For years, B2B merchants across many industries and sectors have relied on a three-tier system to manage credit card processing costs. By registering and systematically providing additional details to major credit card companies beyond a simple transaction amount, businesses could unlock lower interchange rates.
However, as of October 2025, Visa started enforcing the Commercial Enhanced Data Program (CEDP) verification requirement. CEDP replaces its legacy system with a more rigorous, AI-driven framework that prioritizes data integrity over mere data presence.
Will other prominent players follow suit?
Understanding the History of the 3 Level Programs
Historically, the payment management system was divided into three levels based on the amount of data merchants provided the credit card companies:
- Level 1: Basic info (amount, date) used for standard consumer transactions.
- Level 2: Enhanced data (tax amounts, customer codes).
- Level 3: Full line-item details (SKUs, quantities, shipping info).
The Key Weakness: Under the old rules, networks only checked if the required fields were present, not if they were accurate. Many merchants used placeholder values (like "9999" for tax) to trick the system into granting lower rates.
The 2025 Turning Point: Major Changes
The transition to CEDP began in April 2025 with an increase in Visa Assessment costs for all transactions passing L2 / L3 data. The full enforcement phase began in October 2025, introducing several shocks to the B2B payments landscape.
The Sunset of Level 2
The Sunset of Level 2 was scheduled for April 2026 but an early termination was announced in Late December of 2025. Level 2 savings was completely gone by the end of January 2026.
- The Exception: Only Fleet fuel-only transactions retain a legacy Level 2 fee category.
- The Impact: For all other B2B transactions, providing only Level 2 data will no longer result in a discount; merchants must now provide full Level 3 data to qualify for any savings under the new "Product 3" category.
Punitive Rates for Small Business Cards (January 2026)
In January 2026, Visa implemented steep rate increases that specifically targeted merchants sending poor data for small business cards:
- Due to the program termination, all Level 2 rates for small business cards increased by 75 basis points (0.75%).
- Product 3 (CEDP) rates increased by 65 basis points (0.65%).
- The Net Result: It is now 5 basis points more expensive if this change is ignored.
AI-Assisted Audits and "Verified" Status
Visa now uses machine learning to audit transaction data in near real-time.
- Verified Merchants: To get the best rates, you must maintain a high accuracy rate (typically around 90%) over time.
- The AI Trap: The AI explicitly flags "junk data," such as generic descriptions (e.g., "Product" or "Goods"), repeated characters (e.g., "XXXX"), or tax amounts that don't match the line-item math. Make sure data in your submissions are correct and not static placeholders.
- Please note: The verification process for Level 3 has been temporarily paused for any unverified merchants. Visa has not provided information as to when they will resume verifying merchants, but they are issuing interchange credit (refunds) for transactions that meet CEDP requirements.
Considerations for Americaneagle.com Clients
For B2B clients of Americaneagle.com, these changes require a proactive technical audit to avoid unexpected fee spikes.
- Audit Your Data Pipeline: Ensure your ecommerce platform isn't just "passing" data, but passing accurate data. Check if your checkout process or ERP integration is using generic placeholders that the new AI will reject.
- Gateway Compatibility: Use a CEDP-ready gateway that performs real-time pre-validation. These gateways catch errors (like mismatched tax logic or invalid ISO unit codes) before the transaction is sent to Visa, protecting your "Verified" status.
- Monitor Statements Closely: If you see UV or Unverified Visa transactions and not seeing a Visa CEDP verified credit in the assessment section of your statement, Visa’s AI is rejecting your current data format.
- The 0.05% Fee: Remember that a 0.05% participation fee now applies to all commercial transactions where enhanced data is submitted, regardless of whether you pass the audit. This makes "guessing" at Level 3 compliance a costly experiment.
If you have seen a recent, unexplained increase in bottom line fees in your monthly processing statements in 2026, reach out to us at Americaneagle.com and let us help bring clarity to your new pricing.
