Visa’s Unexpected CEDP Changes Impacting Fees and Compliance Starting January 2026
Dan Carter
Senior Director, Payments
Chelsey Kukuk
Director, Payments
Immediate Release
We are sharing an important and time-sensitive update regarding recent Visa interchange changes that will impact small business card transactions. Visa released new guidance that has not yet been widely communicated across the market, and we want to ensure you are informed well ahead of the January 24th, 2026 effective date.
Background & Context
Initially, Visa released their new CEDP program at a very high level in April 2025, with the details rolling out overtime. The program was positioned as a framework to enhance security, accuracy and oversight of the data submitted with business, corporate, and purchasing card transactions. For a full background, please read our prior announcement on the program here.
Summary
If your business is sending Level 2 data on small business card transactions, your costs are going up. Under Visa’s updated terms effective January 24, 2026, Level 2 interchange for small business cards increases by 75 basis points, making it more expensive than sending no enhanced data at all. Unless transactions quality for verified CEDP, merchants with a sizable amount of small business cards processing at Level 2 should expect higher effective rates and increased cost exposure under the new Visa rules.
What’s Changing
Effective January 24th, 2026, Visa will implement two significant changes for business cards:
- Visa CEDP Business Tier 1-5 Product 3 interchange rates will increase by 65 basis points
- Level 2 interchange rates will increase by 75 basis points, making them equivalent to Business Product 1 rates (this is only applicable until April 2026)
- These increases apply only to small business cards. At this time, Visa has not announced any changes to CEDP Product 3 rates for corporate or purchasing cards.
Based on your current situation please find the scenario most common to you – you may have all three scenarios simultaneously
1. Not Sending Level 2 or Level 3 Data
- No change for either commercial or small business cards.
- Transactions continue to qualify at standard Business Product 1 rates.
2. Sending Level 2 or Unverified CEDP / Level 3 Data
If the Card type is a Small Business Cards
- A 5 basis point CEDP fee was added in April 2025.
- A 75 basis point interchange increase to prior Level II rates takes effect January 2026.
- Net result: Level 2 rates become 5 bps more expensive than sending no data at all.
- If transactions cannot qualify for verified CEDP, sending Level 2 data provides no cost benefit.
If the Card type is a Corporate / Purchasing Cards
- Only the 5 bp CEDP fee applies.
- No additional increases announced.
- Until Level 2 sunsets in April 2026, this still represents a 15 bp savings versus sending no data.
3. Sending Verified CEDP Data
If the card type is a Small Business Card
- October 2025: 15 basis point interchange reduction with a 5 basis point CEDP fee. So the cost was decreased by 10 basis points.
- January 2026: Visa introduced the CEDP verified Product 3 rate will now be 2.45% to 2.70%, representing 65 basis point increase from the October 2025 CEDP verified rates.
- Net outcome:
- 25 bp savings vs. Level 2
- 20 bp savings vs. sending no data
If the card type is a Corporate / Purchasing Cards
- No additional changes announced.
- By sending CEDP verified data savings remain at 75 basis points over legacy Level II and 90 basis points over Level I. 75 bp savings vs. Level 2
*0.05% = Visa Network’s fee for CEDP
Redbridge Thoughts
The most recent update to Visa’s Commercial Enhanced Data Program CEDP represents a significant reversal from the publicly announced program earlier in 2025. This unexpected escalation in cost exposure for merchants is extensive – and seemingly punitive in context of a change in the network’s honor all provisions. Redbridge internal data clearly demonstrates extensive growth in Visa Small Business issuing programs that significantly outpaces the Purchasing, Corporate, and Fleet card issuance that are programs that will continue to benefit from CEDP rates.. While the initial rollout of the CEDP in April 2025 established enhanced data standards, limited detail around CEDP verification, program qualification standards, and long-term implementation left many acquirers and merchants with incomplete visibility into how compliance would ultimately be evaluated and re-assessed over time.
The January 24th, 2026, effective date for the newly announced small business card rate adjustments – some of which are approaching an increase of approximately 75 basis points – raises concerns around timing and transparency. Based on our understanding, it appears the acquirers were notified in late 2025; however, communication to merchants has been limited and, in many cases, delayed. The timing of these updates over the holiday period, combined with minimal proactive outreach, has resulted in many merchants becoming aware of the changes only after the fact, leaving little opportunity for advance assessment or planning.
These changes reinforce the value of independent advisory support. As card brand programs become more complex, enforcement more automated, and more difficult to audit incentives, merchants benefit from partners who can interpret evolving requirements, provide clarity where communication is limited, and proactively support cost and risk management. Merchants should not hesitate to reach out with questions. We are available to provide guidance and assist in understanding and navigating these changes as the program continues to evolve.
Easy Next Steps
We recommend our clients treat these developments as a priority rather than a routine card brand update.
- Assess Exposure: Identify how much of your card volume is driven by small business cards and which transactions currently qualify at Level 2
- Validate Qualification Status: Confirm whether your transactions fully meet Visa’s verified CEDP requirements
- Assess Data & Processing Gaps: Review whether your current data capture, transmission, and processing workflows realistically support CEDP compliance
- Model the Financial Impact: Compare the projected cost of remaining at Level 2 vs moving to Level 3, verified CEDP, or reverting to unverified CEDP where appropriate
- Prioritize these actions before January 24, 2026