fee programs (data requirements remain)
- Expanded requirements for Fleet and EV charging data
Finance leaders must act now: failure to comply has already resulted in higher costs and the loss of interchange discounts for many businesses.
Who Is Affected
- Industries: Manufacturing, wholesale, professional services, distribution, fuel/fleet, government suppliers, and any merchant with high B2B acceptance.
- Roles: CFOs, Controllers, Treasurers, AR leaders, IT/ERP teams.
- Systems: ERP platforms, gateways, and processors responsible for transmitting complete, compliant transaction data.
Financial Risk
For businesses that were processing Level 2 and Level 3 transactions, there is now confirmed evidence that processing fees have increased as a result of the Visa commercial interchange updates.
The reason for this: few businesses were able to maintain these discounted rates under the new data requirements without taking measures to update their transaction workflow from ERP to gateway, in a way that passes compliant data.
The level of impact for these businesses depends on their processing volume in Visa B2B transactions. Below is a chart giving some approximated cost increases:
| Monthly Transaction Volume | 100% B2B | 75% B2B | 50% B2B | 25% B2B |
|---|---|---|---|---|
| $100k | $450 | $338 | $225 | $113 |
| $500k | $2,250 | $1,688 | $1,125 | $563 |
| $1M | $4,500 | $3,375 | $2,250 | $1,125 |
| $10M | $45,000 | $33,750 | $22,500 | $11,250 |
| $100M | $450,000 | $337,500 | $225,000 | $112,500 |
Why This Happened
Level 2 and 3 interchange programs were originally designed to reduce fraud by requiring merchants to submit richer data. Over time, loopholes emerged: many merchants (sometimes with processor assistance) submitted dummy or placeholder data solely to trigger discounts. Issuing banks, which benefit from interchange revenue, pressed Visa to tighten enforcement.
Visa's changes represent:
- A crackdown on placeholders and dummy data
- Standardized, auditable data requirements
- A direct revenue lift for Visa through the 0.05% participation fee
Implementation Timeline
April 12, 2025
- CEDP participation fee (0.05%) began.
- All Level 2 transactions automatically included; flag required only for Level 3 and Large Ticket.
- Acquirers began receiving monthly data quality reports.
October 17, 2025
- New interchange rates became effective (Business, Corporate, Purchasing, Fuel Product 3).
- Merchant verification status began determining access to Product 3 rates.
- Lagged interchange adjustment process (TC20) introduced.
Early 2026 (Earlier Than Announced)
- Small Business and Commercial Level 2 interchange fee programs retired ahead of the originally announced April 17, 2026 deadline.
- Note: Level 2 data requirements remain in force (only fee categories changed).
Merchant Verification Status
Visa assigns merchants to one of three categories, reviewed on a recurring basis:
- Verified: Consistently submits compliant data; immediate access to Product 3 (Level 3) rates.
- Unverified: Initially assessed at standard rates; transactions reviewed within 10-15 days. If data passes audit, the Acquirer receives a lagged true-up via TC20 disbursement.
- Non-Participating: Excluded from CEDP; no access to enhanced rates, but also not charged CEDP fee on Level 3 data.
Switching acquirers resets a merchant's status to Non-Verified until Visa re-evaluates data quality.
New Interchange Rate Structures (Effective October 17, 2025)
| Fee Program | Previous Rate | New Rate (Product 3) |
|---|---|---|
| Corporate Credit Non-Travel Service | 1.90% + $0.10 | 1.75% + $0.10 |
| Purchasing Credit Non-Travel Service | 1.90% + $0.10 | 1.75% + $0.10 |
| Commercial Large Ticket | 1.45% + $35.00 | 1.30% + $35.00 |
| Commercial Fuel (Product 3) | 1.90% + $0.10 | 1.75% + $0.10 |
| Business Credit (Product 3) | New tiered pricing | Tier 1: 1.75% + $0.10; Tier 5: 2.10% + $0.10 |
MCC Exclusions
Certain MCCs are ineligible for Product 3 programs, including:
- Travel: airlines, hotels, cruise lines, travel agencies, car rentals
- Restaurants: MCC 5812 (sit-down), MCC 5814 (fast food)
- For Government Corporate Cards: medical/healthcare MCCs (e.g., hospitals, physicians, dentists)
Fleet and EV Charging Enhancements
- Fleet single fuel-only transactions are excluded from CEDP.
- For EV charging (MCC 5552), new required data includes:
- Connector type
- Charging power output capacity
- Start/end time of charge
- Total charging time and plugged-in duration
Data & Compliance Requirements
Core Fields (All Transactions)
- Purchase Identifier
- Sales Tax Amount
- Destination Postal Code & Country Code
- Order Date
Line Item Detail (Level 3 B2B)
- Item Description
- Quantity
- Unit of Measure
- Unit Price
- Extended Amount
- Item Commodity Code
- Freight/Duty/Discount amounts
Fleet Transactions
- Fuel type, quantity, unit price
- Odometer reading
- Non-fuel product codes required for mixed purchases
EV Charging (MCC 5552)
- Expanded fuel type
- Connector type
- Time and power metrics
Operational Implications
- ERP & Gateway Integration: Most systems needed development to transmit required fields.
- Strict Formatting: Even correct values fail if not in Visa's required format.
- Manual Entry: Unsustainable for high-volume merchants.
- Vendor Solutions: "Plug-and-play" tools may not withstand Visa audits; verification required.
- Settlement Impact: Unverified merchants risk cash flow delays due to lagged adjustments.
Recommended Actions
- Perform a Field-by-Field Data Audit - Check formatting, completeness, and accuracy against Visa's specifications.
- Integrate ERP and Gateway Systems - Automate data capture at transaction; eliminate manual entry.
- Verify Merchant Status - Work with your acquirer to achieve and maintain Verified status.
- Eliminate Placeholder Data - Replace dummy values with true transaction data.
- Validate Vendor Claims - Demand proof of compliance from third-party solutions.
- Plan for Mastercard Readiness - Assume similar enforcement is imminent.
The Verisave Solution
- The Verisave team will make this easy for you
- You don't pay us a dime unless we secure your Level 2 and 3 savings, or bring additional money back to you - so this is a no-expense project
- Our team does the heavy lifting
- We will start with a compliance and rate audit to determine your action plan
- If you agree to move forward, our team will implement the solutions outlined in the action plan, working with your team, your processor, and your payments stack vendors to make it happen without burning your bandwidth
- The solutions will be different for every company, and are based on your current payments stack and transaction mix. They may include:
- Adjusting transaction workflow
- Adjusting merchant account settings
- Implementing a middleware solution between your ERP and your processing gateway
Getting started is easy: let's form an action plan. It all starts with a quick discovery call and we'll take it from there.
If you don't have time for a discovery call, we can get started with just a few recent merchant statements. Send them along to us and our team will prepare an action plan for your review.
For security requirements:
