Visa’s New Compliance Framework: Five Steps Merchants Should Take Ahead of VAMP Enforcement

Starting October first, Visa will begin enforcing its updated Visa Acquirer Monitoring Program—VAMP—a new compliance model designed to consolidate and modernize how the network monitors fraud and dispute activity. For merchants, the implications are significant. VAMP introduces a single, combined ratio for chargebacks and fraud reports, creating a new threshold-based system with potential financial penalties for those who exceed it.

Unlike previous programs, VAMP blends metrics for both fraud (TC40s) and chargebacks (TC15s), and applies double-counting in cases where fraud is reported and a chargeback. This introduces new complexity into compliance operations, particularly for merchants who lack direct access to their own risk data. With enforcement beginning in October and thresholds tightening further in April 2026, now is the advisory period, which is the opportunity for merchants to assess their exposure, review current practices, and ensure their systems—and partners—are prepared for the transition.

1. Understand the New Rules—and Your Own Risk
The foundation of VAMP compliance is accurate monitoring. That begins with understanding Visa’s definitions: TC40s are fraud reports, and TC15s are chargebacks—both fraudulent and non-fraudulent. Visa now calculates a merchant’s VAMP ratio as (TC40s + TC15s) divided by total transactions (TC05). Merchants with more than 1,500 combined incidents per month and ratios above 2.2 percent may be enrolled in the excessive program. The threshold drops to 1.5 percent next year in April. However, merchants often lack visibility into TC40 data, which is held by acquirers. Engaging your acquirer early to access this information is essential.

2. Use Internal Data to Proactively Reduce Disputes
Reducing chargebacks and fraud reports remains the most direct way to remain under VAMP thresholds. Beyond standard tools like 3D Secure and velocity checks, merchants should make fuller use of their own chargeback data. Analyzing this information can surface patterns—seasonal issues, fraud rings, or procedural breakdowns—that often go unnoticed. Centralizing this data across PSPs and operational teams can support smarter interventions and long-term process improvements.

3. Open a Dialogue With Your Acquirer
Merchants are not the only ones subject to VAMP scrutiny. Acquirers also have defined thresholds under the program, and their performance may impact the treatment of individual merchants in their portfolios. Merchants should use this advisory period to ask acquirers key questions: What is your current VAMP ratio? How will you manage underperforming portfolios? Are there planned changes to your monitoring practices or contractual terms in light of VAMP? These conversations can clarify risk-sharing expectations and help preempt downstream penalties.

4. Evaluate Pre-Dispute Tools as Strategic Levers
Visa supports tools that help resolve disputes before they escalate. Services like Rapid Dispute Resolution (RDR) and the Cardholder Dispute Resolution Network (CDRN) can prevent TC15s from being recorded, while Order Insight (Compelling Evidence 3.0) enables data-sharing that may prevent both fraud reports and chargebacks. Each solution carries cost and operational considerations, but merchants operating near the threshold—or with high chargeback exposure—may find them effective as part of a broader strategy. These tools are becoming essential components of modern dispute management, particularly for merchants who are close to or have passed the VAMP ratio limits. 

5. Align Chargeback Strategy With the New Economics
The final step is one that many merchants are only beginning to fully appreciate: chargeback management is no longer just about recovery rates. It’s now a cost-optimization challenge. In this new landscape, the most forward-looking solutions use predictive technology to evaluate each chargeback on a case-by-case basis: projecting success rates, calculating potential fees, and recommending whether to dispute or accept a case.

This approach reflects a broader evolution in the market. Rather than simply fighting every chargeback, merchants are beginning to prioritize disputes that offer the highest net recovery. Decision automation—driven by configurable inputs, real-time data, and evolving machine learning models—is reshaping how chargeback programs operate. For merchants preparing for VAMP and looking to protect revenue in a more complex ecosystem, adapting to this new standard will be essential.

Visa's VAMP framework may have raised the compliance stakes, but it also offers merchants a clear opportunity to modernize and future-proof their operations. The tools and strategies now emerging don't just help businesses meet regulatory standards—they also position them for smarter, more resilient growth in an increasingly dynamic payments environment.