Credit card processors have been offering automatic interchange optimization services to businesses as a way to help them qualify for lower interchange rates, thereby lowering the cost of acceptance for eligible transactions.
But Visa is cracking down on this.
Just as Visa’s new Commercial Enhanced Data Program went live, they sent notices to processors like Worldpay to inform them that certain merchants submitting Level 2 and Level 3 transaction data will fail future validation.
Why?
Essentially, Visa is claiming that because processors do this automatically for their clients, they’re bypassing the system and not actually submitting accurate data.
Merchants who want to continue receiving reduced rates on eligible transactions must correct data errors by October 17, 2025, to qualify for the CEDP rates moving forward.
What’s Really Happening with CEDP Validation
Visa’s Commercial Enhanced Data Program (CEDP) officially went live on April 12, 2025. The program offers reduced rates on eligible commercial transactions submitted with enhanced Level 2 and 3 card data that can be validated by Visa Commercial Solutions (VCS).
Eligible transactions can qualify for even lower rates than merchants were getting with automatic interchange optimization.
However, Visa isn’t just going to give these low rates to everyone who claims they’re submitting enhanced data. The data actually needs to be accurate (and apparently, not all of it has been).
To combat this and maintain the integrity of the CEDP program, Visa is essentially saying that this process can’t be automated anymore.
Visa is Tracking Merchants That Submit Accurate Data (and Tracking Those Who Don’t)
Moving forward, Visa will begin assigning a status code to merchants who are submitting enhanced card data.
There are two categories, and they’re both fairly straightforward:
- Verified Merchants — Submit enhanced data that meets CEDP standards for qualifying transactions.
- Non-Verified Merchants — Do not submit accurate enhanced data that meets CEDP standards on a consistent basis.
Consistency is key here.
It appears as though Visa understands that even verified merchants can make occasional mistakes. So if you don’t have a perfect record, you’ll still be verified.
But merchants that consistently submit inaccurate data (likely through automation tools from their processor) will be marked as non-verified and won’t be eligible for reduced CEDP rates.
Data Quality Issues to Fix Now
Non-verified merchants still have time to fix errors. Visa has sent reports to processors identifying any merchants that are currently submitting Level 2 and Level 3 card data that would fail validation in the future.
If you fall into this category, you can correct those errors by October 17, 2025, if you plan on continuing to submit enhanced data and qualify for optimized rates.
Here are some common examples of data issues that Visa has identified:
- Line item totals are not accurate (each line item doesn’t equal the total transaction)
- Inaccurate taxes, shipping, and discount fields
- Missing data fields that can’t be validated
- Local tax amount can’t be validated
For line-item errors, you need to make sure that the total amount equals the unit cost multiplied by the quantity, minus the discount amount for each line item. The source amount total must be equal to the line item totals, taxes, invoice-level discounts, and invoice-level shipping.
You can refer to this CEDP error guide from Worldpay for a full list of all error codes, descriptions, and how to correct them.
Timeline
- April 12, 2025 — CEDP goes live and Visa begins to review data quality issues
- October 17, 2025 — Merchants must correct data errors identified by Visa
- April 2026 — Visa is sunsetting Commercial and Small Business Level 2 interchange programs (except for Fleet fuel-only Level 2)
Action Steps for Merchants
Here’s what you need to do next if you’ve been submitting Level 2 and Level 3 card data for automatic interchange optimization:
1. Determine Your Verification Status
Contact your payment processor immediately to determine if you’ve been classified as a “Verified” or “Non-Verified” merchant.
I know that Worldpay has already received reporting from Visa that includes merchants with data qualify issues, and I assume Visa is sending these same reports to other processors who currently offer automatic interchange optimization.
Your account manager should be able to tell you if your submissions have been flagged. If they don’t have an answer, check back in a week or two—this is all brand new stuff for everyone, and I imagine new reports will be rolled out over time.
2. Identify Your Data Issues
If you’re a non-verified merchant, you should request a detailed report with your specific data errors. Your processor should have access to the issues that Visa identified with your submissions.
This information will give you a clear starting point for corrections.
3. Evaluate Your Process
Review how you’re currently submitting Level 2 and 3 card data. If you’ve been relying on automatic interchange optimization, you’ll likely need to make major adjustments as this will no longer work.
Determine if your current system actually supports accurate enhanced data submissions or if it needs to be modified. You may also want to implement a manual review process for high-volume transactions and potentially consider third-party tools designed for proper Level 2 and 3 data submissions.
4. Set Up Validation Controls
Once you’ve ironed out your new process, you should also set up validation controls to mirror what Visa will be checking—things like line-item arithmetic, tax calculations, shipping discounts, and all fields being completed.
This will allow you to catch any errors prior to submitting them and reduce your risk of being labeled non-verified.
Final Thoughts
Again, this is completely new information, and I’m expecting more details to come from both Visa and processors between now and October.
It’s also unclear right now if Visa is going to retroactively charge more for transactions that were previously submitted with inaccurate data after the October 17th deadline. This should give you even more of an incentive to correct your mistakes.
If you’re struggling with this news and worried about your rates rising, contact our team here at MCC for assistance.