Visa’s Commercial Enhanced Data Program: What Merchants Should Know in 2026

2026 update: the program was sold as savings and delivered increases

When I wrote this article in June 2025, the Commercial Enhanced Data Program was being presented as a trade. Submit cleaner data, get cleaner rates. Some CEDP rates were 7% to 10% lower than what came before. The deal sounded fair, and I said so in print.

That deal did not hold. If you process Visa Small Business cards, your costs went up in 2026, and they went up whether or not you did everything Visa asked.

How we got here, in order

Why your small business card transactions cost more now

The mechanics are worth understanding, because most merchants who are paying more still do not know why.

Level 2 used to be the practical middle ground. Two extra fields, sales tax and an invoice number, and you earned a meaningfully better rate. It was simple enough to maintain at scale, which is exactly why so many B2B merchants lived there. That option is gone for small business cards. What replaced it is a binary: send full Level 3 data and qualify for Product 3, or send nothing extra and pay the Product 1 base rate.

Here is the part that should bother every B2B merchant in America. Because Product 3 small business rates were raised 65 basis points, a merchant who does everything right, captures every required field, passes validation, and qualifies at the best available rate, still ends up worse off than they were under the old Level 2 program. The reward for full compliance is a rate better than sending nothing, and worse than what they had before any of this started.

Redbridge, an independent payments advisory firm, described the escalation as extensive and seemingly “punitive” given the timing. Their reporting also notes that acquirers appear to have been told in late 2025 while communication to merchants was limited and often delayed, landing over the holidays, which left very little room to plan. That matches what we have seen in client statements: the cost arrived before the explanation did.

What I got right, and what I got wrong

In the original article I wrote that CEDP would most likely kill the processor revenue stream built on auto-populating Level 3 fields and keeping 50% to 80% of the resulting savings. I also wrote that this industry always finds a way to recover lost revenue, and that it would be interesting to watch the next move.

I was watching the wrong party. I expected the processors to engineer the recovery. Instead the network repriced the program itself, thirteen months after announcing it, in the direction that mattered most to its own economics. Small business card issuing has been the fastest growing part of the commercial portfolio, and small business is precisely where the increases landed. Corporate and Purchasing rates, which serve a smaller and slower growing base, were left untouched.

That is the lesson worth carrying forward, and it is bigger than one program. A rate that is announced is not a rate that is guaranteed. The rules and rates of this industry are rewritten more than 200 times a year, and they land in two enormous drops, every April and every October. CEDP is simply the clearest example yet of what that cadence makes possible.

What has changed about the advice

The checklist in the original article below still holds. Check what your ERP or POS is actually sending, ask your gateway directly about tax-exempt transactions, and read your statements looking for downgrades and participation fees charged without benefit. None of that has changed, so I will not repeat it here.

What 2026 added are four things nobody could have told you to do in June 2025, because the concepts did not exist yet or the math had not flipped.

The original article, as published in Forbes on June 27, 2025

Reproduced unchanged. The dates, rates, and predictions below are as they stood in June 2025. Read it against the 2026 update above.

The credit card processing industry is undergoing a major change since Visa announced the Commercial Enhanced Data Program (CEDP), which went live in the U.S. in April. This new program replaces the legacy Level 3 and large ticket interchange structures with a system that rewards merchants for submitting cleaner, more accurate data. After October 17, 2025, transactions submitted with incomplete or incorrect Level 2 or Level 3 data will not qualify for Level 3 interchange rates, according to Worldpay.

If that sounds like a major shift, it is. I’ve worked in this space for more than 25 years, and this is the most significant shake-up I’ve personally ever seen. Here’s what merchants should understand and how they can prepare.

Understanding the CEDP

CEDP is Visa’s attempt to modernize and standardize enhanced transaction data for business-to-business (B2B) purchases. Historically, merchants could qualify for reduced interchange rates by submitting Level 2 or Level 3 data, but the process was often inconsistent and messy.

Now, Visa is tying cost savings directly to data accuracy. If you submit the required line-item fields and Visa Commercial Solutions (VCS) validates them, you can qualify for a lower interchange rate.

The new rates and fees

Visa is also adding a 0.05% CEDP participation fee to every qualifying transaction, Worldpay also said. Merchants may still save money if their data passes validation, thanks to reduced interchange rates. Some CEDP rates are 7% to 10% lower than previously available. Large ticket transactions, for example, drop from 1.45% + $35 to 1.3% + $35, Worldpay reported. That sounds great if you qualify, but merchants can’t simply submit what’s required. It must also be validated by VCS, which could potentially influence how often merchants see the savings.

Goodbye, Level 2

What seems to be one of the most overlooked aspects of this rollout is the elimination of Level 2 interchange rates. That tier provided a middle ground for merchants who couldn’t, or didn’t, submit full Level 3 data.

By April 2026, Level 2 will be gone, with the exception of the fleet fuel-only Level 2 program. Otherwise, only Level 3 will remain, and only for merchants who meet the new validation requirements.

How this could affect tax-exempt transactions

Here’s where I believe things get messy. In my experience, tax-exempt transactions have always struggled to qualify for Level 3. Under CEDP, Visa requires tax amounts or rates be explicitly stated, even if they’re zero. So, unless the data is structured correctly, tax-exempt transactions could still downgrade. And many B2B transactions are tax-exempt.

The good news? I’ve seen some gateways say they’re working on developing solutions to ensure these transactions can still qualify. But this is where merchants need to be proactive. If your gateway can’t support tax-exempt processing under CEDP, you’ll need to find one that can. Because if your transactions don’t qualify, your rates will likely go up.

The bigger picture: an industry shake-up

This isn’t just a new rate structure; I believe it’s a tectonic shift in how processors make money. Many processors have offered to “optimize” Level 3 data by auto-populating fields for years. They’d help merchants qualify for better rates while keeping 50% to 80% of the savings for themselves. So, for example, if the merchant was charged $10 less, the processor would keep $5 to $8 and pass the rest to the merchant.

The new rules will most likely eliminate that revenue stream for the processor. But if there’s one lesson I’ve learned in this industry, it’s that they’ll find new ways to recover lost revenue, so it will be interesting to watch and see what their next move will be.

What merchants should do now

First, check your enterprise resource planning (ERP) or point-of-sale (POS) system. Is it sending the five required fields? More importantly, is that data accurate?

Next, talk to your gateway provider. Ask if they can handle tax-exempt transactions under the CEDP rules. You may need to switch before October to avoid getting hit with unnecessary fees if they can’t.

And finally, watch your merchant statements like a hawk. Especially in the fourth quarter of this year, look for signs that:

• You’re not getting the new reduced rates

• Transactions are downgrading

• CEDP participation fees are being added without benefit

Remember, it’s not just about the rate anymore. It’s about validation. And if your data doesn’t pass, you may pay more without realizing it.

If all this feels overwhelming, you can consider bringing in a professional. Engage a credit card processing audit firm to help you monitor your statements, evaluate your systems and stay ahead of any games being played behind the scenes. Full disclosure: My firm does this, but we’re not the only ones. Shop around. Make sure whoever you choose doesn’t lock you into a contract and has the experience to back up their claims. LinkedIn is a great place to verify that.

Final thoughts

As I see it, Visa has made its move. The question is how the rest of the ecosystem, processors, merchants and software providers, will respond.

One thing’s for sure: The rules have changed. And if you’re not paying attention, you could be paying more.

Frequently asked questions about Visa CEDP

Sources and further reading: program details and dates drawn from Visa program bulletins distributed by Worldpay, and from published analysis by Redbridge. Rates and dates are current as of August 2026 and are subject to change at Visa’s discretion, which is rather the point of this article.