April 2026 Dispute Intelligence Brief

Issue April 2026 monthly brief

Top Story VAMP 1.5% effective today

Networks Covered Visa + MC plus agentic commerce

Action Required Immediate VAMP threshold live

LEAD STORY: VAMP Excessive Threshold Drops to 1.5% — Effective Today

The temporary relief Visa extended in May 2025 is now over. When Visa launched VAMP (Visa Acquirer Monitoring Program) and announced its Excessive threshold, a 2.2% transitional figure was put in place for the first phase. That transitional threshold expires today, April 1, 2026. Merchants in the United States, Canada, Asia-Pacific, and Europe are now subject to the originally planned 1.5% Excessive threshold.

LAC (Latin America and the Caribbean) merchants were already operating at 1.5% and see no change. For every other region, the window has narrowed significantly.

Effective April 1, 2026 — No Grace Period

The 2.2% transitional Excessive threshold is gone. Merchants in the US, Canada, AP, and Europe who were operating between 1.5% and 2.2% are now in violation of the VAMP Excessive tier. There is no additional grace period. Enforcement begins with today’s reporting cycle.

Why This Matters More Than the Launch Did

When VAMP launched on April 1, 2025, many merchants benchmarked their ratios against the 2.2% transitional threshold and considered themselves safe. Merchants who were comfortable at 2.0%—well under 2.2%—are now in violation at 1.5%. The practical effect is that a large segment of merchants who took no action over the past year are now Excessive without knowing it.

The VAMP ratio covers both fraud-related and dispute-related activity. It is calculated at the acquirer level but driven by individual merchant performance. A merchant who accounts for a disproportionate share of their acquirer’s VAMP ratio will draw direct attention regardless of whether the acquirer is technically over threshold.

Region	Previous Threshold	Current Threshold (April 1)	Change
US, Canada	2.2% (transitional)	1.5%	-0.7 percentage points
Asia-Pacific	2.2% (transitional)	1.5%	-0.7 percentage points
Europe	2.2% (transitional)	1.5%	-0.7 percentage points
LAC	1.5%	1.5%	No change

Immediate Action Items

Request TC40 data from your acquirer today. TC40 is the fraud reporting feed that feeds directly into VAMP calculations. You cannot manage your VAMP ratio accurately without knowing what fraud volume your acquirer is seeing from your MID. Call your acquirer’s risk team—not your account manager—and request a current TC40 summary.
Audit your VAMP ratio with the new 1.5% benchmark. Recalculate your trailing 90-day dispute and fraud rate against the 1.5% threshold, not the 2.2% figure you may have been using. Above 1.5%, you are in the Excessive tier with higher penalty exposure. Industry observers anticipate the potential for further reduction in the VAMP Excessive threshold between 2027-2029, though Visa has not confirmed specific figures or dates.
Implement pre-dispute alerts if you have not already. Ethoca Alerts and Verifi Alerts surface potential chargebacks before they are filed. At the current VAMP threshold, every deflected dispute has direct ratio impact. Pre-dispute tools are no longer optional for merchants with meaningful dispute volume.
Enroll in RDR for eligible dispute categories. Visa’s Real-time Dispute Resolution automatically resolves flagged disputes before they become chargebacks. RDR-resolved disputes do not count against your VAMP ratio. If you are not enrolled, contact Verifi to initiate the enrollment process.
Review your refund velocity on borderline orders. Pre-dispute refunds do not count against VAMP. For orders above your cost threshold where the risk profile is ambiguous, a proactive refund before a dispute is filed is VAMP-neutral. A chargeback on the same order is not.

The Core Issue

The merchants most at risk from today’s threshold change are those who saw the 2.2% transitional figure and treated it as a permanent operating ceiling. That ceiling no longer exists. If your VAMP ratio is anywhere above 1.3%, you should be treating this as an active risk management situation—not a compliance checkbox.

Network Updates — April and Beyond

Visa CE 3.0 Updated Requirements — Effective April 17, 2026

Starting April 17, 2026, Visa is updating the qualification requirements for Compelling Evidence 3.0 submissions. This is a significant shift in how CE 3.0 works in practice. Visa is tightening expectations around the quality of CE 3.0 submissions, reinforcing that merchants should only use this defense when the evidence genuinely qualifies. Non-qualifying submissions will face stricter scrutiny and potential penalties.

CE 3.0 requires that prior undisputed transactions match the disputed transaction on at least two of three criteria: same shipping address, same device ID or fingerprint, or same IP address. If your transaction data does not capture device and IP at the time of purchase, your CE 3.0 submissions are very likely to fail under the updated requirements. After April 17, the consequences for submitting non-qualifying CE 3.0 responses will be more significant.

CE 3.0 Qualification Checklist (Before April 17)

Confirm your transaction records capture device ID or fingerprint at the time of purchase—not just at account creation.
Confirm your transaction records capture IP address at checkout. Billing IP is insufficient; capture the checkout session IP.
Verify your prior undisputed transactions for the cardholder match on at least two of the three CE 3.0 criteria before submitting.
Update your dispute management process to run a CE 3.0 eligibility check before any Visa 10.4 response is submitted after April 17.

Visa Level 2 Interchange Phase-Out — Effective April 17, 2026

Visa is implementing changes to Level 2 data requirements effective April 17, 2026. Level 2 interchange applies primarily to B2B card transactions and requires enhanced data fields including tax amount, customer code, and merchant postal code. Merchants who rely on Level 2 rates for corporate card acceptance should confirm with their payment processor that their integration captures and transmits the required data fields under the updated requirements. Failure to submit qualifying Level 2 data will result in transactions downgrading to Level 1 interchange rates—a meaningful cost increase on high-ticket B2B volume.

Mastercard Scam Merchant Monitoring Program — Launches July 24, 2026

Mastercard is launching a new monitoring program on July 24, 2026 that specifically targets merchants involved in scam transactions. The Scam Merchant Monitoring Program is distinct from existing fraud monitoring programs in that it focuses on merchants whose transaction patterns indicate involvement in consumer scam schemes—including authorized push payment fraud, advance fee fraud, and investment scams where the consumer willingly initiated the transaction but was deceived.

For most legitimate merchants, the primary concern is false positives: being enrolled in the monitoring program due to elevated dispute rates on categories that superficially resemble scam patterns. Merchants in digital goods, investment-adjacent services, and high-ticket subscription categories should begin documenting their business model and customer communication practices now, in anticipation of potential acquirer inquiries once the program launches.

July 24, 2026 — Prepare Now

The Mastercard Scam Merchant Monitoring Program launches in less than four months. If your business category has overlap with scam-adjacent transaction patterns, proactive documentation of your legitimate business operations will be your primary defense against erroneous enrollment. Start building that documentation file now.

Fraud Trends — April 2026

$28.1 Billion in Projected Global Merchant Fraud Losses for 2026

Industry projections now put global merchant fraud losses at $28.1 billion for 2026, a figure that continues a multi-year upward trajectory. The growth is not evenly distributed: digital goods, marketplace platforms, and recurring billing merchants are absorbing a disproportionate share of the increase. Card-present fraud, by contrast, has remained relatively stable as EMV adoption has matured in major markets.

The $28.1 billion figure represents direct fraud losses—it does not include associated chargeback fees, operational response costs, or the revenue impact of false declines implemented as fraud countermeasures. When those factors are included, the total merchant cost of fraud significantly exceeds the headline number.

Double-Dipping: 41.6% of Chargebacks

New data shows that 41.6% of chargebacks now involve “double-dipping”—where a cardholder has already received a refund from the merchant and subsequently files a chargeback on the same transaction. The cardholder effectively recovers the transaction value twice: once through the merchant’s refund process and once through the chargeback mechanism.

Double-dipping is technically first-party fraud. It is also one of the most straightforward disputes to win—if you have documentation. A merchant who can present a refund confirmation with timestamp, the refund transaction ID, and the date the funds cleared back to the cardholder’s account has overwhelming evidence in most networks’ adjudication frameworks. The problem is that many merchants do not connect their refund records to their dispute records at the time of response. By the time the chargeback arrives, the refund documentation exists but is not surfaced automatically in the dispute workflow.

Immediate Fix for Double-Dipping Exposure

If your dispute management process does not automatically cross-reference incoming chargebacks against your refund ledger, fix that now. At 41.6% prevalence, roughly four out of every ten chargebacks you receive may already have a refund associated with them—and if you are not surfacing that refund in your response, you are losing winnable disputes on documentation that already exists in your system.

Social Media Normalization of Chargeback Abuse

The trend of social media content normalizing chargeback abuse as a consumer strategy continues to accelerate. Content on major platforms explicitly instructs viewers to file chargebacks rather than contact merchants for returns, treats chargeback filing as a routine financial optimization tool, and in some cases provides step-by-step guidance on constructing dispute claims. The effect on merchant dispute rates is measurable: merchants with high social media customer acquisition costs tend to see elevated first-party fraud rates compared to merchants who acquire customers through other channels.

The structural problem is that the current dispute system’s default posture favors the cardholder. A cardholder who files a dispute based on social media instruction faces minimal friction and minimal consequence for a false claim. The merchant bears the cost of the refund, the chargeback fee, and the VAMP ratio impact—even when the dispute is eventually won. Until network-level consequences for serial dispute filers are implemented, merchant-side prevention (RDR, pre-dispute alerts, CE 3.0) remains the primary mitigation tool.

Agentic Commerce Update

AI agent transactions are moving from experimental to operational across the payment ecosystem. The infrastructure is advancing faster than the dispute rule framework, creating ongoing exposure for merchants who accept agent-initiated payments.

Visa TAP Expanding Partner Network

Visa’s Trusted Agent Protocol (TAP) is expanding its partner network in Q2 2026. TAP provides a cryptographic token framework that allows AI agents to execute payments on behalf of cardholders with verifiable authorization chains. The expanding partner network means more AI agent platforms will have access to TAP-compliant payment rails—which in turn means a larger share of agent transactions will flow through a recognized authentication framework rather than standard CNP processing.

For merchants, TAP participation does not yet come with updated chargeback rules. A TAP-authenticated agent transaction that results in a dispute is still adjudicated under existing CNP frameworks. The authentication evidence is useful in a dispute response but does not create a categorical defense the way chip-and-PIN does in card-present fraud disputes.

Mastercard Verifiable Intent Gaining Adoption

Mastercard’s Verifiable Intent standard, which creates an auditable record of a cardholder’s authorization for an AI agent to act on their behalf, is gaining adoption among major AI agent platforms. The standard is designed to address the core evidentiary gap in agent transaction disputes: proving that the human cardholder actually authorized the specific action the agent took.

Adoption is still early-stage, and Verifiable Intent records are not yet a formal part of Mastercard’s dispute evidence framework. Merchants who accept payments from agent platforms that implement Verifiable Intent should begin capturing and storing these records alongside transaction data—they are likely to become relevant evidence as dispute rules evolve.

Current State: No Dispute Rule Changes for Agent Transactions

Neither Visa nor Mastercard has implemented updated chargeback rules specifically governing AI agent transactions as of April 2026. Existing dispute frameworks apply. This means:

A cardholder can dispute an agent-initiated transaction under existing CNP reason codes regardless of whether the agent had TAP or Verifiable Intent authorization.
CE 3.0 is difficult to apply to agent transactions because IP and device matching will reflect the agent’s infrastructure, not the cardholder’s personal device.
The most defensible position for merchants accepting agent payments is explicit per-transaction authorization documentation stored at the time of sale—not just platform-level consent agreements.

Key Dates — April Through July 2026

April 1 VAMP 1.5% Excessive threshold takes effect. The 2.2% transitional threshold is retired. Merchants in US, Canada, AP, and Europe are now subject to the 1.5% Excessive tier. Request TC40 data from your acquirer and audit your VAMP ratio immediately.

April 17 Visa CE 3.0 updated requirements take effect. Non-qualifying CE 3.0 submissions on Visa 10.4 disputes will face stricter scrutiny and potential penalties. Confirm your transaction records capture device ID and checkout IP before submitting any CE 3.0 responses after this date.

April 17 Visa Level 2 interchange changes take effect. Updated Level 2 data requirements apply. B2B merchants accepting corporate cards should confirm their integration transmits all required Level 2 fields to avoid interchange downgrade to Level 1 rates.

July 24 Mastercard Scam Merchant Monitoring Program launches. New monitoring program targeting merchants involved in scam-pattern transactions. Merchants in digital goods, subscription, and investment-adjacent categories should prepare documentation of their legitimate business operations before this date.

One Action This Week

Call your acquirer’s risk team today and request your current TC40 data and VAMP ratio. Ask specifically: what is my VAMP ratio under the new 1.5% Excessive threshold, and am I currently in any monitoring tier? Do not rely on your account manager to surface this proactively—go directly to the risk team.

Monthly Intelligence Brief — April 2026