VAMP: Consulting with MRC Members to Make Voices Heard
Visa VAMP Program Changes – Visa Announces Advisory Period Extension to October 1, 2025
Visa recently introduced a material change to VAMP (Visa Acquiring Monitoring Program) that has raised concerns with MRC members – we heard this loud and clear at our recent flagship event in Las Vegas. The recent change to not exclude the TC40 records associated with Cardholder Dispute Resolution Network (CDRN) and Rapid Dispute Resolution (RDR) resolutions leaves members with many questions about the path forward.
Along with related concerns regarding new thresholds that will take effect at the acquirer portfolio level and the program calculation itself, this change presents time-sensitive challenges for members as they ready their operations for the launch of the program in April.
The MRC has gathered and summarized feedback from multiple merchant, issuer, acquirer and solution provider stakeholders and delivered this to Visa on March 17th. In addition, we have had follow-up meetings with members of the Visa risk team to review this feedback in depth.
Visa Response – Advisory Period Extension to October 1, 2025 Confirmed
After recent productive meetings with Visa, the MRC is pleased to report that Visa will extend the formal advisory period. This period, which was due to begin April 1 and last three months, will now be extended to six months. Under these current plans, VAMP enforcement will officially commence on October 1, 2025 (versus the previously communicated July 1, 2025).
In addition, Visa will collaborate with both merchants and the MRC to address the program concerns. If further program adjustments are deemed necessary, effective dates for the program could change accordingly to allow for a sufficient advisory period before formal penalties would begin.
Summary of MRC Membership Consultation
To provide additional context, the following summary is based the MRC’s consultation with our membership, including merchants, card issuers, acquirers and solution providers. We continue to work actively with our members and industry stakeholders to bring these challenges to Visa’s attention:
Program Enforcement Timing – As stated above, making these critical changes (no exclusion of TC40 associated with RDR and CDRN resolutions) at such a late stage gives merchants very little time to make fundamental changes to their business operations:
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Fraud Rule Strategy – Under the new program definition, merchants will have to reconsider their fraud rule strategy to ensure they are taking timely action to meet the proposed thresholds. Because this is weeks away, this gives merchants very little time to respond. It also creates risk that merchants will err on the side of overly aggressive fraud rules, which represents lost transaction volume for the entire ecosystem. In addition, higher merchant-side false declines create a poor experience for the cardholder, driving preferred payment cards to ‘back of wallet’ and increased volume in card issuers’ call centers.
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MID Changes & Transaction Acquisition Conversion – Merchants, particularly those who operate in more highly disputed categories, will have to move quickly to adjust their MID strategies and even fundamental sales/customer acquisition strategies. This includes a wide range of operational considerations: sales and product strategy, descriptor management, customer acquisition investments (including advertising and conversion tools/tech), etc. Expecting these adjustments within a few weeks is unrealistic.
Update: Now that Visa has extended the advisory period, some of this immediate time pressure has been addressed for the time being. The MRC appreciates Visa’s collaboration on this change and the extension provided.
VAMP Calculation Construct – MRC members report that they have little insight into either the underlying rationale for the new VAMP program calculation or the specific method of calculation. While we appreciate that resolutions coming from the Verifi (as well as Ethoca/Mastercard) products cannot be definitively determined to be non-fraud (and thus excluded under VAMP), the current program construct over-indexes on fraud exposure. The intent of the combined program was to have a blended ratio informed by both chargeback/dispute and fraud exposure, yet the current calculation and program focuses largely on fraud-related exposure:
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Adjust Program Ratio Calculation – To alleviate the concerns in the industry regarding CDRN and RDR efficacy under the new program, merchants suggested the addition of an additional fraud dispute factor to the numerator formula. For example, instead of the numerator being comprised of non-fraud dispute counts (TC15) and fraud (TC40) counts only, members requested the addition fraud dispute counts. This would create a program construct that provides consideration for merchants utilizing pre-dispute resolution tools in good faith – this includes both the Visa/Verifi and Mastercard/Ethoca products.
In effect, this creates a more balanced approach that preserves the intent to appropriately reflect the impact of reported fraud, while giving merchants due credit for reducing their chargeback exposure with proven tools that are widely adopted in the industry. In addition, this more flexible approach would allow merchants choice: under the current program definition, only CE 3.0 (via Order Insight) offers an exclusion, effectively requiring merchants to undertake an integration that can be costly and resource-intensive.
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Changes to Fraud Reporting – In addition, in cases where issuers are required to report TC40, Visa needs to take steps to ensure that TC40 records can be ‘backed out’ in cases where an issuer has proven a fraud claim to be a result of customer confusion and/or demonstrated first-party misuse/friendly fraud. We are hearing that while many issuers do attempt to back out TC40 records, these changes do not always get reflected in acquirer level TC40 reporting or program calculations. Members feel that Visa should ensure that issuers can easily adjust their TC40 reporting in such cases, and/or create further clarity that all issuers should be following this practice to ensure reported ‘fraud’ is truly fraud. This will give merchants appropriate relief in cases where fraud is incorrectly categorized.
Update – The MRC is continuing to discuss options with Visa, but it is not yet clear whether the VAMP calculation approach will be changed. Adding fraud disputes to the program calculation is a significant change that would require new thresholds as well.
Acquirer Risk & Thresholds – MRC members feel the current thresholds of 30 and 50 basis points carry potential risks as follows:
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Lack of Acquirer Enforcement Consistency – It’s very common for merchants to have multiple acquirers, yet it’s clear there is no consistent approach for how acquirers will manage their portfolios, rationalize MIDs, pass down fees, handle the increased risk exposure, etc. This means that merchants using multiple acquirers will face additional complexity when it comes to managing their fraud rule strategy and acquisition/conversion strategy. Merchants have expressed concerns about the lack of clarity on how to prepare for these changes, and are equally concerned about the impact of lost sales to their business.
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Aggressive Threshold Targets – While it is not yet clear, the new thresholds could bring many more merchants and transaction volume into compliance, forcing acquirers to deny processing in some cases and/or shut down MIDs that create risk to the overall acquirer portfolio. This will result in lost transaction volume/sales – this ultimately hurts everyone in the industry. Merchants lack a clear understanding of how Visa arrived at these new thresholds, which are more punitive than the merchant-side penalties.
In addition, the acquirer side thresholds effectively become the new merchant thresholds: that means a reduction from 90 basis points to, at the most extreme, 30 basis points. Our acquiring partners have reported to us that whether acquirer-level fees are passed down to merchants or not, these changes are likely to increase the overall cost of merchant processing to recover the cost of penalties incurred at the acquirer level.
Update – The MRC requests that Visa reevaluate its approach to established acquirer-level thresholds to ensure they are reasonable, rational, and achievable. Overly aggressive thresholds at the acquirer level penalize virtually every stakeholder in the payments ecosystem, resulting in lost sales and associated transaction processing revenue streams.
The MRC is satisfied with this interim outcome and is committed to working with Visa to help ensure the successful introduction of its new VAMP program. You will see additional events like webinars, including Visa representatives, scheduled soon so please take advantage of these opportunities to learn more about any upcoming program changes.
If you have additional feedback you would like to provide, please send it to Keith Briscoe, VP, Member Advocacy. It will be passed on to Visa in due course.
