New Visa SaaS subscription rules for trial periods

Effective April 18, 2020, merchants must comply with new Visa subscription billing terms and conditions. These are, once again, big changes that merchants must take action on to comply with. The payment gateway will be critical, and not all are ready to meet the new technology requirements for authorization and receipts.

Who do the new Visa rules apply to?

  • All merchants globally
  • Merchants that offer a free or discounted introductory offer as part of a subscription service

What are key Visa SaaS subscription changes?

  • Merchants must get express consent to enter into agreement for recurring billing. For example, if an online purchase, a checkbox agreeing to the terms is acceptable.
  • Notification via text, email, or other agreed upon method (not realistic for most businesses), of the subscription terms including start date, product/service details, billing frequency, billing start date, and link to cancel.
  • Notification at least 7 days in advance of the expiration

Revised sale transaction receipts are required.

  • Details to include length of trial period, introductory offer, or promotional period, and notice the cardholder will be charged unless the cardholder takes steps to cancel.
  • Date it starts, even if no payment is due, and date subsequent recurring transactions begin.
  • A link to cancel or other simple method.

Payment Gateway and settlement changes to support new Visa Authorization is required.

Many payment gateways are not yet compliant with the October 2017 stored credential mandate and they won’t be ready with this either as it is not a simple update.

  • A new descriptor, “trial” or similar, must be sent with Merchant Name field of the Clearing Record for the first transaction at the end of a trial period. This descriptor will then appear on cardholder statements, online banking etc.

“This is another huge change that most merchants will probably have difficulty complying with because of outdated payment gateways,” according to Christine Speedy, 3D Merchant Services payment gateway expert.

Merchants must make it easier to cancel recurring billing.

This is actually an extension of rules and recommended changes over the last few years. For example, if a customer signs up online, they should be able to cancel online, not have to call on the phone. The new rule now says regardless of where they signed up, retail store or other, they must be able to cancel online.

Visa expands cardholder dispute rights for subscription billing via existing condition “Misrepresentation”.

Basically, merchants need to be able to prove that the cardholder expressly opted in, and they notified customer before processing after the trial period.

Visa will actively monitor trial period compliance.

This is huge. While they don’t state how, the advances of Artificial Intelligence (AI) make if fairly easy. Additionally, merchants that are using recurring billing properly already notify the parties in financial ecosystem that they are doing recurring billing via the 2017 recurring billing stored credential changes.

What are merchants benefits to comply with Visa rules?

Merchants can expect increased authorization approvals, better rate qualification (higher profits), and increased customer satisfaction. Merchants avoid getting shut down, fined, assessed fees, penalty fees and also reduce customer service bandwidth.

DISCLAIMER: condensed and incomplete information. Information may be quickly outdated. Follow links from our Merchant Rules web page here or click here to download Visa’s PDF with review and quick reference card. Two page PDF, 675kb.

Call Christine Speedy for compliant payment gateway solutions to maximize profits and improve your customer experience. 954-942-0483, 9-5 ET for all your recurring billing and stored credential payment gateway and virtual terminal needs.

Which Payment Gateways Support Stored Credential Requirements?

Rules for storing and using stored cards changed for merchants in 2017, yet many payment gateways in 2019 still don’t support the transaction requirements, opening risk of issuer chargeback, fines, and assessments to merchants. Since the card networks are now notifying acquirers of non-complaint merchants, it’s time to get serious about making updates.

The four types of stored credential transactions are recurring billing, installment billing and Unscheduled Credential On File, where buyer agrees to store the card and future transactions will be initiated either by merchant or buyer. Read more about the stored credential rules either by searching the blog for ‘credential’ or click here for card network rules. The payment gateway manages most of the compliance after merchants make the appropriate changes for standalone or integrated solutions, but merchants also have responsibility for getting the proper wording and opt-in record keeping for agreements to store cards.

Which payment gateways support authorization requirements for stored credentials? Ask gateways if they support your specific card not present transaction type. Even if they do, merchant compliance is not automatic and merchants cannot rely on web developers to automatically get them updated either. This list is valid as of today. Please comment below if you have new information about updates or more payment gateways to add to the list.

  • Authorize.net- No, see developer forum for updates.
  • Bluepay- Unable to determine.
  • Braintree- Yes, added MasterCard 1/18/19, Visa 2018.
  • CenPOS– Yes, since 2017, all transaction types. CenPOS does not publish developer information online. See contact info below for sales, integrations and developer assistance.
  • Cybersource- No, not if this article is still valid. It says they are getting ready.
  • Ingenico- Maybe. Yes, with Ingenico ePayments DirectLink on the international web site, but I was unable to find the related developer code for updating US ePayments needs.
  • Orbital (Chase)- Unable to determine.
  • Payeezy (First Data)- Yes, developer instructions.
  • PayFlow Pro- Unable to determine, doesn’t look like it.
  • Shift4 – No.
  • Vantiv/WorldPay- Maybe. With the merger of these companies, merchants might or might not be using a payment gateway that supports it. Developer info for Worldpay.

Call Christine Speedy, CenPOS Global Sales. 954-942-0483, 9-5 ET for a payment gateway compliant with stored credential rules that can be quickly implemented. CenPOS is an integrated commerce technology platform driving innovative, omnichannel solutions tailored to meet a merchant’s market needs. Providing a single point of integration, the CenPOS platform combines payment, commerce and value-added functionality enabling merchants to transform their commerce experience, eliminate the need to manage complex integrations, reduce the burden of accepting payments and create deeper customer relationships.

What is Recurring CoF Monitoring?

Recurring CoF monitoring is related to merchants using stored cards on file for recurring billing. Merchants are getting notices from acquirers about failing MasterCard Data Integrity reporting and, from what I’ve seen, only have two weeks to correct the issues.

The below merchant has been identified by the latest MasterCard Data Integrity reporting as failing Edit 21 – Recurring CoF Monitoring. Per MasterCard, all recurring payments are considered credential-on-file transactions.  MasterCard requires POS entry mode= 10 (credential-on-file) to be sent for transactions identified as recurring.  Please work with the POS vendor and these locations to correct the POS entry mode. If corrections are not completed, merchants are subject to non-compliance assessments and fines will be allocated.

Basically, a merchant must comply with rules about how a transaction is presented to the acquirer and the issuer for authorization. The payment gateway is largely in control of sending the correct data with each transaction. In the example violation notice, the merchant is not compliant with recurring payment rules which requires specific steps when storing a card for the first time and then for ongoing payments.

The 3Dmerchant.com blog has many articles about the Visa Stored Credential Mandate. Visa’s are the most stringent and by following them, merchants will also be compliant with MasterCard’s. The rules went into effect in October 2017, with enforcement delayed to May 2018. Despite some claims to the contrary on payment gateway web sites, the mere fact that a payment gateway can support the correct data set does not make a merchant compliant automatically. Merchants should read the rules on this web site, which includes links to the card brand rules.

Card brand rules (Visa, MasterCard etc) are constantly changing and many payment gateways have not kept pace with been given a notice, then don’t call your existing provider. The rules were announced in 2016 and went into effect for most businesses (some were earlier) in October 2017. If your vendor let this happen to you, it’s time to get advice from another source. Here’s a list of payment gateways compatibility status.

Call Christine Speedy, CenPOS Global Sales. 954-942-0483, 9-5 ET for all your stored credential payment gateway and virtual terminal needs. CenPOS is an integrated commerce technology platform driving innovative, omnichannel solutions tailored to meet a merchant’s market needs. Providing a single point of integration, the CenPOS platform combines payment, commerce and value-added functionality enabling merchants to transform their commerce experience, eliminate the need to manage complex integrations, reduce the burden of accepting payments and create deeper customer relationships.

Recurly Visa Stored Credential Framework blog omission

A Recurly blog article “How Recurly is Supporting Visa’s Stored Credential Framework” has some misinformation. The cited dates are incorrect and merchant responsibilities are understated. Why is that important? Most payment gateways and technology solution providers are not keeping up with the rapid pace of rules and compliance changes, impacting merchant profits and risk. Therefore, payment technology vendor selection, including payment gateway selection, is critical.

Recurly, like others in the cloud solutions space, is partially dependent on their partners to keep their clients in compliance with a myriad of rules. When should technology partners alert their integrated solutions partners about industry changes affecting their mutual clients? Solutions providers and merchants are getting inaccurate advice, or none at all, from trusted advisors, technology providers, and consultants of all sizes and sources.

As soon as Visa released the news in their Merchant Business News Digest in August 2017, Recurly began reaching out to our gateway partners to get ahead of the work required to fulfill the mandates.” The real dates were much earlier than cited. Visa typically announces at least one year in advance of due dates for any significant change, which this update is. Updates were in the October 2016 Visa Core Rules and Visa Product and Service Rules rules, citing changes coming in April and October 2017. On April 27, 2017 Visa published further information for merchants via the Stored Credential Framework document, which also references prior articles published on the subject dating back to 2016.

For most merchants, the mandate went into effect October 14, 2017, not April 2018, however, Visa did announce a delay in compliance action to April 2018.

From Recurly, “There is no action needed from our customers.” While technology solutions and payment gateways manage technical aspects for compliance, there’s much that’s left to merchants. Here’s an excerpt from the Stored Credential Framework document:

Merchants and their third-party agents, payment facilitators, or stored digital wallet operators that offer cardholders the opportunity to store their credentials on file must:
• Disclose to cardholders how those credentials will be used.
• Obtain cardholders’ consent to store the credentials.
• Notify cardholders when any changes are made to the terms of use.
• Inform the issuer via a transaction that payment credentials are now stored on file.
• Identify transactions with appropriate indicators when using stored credentials.

I strongly recommend reading Visa Core Rules Table 5-20: Requirements for Prepayments and Transactions Using Stored Credentials and Disclosure to Cardholder and Cardholder Consent. For example, how will you provide proof of cardholder consent (think time and date stamp) upon request? Are you providing the required receipt with proper format for zero dollars when storing a card without running a transaction?

Note: This article is not a review, endorsement or complaint about the quality of Recurly services which I have never used. It is simply identifying errors and omissions related to the stored credential mandate that may impact merchant profits, risk and decision making. I would have written in their blog comments, but it wasn’t available. When choosing a payment gateway, consider how agile they’ve been in meeting deadlines for changes, and how they’ll help reduce compliance burden, among other factors.

Christine Speedy, CenPOS Authorized Reseller, 954-942-0483 is a PCI Council QIR certified professional based out of South Florida, near Fort Lauderdale, and Rochester, NY, with extensive payment gateway experience. Christine can uniquely help merchants and technology providers navigate the complexities of PCI, acquirer, and card brand compliance rules.

Are You Compliant? B2B Credit Card Processing Fact Check

Merchant compliance with various credit card processing rules maximizes profits while mitigating risk. This is especially true for business to business companies. But that task is getting harder and harder with the onslaught of new rules, and virtually impossible if not using a sophisticated cloud solution to help manage compliance.

b2b visa stored credentialIf your B2B company stores credit cards, there’s a pretty good chance you’re not compliant. For example, Visa’s 2017 Stored Credential Transaction framework (PDF download from Visa) outlines merchant responsibilities to obtain customer consent as well as storing credit cards, using stored credentials (token), and managing stored tokens. Failure to comply with Authorization rules, for example preauthorization and final settlement do not match, has far-reaching consequences including higher interchange rates (the bulk of credit card processing fees), penalty fees and new chargeback risks. With so many new rules across multiple card brands that vary based on business and transaction type how can a business quickly ascertain if they’re compliant?

Quick tips to validate compliance:

  1. Is cardholder authentication performed when a new card is stored? When the cardholder data is entered and submitted, the issuer responds with an approval or declined message. A small charge is not an acceptable practice to submit transaction for approval; instead a zero dollar authorization request for authentication is submitted. If authentication is via 3-D Secure -Verified by Visa, MasterCard Secure Code, whereby the customer self-authenticates vs merchant initiating, reduced rates may apply. Under the new rules, two transactions occur at the time a card is stored. Compliant answer is yes.
  2. Is a transaction receipt delivered to customer when you store a credit card? This will be either for an amount or a zero dollar authorization. When stored credit card credential (token) is created, a transaction receipt is generated with the approval or decline and other mandatory fields. Compliant answer is yes.
  3. Does the receipt include “RECURRING” or “REPEAT SALE” for token transactions? Compliant answer is yes.
  4. Review merchant statements, usually the last 1-2 pages with the heading “pending interchange” or “fees” section. Do you see EIRF, STANDARD (STD), or DATA RATE I? Compliant answer is no.
  5. Can you produce documentation of customer consent to store their card (including with 3rd party service) and how it will be used?

If you’re not in compliance, your payment gateway is the most likely culprit, followed by ERP or other software integration limitation. I can fix that.

Reference: Links for all Card brands.

Need help getting compliant?

Call Christine Speedy, , for simple solutions to complex payment transaction problems, 954-942-0483, 9-5 ET. CenPOS authorized reseller based out of South Florida and NY. CenPOS is an integrated commerce technology platform driving innovative, omnichannel solutions tailored to meet a merchant’s market needs. Providing a single point of integration, the CenPOS platform combines payment, commerce and value-added functionality enabling merchants to transform their commerce experience, eliminate the need to manage complex integrations, reduce the burden of accepting payments and create deeper customer relationships.