Editor’s Note (September 2025): Visa has clarified thresholds and extended the advisory period. For the latest guidance, read our updated guide here.

UPDATE: Visa has announced a key update to its upcoming Visa Acquirer Monitoring Program (VAMP): the advisory period will now be extended from three to six months. While VAMP is still scheduled to launch on April 1, 2025, formal enforcement has been delayed from July 1 to October 1, 2025—giving merchants additional time to adjust to the new requirements.

Visa is launching the Visa Acquirer Monitoring Program (VAMP) in April 2025 to unify the separate oversight frameworks that have historically governed fraud, chargebacks (disputes), and risk. VAMP brings together the Visa Fraud Monitoring Program (VFMP), Visa Dispute Monitoring Program (VDMP), and Visa Risk Monitoring Program (VRMP) into a single, more streamlined system.

Although this promises a more efficient approach for Visa and acquirers, it poses new challenges for merchants—especially those who have been safe under older, separate thresholds for fraud and disputes. In this article, we’ll provide a comprehensive view of VAMP, from core calculations and penalties to routing decisions, dispute best practices, and how VAMP fits alongside other card networks’ programs.

Why Is Visa Implementing VAMP?

Visa’s primary goals for VAMP are to reduce persistent e-commerce fraud, better capture “friendly fraud” or non-fraud disputes, and crack down on enumeration attacks (card testing at scale). As digital commerce accelerates, merchants have experienced rising fraud losses and chargebacks . By combining data from both fraud-related and non-fraud disputes, Visa aims to identify high-risk merchants more quickly, impose a tiered fee structure for excessive risk, and encourage stronger prevention tools across the board.

Key Metrics and Considerations Under VAMP:

The VAMP Ratio combines fraud chargebacks and non-fraud (service-related) disputes into a single calculation.

VAMP Ratio = (Fraudulent Transactions + Non-Fraud Disputes) / Total Settled Transactions

A “fraudulent transaction” typically refers to any issuer-confirmed fraud (e.g., unauthorized card use), while “non-fraud disputes” can include reasons such as merchandise not received or a product/service not as described. Under legacy programs, fraud chargebacks were tracked separately by VFMP, and non-fraud chargebacks were primarily relevant under VDMP. With VAMP, both are combined and count toward a single threshold.

Enumeration Ratio

VAMP also specifically monitors card testing (also known as “enumeration fraud”), where fraudsters rapidly submit authorization attempts on multiple card numbers to identify valid ones. Visa calculates an Enumeration Ratio as:

Enumeration Ratio = Confirmed Enumeration Transactions / Total Settled Transactions

Visa has indicated that it will treat enumeration breaches more seriously than before, with a published (or soon-to-be published) threshold around 20% for confirmed card testing. While 20% may seem exceedingly high, merchants who become frequent targets of enumeration attacks can quickly surpass this threshold if they lack effective bot defenses.

Merchants should implement tools like CAPTCHA, velocity checks, device fingerprinting, and other automated security measures to detect and block bulk testing attempts. Failing to curb enumeration can lead to immediate fines or potentially escalate to the “Excessive” tier if the ratio exceeds Visa’s threshold.

What VAMP Replaces: VFMP and VDMP

The Visa Fraud Monitoring Program (VFMP) previously flagged merchants whose fraud dollar volume exceeded a specific threshold (often $75,000 or more in a month) and also exceeded a set fraud-to-sales ratio (e.g., 0.9% or 1.0%). Merchants who remained in the “excessive” zone for too long faced escalating fines, which could reach thousands of dollars per month.

The Visa Dispute Monitoring Program (VDMP) typically applied when a merchant’s total disputes and dispute-to-transaction ratio surpassed certain thresholds (e.g., more than 100 disputes in a month and a 0.9% dispute-to-transaction ratio). Merchants in the VDMP program could face tiered fines and, if no improvement was made, potential termination of Visa acceptance rights.

Under VAMP, the distinction between “fraud chargebacks” and “other disputes” is eliminated. A merchant’s total dispute ratio—combining both fraud and non-fraud disputes—can easily exceed the new VAMP threshold (whether it’s 1.0% or another ratio). This is true even if the merchant was previously below each individual threshold under VFMP and VDMP.

How VAMP Differs from Legacy Programs

Under VFMP, merchants tracked a fraud-to-sales ratio (typically around 1.0%) and a minimum fraud dollar threshold. In VDMP, merchants monitored total dispute counts and a dispute-to-transaction ratio (e.g., 0.9%). These programs operated in isolation, meaning a merchant could be compliant in one program but at risk in the other. VAMP combines these metrics, making it impossible to separate the “fraud ratio” from the “other dispute ratio.”

Comparison with Other Card Networks
Although VAMP is getting a lot of attention, Mastercard, American Express, and Discover also maintain monitoring programs:

• Mastercard: Excessive Chargeback Program (ECP) and Fraud Monitoring Program (FMP).

• American Express: High Dispute Merchant Program, Fraud Full Recourse Program.

• Discover: Dispute Monitoring Program, with thresholds for dispute count and ratio.

  
  All share the fundamental principle: keep fraud and disputes below certain levels or face financial penalties and possible termination. As VAMP rolls out, merchants should remember that improving overall fraud and dispute metrics benefits performance across all networks.

Who Is Affected

• All merchants processing Visa card-not-present (CNP) transactions (e-commerce, mobile, recurring billing, subscription models, etc.).

• Acquirers and payment service providers (PSPs) that underwrite these merchants: They face increased obligations to report exceeding merchants, potentially shoulder penalties, and could eventually terminate high-risk relationships.

• High-risk industries (digital goods, travel, subscription services, dating sites, nutraceuticals, etc.) are especially likely to be impacted if they experience both fraud and non-fraud disputes in meaningful volumes.

How Transactions Are Counted

• Included: Any Visa-branded CNP transaction authorized over Visa rails (credit, signature debit, prepaid).

• Excluded: Disputes resolved via Rapid Dispute Resolution (RDR) will not affect your VAMP Ratio unless there is a corresponding TC40 fraud record. Also excluded are transactions routed solely through non-Visa debit networks (e.g., STAR, NYCE, PULSE) and in-store card-present transactions.

  Important: Visa recently announced that all TC40 records (issuer-confirmed fraud) will count toward VAMP—even if a merchant attempted to resolve the transaction via RDR. If there is a TC40 record, that fraud case remains in scope for VAMP calculations.

  This routing distinction matters: If a merchant uses “PINless debit” on a non-Visa network for certain transactions, those do not count toward the VAMP Ratio. However, the merchant must then comply with the dispute rules of that alternate network.

Penalties and Compliance Tiers

Visa has indicated there will be at least two tiers of non-compliance:

• Above Standard: Slightly exceeding VAMP thresholds, with an approximate fee of $5 per dispute over the limit.

• Excessive: Significantly surpassing VAMP thresholds, with an approximate fee of $10 per dispute. Merchants newly flagged get a 3-month grace period to fix issues, however, if the performance does not improve, fines escalate, acquirers may impose higher reserves, and Visa could potentially terminate the merchant’s card acceptance rights. Persistent offenders can run into thousands (even tens of thousands) of dollars per month in fines, similarly to how it worked under VFMP and VDMP but now triggered by a single combined ratio.

How VAMP’s Combined Metrics Can Lead to Sudden Penalties for Merchants

Under older systems, a merchant might have 0.6% fraud chargebacks (under the VFMP threshold) and 0.45% non-fraud chargebacks (under the VDMP threshold), and thus face no fines. But combining them into a single 1.05% ratio could cross the new VAMP threshold, instantly putting them into fee territory. Even a merchant with 0.4% fraud and 0.6% non-fraud is right at 1.0% combined, leaving little margin for error. The net effect: Some previously “safe” merchants will need to tighten up both fraud prevention and dispute management in tandem.

Example Scenarios

• Scenario A (Safe Before and After): 0.3% fraud + 0.2% non-fraud = 0.5% total, comfortably below a hypothetical 1.0% threshold.

• Scenario B (On the Line): 0.4% fraud + 0.6% non-fraud = 1.0% total, precisely at threshold. Under older programs, these separate ratios might have been acceptable, but combined, it’s borderline.

• Scenario C (Now in Trouble): 0.6% fraud + 0.45% non-fraud = 1.05% total, over a potential 1.0% threshold. This merchant never triggered VFMP or VDMP individually but will be in fees under VAMP.

Preparing for VAMP:

1.Tighten Fraud Prevention: Adopt 3D Secure (3DS) for liability shift, use AVS/CVV verification, deploy AI-driven fraud detection, and implement robust velocity checks to block suspicious patterns. Keep an eye on unusual spikes in authorization attempts, which could signal enumeration.

2.Strengthen Dispute/Chargeback Management: Provide clear billing descriptors to reduce confusion, handle refunds promptly, and proactively communicate with customers. Consider Rapid Dispute Resolution (RDR) to resolve certain claims automatically before they become official chargebacks.

3.Monitor Combined Ratios: Historically, merchants tracked fraud and non-fraud disputes separately; under VAMP, you must look at them together. Run internal month-end tallies to see if your combined ratio is near or above 1.0% (or the final official threshold).

4.Develop a Remediation Plan: If your ratio is creeping up, create an action plan with your acquirer. Visa typically grants a 3-month grace period for newly flagged merchants, but improvement steps must be swift and tangible.

5.Using RDR for Non-Fraud Disputes: Rapid Dispute Resolution remains effective at preventing many service-related chargebacks (e.g., product not received) from escalating. However, note that if a transaction is tied to a TC40 record (issuer-confirmed fraud), it will still count toward VAMP, even if resolved via RDR. Merchants should, therefore, focus on preventing fraud at the authorization stage (through 3DS, velocity checks, and device fingerprinting) rather than relying on RDR to remove those fraud cases from VAMP tallies.

6.Evaluate Routing Choices: One strategic consideration for you is whether to route certain debit transactions through Visa or rely on PINless debit networks like STAR, NYCE, or PULSE. A few key factors you should consider when choosing between Visa Rails or Debit Networks:

• Avoiding VAMP Tally: Transactions that do not go over Visa rails do not appear in the VAMP Ratio. However, each debit network has its own monitoring standards, though often less publicized and sometimes less stringent.

• Interchange Savings: PIN-debit or PINless debit can be cheaper in some cases, especially for Durbin-regulated issuers, reducing merchant fees.

• Robust Dispute Tools: Visa’s ecosystem (including Rapid Dispute Resolution, structured representment, clearer reason codes) is often more advanced than smaller networks. PINless debit systems can have fewer reason codes and less automation. For merchants with high dispute rates, Visa’s more mature processes can be beneficial.

  You could deploy a hybrid approach: route high-value or higher-risk transactions over Visa rails for better dispute infrastructure, while funneling lower-value, low-risk debit transactions through a PIN-debit network for cost efficiency and reduced VAMP ratio exposure.

7.Review Your Policies and Customer Service: Many non-fraud disputes arise from unclear return policies, billing confusion, slow shipping, or poor communication. Improving customer experience often correlates to fewer chargebacks.

Potential Pitfalls and Additional Considerations

• Secondary Consequences: Repeated non-compliance can lead to higher acquirer reserves, reputational damage, or forced re-underwriting.

• Effect on New Merchants: Start-ups or recently launched merchants with minimal chargeback data may face stricter underwriting or be asked for additional documentation if VAMP issues occur soon after going live.

• Shift in Fraud Patterns: As merchants close the gaps in fraud prevention, criminals may increase enumeration attempts or pivot to friendly fraud. Staying agile with your fraud tools is crucial.

• Align with PSPs/Acquirers: Service providers often have advanced dashboards or integrated dispute management features that can help you monitor real-time performance. Collaborate closely on setting up thresholds and filters that align with your industry.

Visa’s Acquirer Monitoring Program (VAMP) represents a significant shift in how fraud, non-fraud disputes, and enumeration attacks are monitored. Merchants who were previously safe under separate fraud and dispute thresholds may find themselves over the line when those metrics merge into one.

Proactive preparation is essential: refine both fraud prevention and dispute management, keep an eye on enumerations, consider strategic routing, and maintain close contact with your acquirer. The heightened scrutiny is meant to ensure better protection for consumers, acquirers, and the card network, but it also places new burdens on merchants to stay below combined ratio thresholds. By understanding every angle—from how VAMP is calculated to how you can mitigate risk and avoid fees—you’ll be poised to maintain healthy transaction flows and customer satisfaction when VAMP goes live in April 2025.

Disclaimer: This article is based on publicly available information and typical Visa guidelines as of publication. Visa may continue updating details—especially regarding exact thresholds, enumeration definitions, or penalty structures—as the 2025 launch date approaches. Always consult your acquirer and the most recent Visa documentation for final guidance.

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