Insights contributed by Evan Andersen
As a merchant, you should be paying close attention to changes that affect your costs. Every adjustment in interchange can impact your bottom line, and Visa’s new Commercial Enhanced Data Program (CEDP) is no exception. This allows Product 3 rates for Business cards now, which were not eligible for Level 3 rates in the past. These recent changes may directly affect how your commercial transactions qualify and what you pay in interchange fees.
On October 17, 2025, Visa broke new ground by rolling out its new Product 3 interchange rate changes and data quality enforcement (CEDP). This move brings Visa closer to fully retiring its existing Level 2 program by April 2026 (excluding fleet fuel transactions).
Visa’s CEDP merges the previous Level 2 and Level 3 incentive structures for small business and commercial cardholders into a single program. Under this new structure, all prior Level 2 and Level 3 transaction data qualifies for the reduced Product 3 rates – creating additional savings beyond current levels.
Merchants currently qualifying for Level 2 and Level 3 rates should see Product 3 rates that are 15 basis points lower than existing levels. Partially offset by a 5-basis point network CEDP participation fee, this will result in net savings of 10 basis points per eligible transaction.
For merchants not sending Level 2 and Level 3 data, the Product 3 rate is 90 basis points lower, netting 85 basis points in opportunity for reduced costs on eligible transactions. To realize these savings, businesses must meet Visa’s stricter CEDP standards and pass its AI-driven validation process.
Early Observations:
Through our Harmonize analytics dashboards, we’ve already seen several merchants experience higher interchange costs on transactions that were previously qualifying for Level 2 or 3 rates, even merchants that are fully supporting CEDP. If you notice this trend in your data, contact your payment processor immediately to determine why CEDP qualification isn’t occurring – this will directly impact your bottom line.
Early data suggests that Visa’s new CEDP structure introduces broader qualification opportunities for merchants. Transactions on Business cards that were eligible only for Level 2 could now qualify for reduced Product 3 rates, provided that data fields are complete and compliant with Visa’s enhanced validation requirements.
You may also begin to see new interchange rates labeled “Product 3” in your acquirer data. For example, one merchant’s data showed a rate titled “Visa Prod3 Business Credit Tier 1,” where the per-item fee of $0.10 remained constant, but the percentage fee dropped from 1.90% to 1.75%. These new rates apply across Small Business Tiers 1–5 as well as Purchasing and Corporate cards. To ensure accuracy, review and update your interchange table logic so your systems correctly recognize the new rate structure.
Additional Insights:
Visa’s validation process is supposed to be streamlined under CEDP due to their new AI automation, but nothing with AI is ever perfect. Even small errors in address, tax amount, or line-item details can prevent transactions from qualifying for the reduced rate. If your business uses automated invoicing or ERP integrations, make sure your data mapping includes all required fields to avoid missing out on savings.
Some merchants have also reported temporary fluctuations in qualification rates, particularly on transactions that previously performed well under Level 3. These issues often stem from acquirers that haven’t yet completed CEDP certification. As processors finish their rollouts, these inconsistencies should begin to stabilize.
Client Example:
One merchant saw their Level 2 and Level 3 qualification rates drop immediately after October 17. After working with their processor to identify this issue, they restored their qualification rates to normal. This reinforces the importance of maintaining accurate data submission to preserve savings under Visa’s new program.
What this chart shows: Level 2 penetration rate declined immediately after October 17th, meaning the current data did not pass the CEDP validation process for Product 3. The client fixed an error with the data and started receiving Product 3 qualification the next day.
What This Next Step in CEDP Means for You:
Visa’s CEDP and the new Product 3 interchange structure represent a significant evolution in how commercial transactions are evaluated and priced. To protect your savings:
- Monitor your acquirer data closely
- Review new “Product 3” rate descriptions
- Confirm with your gateway or processor that your setup meets Visa’s updated requirements.
To protect your savings and stay ahead of Visa’s evolving interchange rules, proactive monitoring is essential. Harmonize empowers merchants to track qualification changes, pinpoint missed opportunities, and ensure every transaction earns the best possible rate.
If you’d like to understand how Visa’s CEDP changes are affecting your business—or confirm that you’re capturing every dollar of potential savings—connect with Optimized Payments for a complimentary CEDP analysis through our Harmonize platform. Reach out to us at sales@optimizedpayments.