Payment Compliance Program Thresholds

Visa Acquirer Monitoring Program. Replaced the retired VDMP (dispute monitoring) and VFMP (fraud monitoring) with a single combined, count-based ratio. There is exactly one merchant tier — Excessive; the "Above Standard" tier exists only at the acquirer level. Figures per Visa's VAMP fact sheet (PDF).

• Formula: count of (TC40 fraud + TC15 disputes) ÷ count of settled (TC05) card-not-present VisaNet transactions, per calendar month — count-based, not dollar-based
• Merchant threshold: 1.5% since April 1, 2026 in AP, Canada, EU, and US (reduced from 2.2%); LAC was already 1.5%; CEMEA remains 2.2%
• Minimum-count gate: the ratio only applies at ≥1,500 fraud+dispute transactions per month (CEMEA: ≥150 and ≥USD 75,000)
• Exclusions: disputes resolved via RDR/CDRN pre-dispute tools and TC40s qualified under Compelling Evidence 3.0 are excluded from the numerator
• Acquirer vs merchant: merchant-level thresholds apply only when the merchant's acquirer is itself below Above Standard (<0.5%)
• Exit: identification reassessed monthly — Visa publishes no formal multi-month exit window

Full operator's guide: Visa VAMP Explained →

Excessive Chargeback Program (ECP) is the program; its two tiers are ECM (Excessive Chargeback Merchant) and HECM (High Excessive Chargeback Merchant). Both tiers require the chargeback count and the ratio to be breached. Figures per Stripe's monitoring-programs documentation.

• Formula: current-month chargeback count ÷ preceding month's captured transaction count
• ECM fines: Mo 1: $0 · Mo 2–3: $1,000 · Mo 4–6: $5,000 · Mo 7–11: $25,000 · Mo 12–18: $50,000 · Mo 19+: $100,000
• HECM fines: Mo 1: $0 · Mo 2: $1,000 · Mo 3: $2,000 · Mo 4–6: $10,000 · Mo 7–11: $50,000 · Mo 12–18: $100,000 · Mo 19+: $200,000
• Issuer Recovery Assessment: USD 5 per chargeback above 300, from month 4 onward, in both ECM and HECM. Example: a month-4 ECM merchant with 400 disputes owes $5,000 + (400−300)×$5 = $5,500
• Exit: Both ratio + count below thresholds for 3 consecutive months
• Nuclear outcome: Persistent breach can lead to MATCH list placement (5-year ban from Mastercard processing)

Full operator's guide: How to Exit Mastercard ECM →

Excessive Fraud Merchant — Mastercard's separate fraud monitoring track, distinct from chargeback-focused ECM.

• Formula: fraud dollar amount ÷ total sales dollar amount, per month
• Volume floor: $50,000 in monthly fraud AND 1,000+ transactions
• Notes: EFM is dollar-based, not transaction-count-based. A subscription app with many small fraud transactions can stay under the $50K floor even at elevated fraud ratios

Chargeback Monitoring Program. Amex operates a closed loop (acquirer + issuer in one), so enforcement is typically more direct and faster than Visa/Mastercard.

• Note: Amex thresholds are less publicly documented than Visa/Mastercard. Specific values are typically disclosed only to merchants directly during enforcement
• Volume floor: Effectively none for Amex — they can review at low volume
• Exit: Bilateral; depends on Amex risk team assessment of remediation
• Practical: For most subscription apps, Amex transaction share is small enough that Amex enforcement comes later than Visa/Mastercard

Discover's program mirrors Mastercard ECM in structure — chargeback ratio + absolute count, with US-focused enforcement.

• Note: Discover's program is functionally similar to Mastercard ECM but with smaller volume and US-focused enforcement
• Practical: Most subscription apps Discover-volume is <5% of total — enforcement here is rarely the binding constraint

Member Alert to Control High-risk merchants. A 5-year placement that effectively bars the merchant principal from acquiring relationships across most major networks.

• Owner: Mastercard maintains the list; queried by Visa and other networks during merchant onboarding
• Duration: 5 years from placement
• Common triggers: Excessive chargebacks, fraud convictions, identity theft, money laundering, bankruptcy/insolvency, illegal merchant activity
• Reason codes: 13 numeric reason codes — for subscription apps, the most common are 12 (excessive chargebacks) and 04 (excessive fraud)
• Exit: Not removable on demand; serves the full 5-year term unless successfully challenged