What is CEDP and why is Visa implementing it?

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The Visa Commercial Enhanced Data Program (CEDP) is a new interchange framework for U.S. commercial and small business credit cards, launching in 2025.

Purpose:

• Simplify commercial card interchange by consolidating Level 2 and Level 3 into a unified Product 3 structure
• Reward merchants who submit clean, validated enhanced data (Level 2/3) with lower rates (10 bps overall impact for applicable Visa card types)
  • 15 bps decrease in interchange rates on Visa Product 3
  • New 5 bps CEDP fee charged by Visa on all Level 2/3 volume
• Improve data quality to enhance fraud prevention, compliance, and reporting
• Expand access to lower rates for small business cards, currently limited to corporate and purchasing cards

Visa is implementing CEDP to address the complexity and data quality issues of the legacy Level 2/3 system, ensuring only merchants providing accurate, non-static, and complete data receive preferred rates, and to encourage adoption of enhanced data for all commercial payments.

Key Changes: From Level 2/3 to CEDP Product 3

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1. Merchant verification now required
   1. Only merchants submitting clean, accurate, and non-static data will be “verified” and receive the new lower Product 3 rates
   2. Merchants with incomplete or inaccurate data will be classified as “non-verified” and not be given immediate access to interchange benefits
2. All fields must pass arithmetic validation
   1. The sum of all fields within the payload must equal total authorization amount
   2. Total Authorization Amount = (Unit Quantity x Unit Amount) + Tax Amount + Shipping Amount
3. Consolidation to a single Product 3 tier
   1. The separate Level 2 (April 16, 2026) and Level 3 (October 17, 2025) interchange categories are being eliminated
4. All Level 3 fields required to be sent for Product 3
   1. Payments can still qualify for level 2 until April, 2026
5. New fee structure introduced
   1. All CEDP payments with Level 2/3 data will incur a 0.05% (5 bps) participation fee. Cards not eligible for Product 3 or Level 2/3 processing will not be charged the 5 bps fee.

Merchant enrollment process

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Visa is performing ongoing merchant verifications for CEDP using machine learning based on historical enhanced data quality payments from merchants.

Status Assignment (Verified or Non-verified)

• All merchants will onboard in a non-verified status
• If 90% of the data sent with relevant payments (business, corporate, purchasing cards, etc.) meet CEDP requirements over the previous 30 calendar days of processing, merchants will gain the ability to move to a verified status.
• Merchants can be moved back to the non-verified status by sending less than 90% validated payments in the previous month.
• Merchants can correct their data being sent with payments to be added to the CEDP verified list.
• Rainforest enrolls and un-enrolls all verified and non-verified merchants once per month. There is no action required by the Platform or the Merchant to update the merchant's CEDP status.

Interchange Implications of Merchant Verification

• Payments from verified merchants will receive interchange incentives in real-time.
• Payments from non-verified merchants will receive lagged interchange incentives. Interchange will be adjusted to reflect the appropriate interchange rate after Visa performs Payment Data Quality Validation up to 45 days after the transaction.

CEDP timeline

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• April 2025: New CEDP fee charged on all Level 2/3 payments
• August 1, 2025: Recommended date to complete initial CEDP changes for testing and validation with Visa
• October 17, 2025: CEDP Product 3 rates become effective; Level 3 program sunsets (except Fleet fuel-only)
• April 2026: Level 2 program sunsets (except Fleet fuel-only)

Recommended implementation timeline

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• August 15, 2025: Begin sending quality Level 3 data for all payments
• September 15, 2025 - October 17, 2025: Based on feedback from Visa, correct any errors present in the data set to prepare for mass launch on October 17, 2025
• October 17, 2025: Live with new CEDP structure

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Tax exempt payments

Key Note: If a significant portion of payments are tax exempt, please reach out to Rainforest directly to discuss strategy for implementation as we may recommend a more nuanced approach to the CEDP implementation.

Interchange rate comparison: current vs. new CEDP

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Rainforest level 2/3 field requirements

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See the Level 2/3 processing guide for how to pass the necessary level 2/3 fields to Rainforest to meet CEDP requirements.