Elena Crespo, Advisory Board Member and Principal, Verisave
I’ve spent over 20 years in the credit card industry, including a long stint within Citi’s cards
business. 2025 was one of the most eventful years I can remember, and the developments that
unfolded are going to reverberate throughout 2026 and beyond. Here are six things merchants
need to understand as we move through this year.
CEDP is still causing chaos
Visa’s Commercial Enhanced Data Program is the biggest processing rule change in the last 25 years. It overhauled requirements for the lowest interchange rates on business and commercial cards. For years, many merchants achieved discounted rates by submitting fabricated data.
CEDP was designed to end that. The problem is the new rules are complex and the rollout was botched, confusing processors and merchants alike.
Some processors and gateways are focused on finding new ways to game the system instead
of helping merchants comply. That’s a mistake — Visa’s AI will catch on, and those merchants
will lose their discounts overnight. CEDP is here to stay, and Mastercard is likely to align its
rules. Merchants who want interchange discounts need to become compliant now.
VAMP is changing how fraud is measured
The Visa Acquirer Monitoring Program replaced previous dispute and fraud monitoring with a new framework that added risk thresholds for acquirers. Merchants and acquirers exceeding those thresholds started incurring fees in October 2025.
Merchants need to understand how the VAMP ratio is calculated to avoid penalties, and may find processors putting more pressure on them since processors now have portfolio-level thresholds.
Proposed Visa/Mastercard settlement has real teeth — if it survives
In November 2025, Visa and Mastercard announced a revised $38 billion settlement stemming
from the 2005 class-action lawsuit. From a merchant perspective, the new settlement improves
upon the rejected 2024 proposal. Doing away with the “honor all cards” rule — allowing
merchants to refuse high-interchange rewards cards — is a significant concession.
Don’t hold your breath waiting for resolution. It’s unclear if the court will approve the settlement,
and suits from large merchants who didn’t join the class action are still pending. We’ve been
waiting over 20 years for this to be resolved.
Illinois threw a wrench into interchange fees
In 2024, Illinois passed the Interchange Fee Prohibition Act, which prohibits collecting interchange fees on sales taxes, excise taxes and tips if a merchant separates those charges. A preliminary injunction covering nationally chartered banks, federal savings associations and out-of-state banks is already in place, exempting about 90% of card transactions in the state.
The law clearly violates federal statutes, which is why other states didn’t pursue similar
legislation. Even if you don’t live in Illinois, keep an eye on this one — it has national
implications. I don’t think the IFPA will ever be implemented, and some legislators are already
working to repeal it.
Debit interchange is a mess
In late 2025, contradictory rulings by two federal courts created uncertainty about the framework
the Federal Reserve uses to set debit card interchange rates. One ruling invalidated the
framework while the other upheld it. This puts a hold on the Fed’s 2023 proposal to lower the
debit interchange fee cap by 30%.
The courts are slow in the best of times, and the contradictory rulings from courts in different
federal circuits add another layer of complexity. It’s hard to believe this will be resolved in 2026.
Consolidation keeps squeezing merchants
Consolidation continues, not just through mergers but also through SaaS companies adding payment integrations that reduce processing options. Two significant events in 2025: Global Payments announced it’s acquiring Worldpay, and Capital One closed its acquisition of Discover. This leaves merchants with fewer options and probably higher fees — processors have raised fees post-acquisition in the past.
Consolidation will continue causing upward pressure on fees, which makes it even more
important for merchants to proactively optimize their processor, interchange and card network
fees to keep overall costs as low as possible. pressure on processor fees, which makes it even more important for merchants to proactively optimize their processor, interchange and card network fees to keep overall costs as low as possible.
About the Author
Elena Crespo is Advisory Board Member and Principal at Verisave,
a consulting firm that reviews merchant accounts to identify
unnecessary credit card transaction fees, on behalf of retailers,
restaurants and other merchants. She is based in New York, and
the firm is in Salt Lake City, Utah.
Recent PaymentsNEXT news:
From Generative to Agentic AI: The Industrialization of Synthetic Identity Fraud