If you manage commercial card acceptance, you’ve probably noticed the costs creeping up. That’s not your imagination—commercial cards already carry higher interchange rates than consumer cards, and those costs are only increasing as issuers lean into the higher-margin opportunity.
Historically, you’ve had ways to push back. Level 2 and Level 3 data help reduce those fees if you submit enhanced details with your transactions. But that playbook is changing.
Visa’s new Commercial Enhanced Data Program (CEDP) is set to replace the old Level 2/3 structure entirely. And if you’re not ready for the transition—or if your data feeds are messy—it could mean losing access to the savings you’ve worked hard to capture
What is Level 2 and Level 3 Data
Level 2 and Level 3 processing are enhanced transaction methods that involve sending additional data elements during B2B transactions to qualify for better interchange rates. For example, if you include the sales tax amount on a transaction over $0, you could get a lower interchange rate on a small business, corporate, or purchasing card—thanks to Level 2 data. That small detail can mean a few basis points shaved off your interchange fees.
Level 3 goes even further. It only applies to purchasing and corporate cards, and it requires sending more detailed, line-item information—like a full invoice. By providing Level 3 data, you can qualify for an even better interchange rate.
Right now, Visa and Mastercard’s programs only check if the data is present—they don’t verify its accuracy. That means if you or your processor sends data elements that loosely match their requirements, you’ll still get the interchange benefits. But that’s about to change.
Visa’s Commercial Enhanced Data Program (CEDP)
Visa’s rollout of its Commercial Enhanced Data Program (CEDP) introduces pivotal shifts in Level 2 and Level 3 data handling—beyond a few technical tweaks. These updates will redefine the interchange savings and optimization tactics merchants, processors, and acquirers have been using for years.
Level 2 and Level 3 as we know them are going away. Instead, there will only be one program: Product 3 Commercial Card Elements for eligible transactions.
Visa has launched the CEDP Commercial Card Program, which aims to consolidate Level 2 and Level 3 into a single program focused on accurate data. Under this new system, all Level 2 and Level 3 transaction data will be eligible for Product 3—but Visa will now validate the data you send using AI. As a merchant, you’ll need to make sure the data you pass is both eligible and accurate.
As I mentioned, as of now Visa doesn’t check if your data is correct—they only look for the presence of data elements. But once these changes roll out, Visa will actively monitor the data for accuracy using AI, and your ability to qualify for better interchange rates will depend on whether your data meets their standards.
While we don’t know exactly what Visa’s AI will evaluate or how they’ll determine accuracy, we do know that some merchants who currently qualify for these reduced rates might not qualify in the future.
That’s why it’s critical to stay ahead of these changes and make sure your data is accurate—so you can continue to receive the interchange benefits.
Keys to Maintain Existing IC Benefits
As Visa transitions to CEDP, it’s critical for you to ensure you maintain your current interchange (IC) benefits by becoming validated with your processor(s). Validation confirms that your Level 2 and Level 3 (L2/L3) data meets Visa’s new standards—qualifying you for the CEDP program and helping you secure the lowest possible interchange rates.
Visa recently released a CEDP User Guide, which outlines several key reports that processors will have access to, including:
- Transaction Detail Report: This provides detailed transaction-level data, highlighting invalid entries and any CEDP-specific error codes.
- Verified Merchant List: A master list from Visa showing all merchants who have passed validation.
You should request these reports from their processors to check if the current L2/L3 data you’re sending is accurate enough to validate under the new CEDP requirements. Without validation, you risk losing access to your interchange benefits.
To date, processors have not been widely sharing these validation reports with merchants. While some processors have started receiving data from Visa, they are still working to break down the information to the merchant level. As a result, all merchants need to take the initiative and start asking their processors for these validation details now to avoid surprises later.
Staying ahead of these changes will ensure you’re not leaving money on the table.
Understanding Interchange Cost Changes with Visa’s New CEDP Program
Under CEDP, those that send accurate data will be eligible for an additional 15 basis points in interchange benefits. However, because Visa is retiring Level 2 (L2) and moving to a unified Product 3 structure, if you’re currently relying on L2 data alone, you may lose existing benefits.
Visa will also introduce a 5-basis point network fee for participating in the CEDP program. This means if you meet the requirements and send valid CEDP data you can net an additional 10 basis points in overall savings per eligible commercial card transaction—a significant improvement if managed correctly.
Today, Level 3 (L3) interchange rates can be achieved even if the sales tax value is zero (using a local tax included field value of “2”), and Level 2 can be qualified with sales tax above a certain threshold. However, these options will expire in April 2026, as Visa phases them out in favor of the new Product 3 requirements. Moving forward, it will be essential to send line-item details, specifically the Product 3 detail fields, to qualify for interchange benefits.
Verification Status Matters
Visa will classify merchants as either Verified or Non-Verified within the CEDP program. This classification is critical: Verified merchants will qualify for the new interchange benefits, while Non-Verified merchants may lose them entirely.
Additionally, Visa retains the right to retroactively adjust interchange fees if they later determine that you’ve submitted incorrect or invalid data. In such cases, Visa can reclassify past transactions and charge merchants back for any benefits they improperly received—making accurate data submission not just important, but essential for avoiding costly reclassifications.
Error Codes and Monitoring
Visa has released a comprehensive CEDP User Guide with over 100 possible data validation error codes. These codes identify issues with submitted transaction data that could jeopardize your CEDP qualification.
To protect your bottom line, you will need to secure daily visibility into interchange charges and any reclassification adjustments and should proactively monitor error codes to correct data issues before they impact interchange costs.
Strategic Implications for Optimization
Visa’s CEDP isn’t just a compliance update—it’s a strategic shift. And if you’re managing significant commercial card volume, this is much more important than a simple data mapping exercise. This is about protecting your margins, improving data discipline, and tightening your entire reconciliation process.
Better Data = Better Results
If you’re not already treating data quality as a revenue driver, this is the wake-up call. Visa’s new validation requirements mean you can no longer send placeholder or generic values and expect to earn optimized interchange. A few key fields—like product description, quantity, price, tax, and merchant identifier—now carry significant weight. When you get that correct, you position your business to earn more favorable rates.
Reconciliation Just Got More Complicated
Let’s be real: if your processor misclassifies a transaction, or your feed isn’t properly tagged, you could see chargebacks or fee corrections weeks later. That means your team needs to track CEDP status across every transaction—and reconcile interchange adjustments over multiple cycles. If you’re not set up to handle that today, now’s the time to start building that infrastructure.
Your Processor Needs to Step Up
If your gateway or processor can’t support clean, structured L3 feeds with proper validation and error tagging, you’re at risk. You need systems that reject bad data before it’s submitted, not after. That means ditching defaults, fixing repetitive or missing fields, and making sure your metadata (like SKUs, product names, and tax breakdowns) reflects what you actually sell—not just what’s easy to send.
Recommendations: Optimizing for CEDP Success
So what should you actually do? Here’s how I’m advising clients to prepare:
- Tighten Your Data Governance
Start by auditing your data fields. Are you capturing rich product descriptions, accurate SKUs, and correct tax details? If not, fix that now. Incorrect data will get flagged by Visa’s AI, and you’ll lose your rate.
- Track Your Verification Status
Make sure you know which of your merchants or business units are Verified under Visa’s system—and which aren’t. Then build workflows to monitor changes and account for credits or unexpected debits in your interchange costs.
- Upgrade Your Reporting & Reconciliation
If you haven’t already, update your reporting tools to include Product 3 fees and any retroactive credits or charges. Some of these adjustments may hit you 10–15 days after the transaction, so plan to close that loop with AP/AR regularly.
- Prepare Your Systems & Teams
Your tech stack and ops team need to be aligned. Make sure your systems aren’t just passing data—they’re validating it before it hits the network. And if your teams aren’t familiar with what Product 3 requires, now’s the time to train them.
Final Word: CEDP = Opportunity & Discipline
Visa’s CEDP journey—from the April 2025 fee to the full Level 2 sunset in April 2026—is more than an incentive redesign. It signals a strategic shift toward high-quality, structured payments data—tied directly to financial benefits. For merchants and processors who optimize early and cleanly, CEDP offers solid gains in interchange savings and operational clarity. For those puzzled by lagged credits and data penalties, it’s a cautionary tale.
Through optimized tooling, rigorous governance, and smart reporting, you can not only survive this transition—but thrive—by aligning with the future of commercial card optimization.