VAMP Acquirer DataThe VAMP Awareness Gap: Financial Institutions Need to Know About Major Changes to Visa Disputes

NEW DATA | Financial Institutions Need to be Aware of Risks Resulting From Visa VAMP Requirements

Portfolio-level fraud and dispute management is more consequential than ever for acquiring banks.

The Visa Acquirer Monitoring Program (VAMP) consolidated Visa fraud and dispute oversight under a single, unified framework that holds acquirers accountable for fraud and dispute activity across their entire merchant portfolio, not just at the individual merchant level. This means an FI can face penalties before any single merchant in their portfolio has technically breached any limits. The fee structure for non-compliance is real and cumulative; across a large merchant portfolio, penalty exposure can reach hundreds of thousands of dollars annually.

What makes this manageable — or not — is the degree to which acquirers have visibility into the merchant-level behavior driving their portfolio ratio.

New data, derived from surveys conducted with hundreds of merchants in the first half of 2026, reveals a finding that should give every acquiring institution pause: a third of merchants don’t know whether VAMP is affecting their business at all.

That awareness gap is not just a merchant problem. It is a direct portfolio risk for the banks that serve them.

Visa Acquirer Monitoring Program: Current Enforcement Thresholds

In April 2025, Visa consolidated two of their existing chargeback monitoring programs — the Visa Fraud Monitoring Program (VFMP) and the Visa Dispute Monitoring Program (VDMP) — into a single, unified program. VAMP, or the Visa Acquirer Monitoring Program, now monitors both fraud and chargebacks at the bank level, rather than at the level of individual merchants.

The switchover was not immediate; Visa gradually adapted their ecosystem to the new rules over the course of a one-year transitional period. The network gradually lowered its compliance thresholds, allowing less leeway as regards incurring fraud and chargebacks, with the last change taking effect in April 2026:

Threshold	VAMP Ratio	Minimum Monthly Count
Merchant — Excessive (Effective April 2026; CEMEA Excluded)	1.5%	1,500 TC40 and TC15 combined
Merchant — Excessive (Effective April 2026; CEMEA Only)	2.2%	1,500 TC40 and TC15 combined
Acquirer — Above Standard	0.5% to < 0.7%	1,500 TC40 and TC15 combined
Acquirer — Excessive	0.7% or higher	1,500 TC40 and TC15 combined

Penalties for non-compliance also increased. As of this writing, these are the fees that will be assessed:

These fees may not seem like much, but they add up quickly. Across an acquirer’s full portfolio of merchants, this could mean hundreds of thousands of dollars in fines per year.

Acquirers are mostly fighting this battle alone, as they cannot rely on merchants to police themselves. Seller sophistication regarding dispute best practices is low, and portfolio-level dynamics are very difficult to reduce to individual merchant behavior.

What the Data Reveals About Merchant Awareness

By and large, merchants are not well-versed in chargeback rules. They are similarly unaware of changes to the limits imposed as part of the Visa Acquirer Monitoring Program.

Only 23% of merchants surveyed in the report say they are “very” up-to-date on card network rules. In comparison, 31% say they are “somewhat” informed, while the remaining 45% say they have little to no familiarity with card network rules.

Awareness of industry rules and regulations are even lower among small businesses, with just 17.4% of those surveyed reporting that they are “very” informed. Even enterprise merchants aren’t doing much better, though; less than one-third of enterprise merchants say they feel they are “very” familiar.

But while unfortunate, merchant ignorance surrounding card network rules is not especially surprising.

Card network rules are notoriously complex to begin with. There are also frequent changes; revised guidelines governing chargeback management may be issued more than once per year, with different effective dates for different rulesets and updates. This means the goalposts are always moving.

Few people with decision-making authority within a business of any size will be experts in the payments ecosystem. Businesses are run by people with expertise in product development and marketing. Few are run by payments experts or chargeback specialists, so it’s not surprising that merchants have little knowledge of the details of card network rules.

It follows, then, that merchants are also unfamiliar with VAMP, which has proven to have a complex rollout.

Asked whether VAMP has impacted their businesses, 33% of merchants surveyed said they do not know. Another 20% say they have not been affected, but that they also do not monitor TC40 data; one critical component in determining whether the business’s fraud and chargeback volume is considered “excessive.” This implies that they may actually have seen some impact, but are not aware of it.

21% of surveyed merchants say they have been affected. Some of the most common complaints among these merchants are that changes to Visa dispute rules have resulted in both stricter chargeback thresholds and heftier penalties for non-compliance.

It’s not all bad news, though; some merchants remarked that they began tracking TC40 data in response to VAMP requirements. Through doing this, they learned that fraud is actually a much bigger problem than they initially thought. 27% of survey respondents say that, although they did not see any restrictions on their operations resulting from VAMP implementation, they now monitor TC40 fraud data.

The Merchant Awareness Gap is a Serious Problem for Acquirers

Merchants may operate in hundreds of different merchant categories and sell different products to different customers. This means that each merchant’s risk profile is unique.

Some merchants, like business-to-government contractors or brick-and-mortar retailers, may face minimal fraud or dispute risks. Other sellers — subscription merchants, credit repair firms, cannabis sellers, online gaming, auction sites and marketplaces, etc. — may be highly prone to criminal fraud or chargeback abuse.

Acquirers need to onboard thousands of merchant clients. But, this is risky: even if the majority of a bank’s merchants experience limited amounts of fraud or disputes, the presence of just a small handful of high-risk sellers can dramatically elevate portfolio-wide fraud and dispute levels. Acquirers face much lower VAMP thresholds imposed by Visa (as low as 0.3%, versus 1.5% for merchants). In other words, it’s possible that acquirers can face penalties for non-compliance before any individual merchant in their portfolio exceeds chargeback limits.

If merchants are largely ignorant about card network rules and unaware about VAMP’s impact on their own businesses, then banks can’t count on them to understand what’s at stake, let alone self-regulate. Merchants may very well be on the cusp of exceeding VAMP thresholds before they realize something is wrong; by that time, damage to their acquirer will have already been done.

How Acquirers Can Close the Gap

Acquirers will need to step in and enforce compliance from merchants; not out of any oppositional stance toward their merchants, but simply to serve the end of protecting their own interests.

Acquirers can take several escalating actions here:

The typical financial institution is bound to be more informed about card network rules, including changes to the Visa Acquirer Monitoring Program, than even a well-informed merchant.

Although acquirers do not have to educate merchants, doing so is good business: more informed merchants are likely to be more proactive about keeping their fraud and dispute levels in check. In turn, this may allow acquirers to enjoy a lower portfolio-wide VAMP ratio without playing the thankless role of enforcer.

Educational and support materials can also serve a second purpose as a customer engagement and retention tactic. All else being equal, merchants are more likely to keep doing business with an acquiring bank that appears knowledgeable and ready to help, rather than a partner that offers no meaningful assistance after onboarding.

While a merchant’s VAMP ratio can be calculated manually, few sellers are going to put in the effort to crunch their own numbers and track them closely enough for it to provide any useful insights.

Acquirers can help with this by providing this data on the dashboard that merchants use to manage their account. Chargeback rate, broken out by relevant card brand, is no less important a KPI than effective processing rate or authorization rate. It should be regarded as such.

The Visa limits outlined earlier in this report represent the ceiling for what Visa regards as “acceptable.” Acquirers are under no obligation to stick to Visa’s threshold for merchants internally, though.

In many cases, it may be beneficial for acquirers to set tighter internal limits for merchants. This can keep acquirers safely out of the penalty box while allowing banks to flag and remediate high-risk merchants early.

For example, merchants must have a dispute rate of 1.5% of transactions and at least 1,500 combined TC40 and TC15 reports for Visa to mandate action. Acquirers can choose to take actions like requiring more internal monitoring, or assessing higher payment processing fees, if the merchant exceeds a dispute rate of 1% of transactions. This kind of preemptive and judicious action can help insulate acquirers from Visa penalties.

Flagging merchants that exceed lower internal thresholds buys acquirers a margin of safety and the time needed to course correct. It’s good business to attempt to retain those merchants who can be remediated. But, with merchants that repeatedly exceed acceptable risk thresholds, it may be best to terminate the processing relationship.

This is “the nuclear option,” so it should only be exercised as a last resort. But, culling high-risk is sometimes necessary to protect acquirers from enforcement actions, since most fraud and disputes across an acquirer’s portfolio are often disproportionately caused by a small handful of sellers.

Think of this as a last-ditch effort to preserve the integrity of the rest of the financial institution’s portfolio and avoid fines that may end up with costs being passed on to non-offending merchants.

Acquirers are Uniquely Positioned for Better Chargeback Management

VAMP has fundamentally changed the compliance calculus for acquiring institutions. Thresholds are tighter and penalties are steeper. But, the merchants generating portfolio-level risk are largely unaware of the exposure they’re creating. Acquirers who wait for merchants to self-correct are waiting for something that data suggests won’t happen on its own.

The good news: acquirers are uniquely positioned to close this gap.

They have portfolio-wide visibility that no individual merchant can match, established relationships that create natural channels for education and communication, and the leverage to set internal thresholds that provide a meaningful buffer against Visa enforcement. Used proactively, those advantages turn a compliance burden into a competitive differentiator. 

Some acquiring institutions will help merchants understand and manage their dispute exposure. Those FIs will build stronger, more durable merchant relationships than those that don’t.

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