Visa Just Rewired the Chargeback Rules for Card-Absent Fraud: Multi-Merchant Evidence Is Live, But It Stops at Your Acquirer
TL;DR
Since 24 October 2026, Visa’s Compelling Evidence 3.0 (CE3.0) rules allow merchants responding to qualifying card-absent fraud disputes, reason code 10.4, to use two undisputed transactions from one or more merchants. That is a significant change from the original same-merchant model. But it is not a Visa-wide search across every merchant: at pre-arbitration, an acquirer can submit only transaction data it accepted and processed itself. In practice, cross-merchant evidence depends on the acquirer’s portfolio and technical integration.
Visa has expanded the evidence available for reason code 10.4 disputes, but merchants should not assume that the new option is already available through their provider. The key question is whether their acquirer can retrieve and submit eligible transaction history from other merchants in its own processing portfolio.
What changed in Visa CE3.0 on 24 October 2026?
The expansion means the two qualifying undisputed transactions used in a CE3.0 response can now come from one or more merchants. Previously, both had to come from the same merchant.
The transactions must fall within the existing CE3.0 lookback window: 120 to 365 days before the dispute. The change applies to Visa Dispute Condition 10.4, “Other Fraud – Card-Absent Environment”, and is intended to help address first-party misuse, often called friendly fraud.
CE3.0 began in 2023 with a narrower evidence model. The 2026 expansion recognises that a cardholder’s undisputed activity at another merchant may help demonstrate a connection to a disputed purchase. It widens the evidence pool, rather than removing the existing requirements. Merchants still need two eligible, undisputed transactions and evidence that meets Visa’s criteria.
Why does “multi-merchant” still stop at the acquirer?
Because an acquirer can only submit transaction data that it accepted and processed itself at pre-arbitration. A prior transaction at another merchant may be useful only if that merchant’s transaction was processed within the same acquirer’s portfolio, and the acquirer can retrieve the relevant information.
That makes the operational meaning of “multi-merchant” more constrained than the headline suggests. Visa has broadened which merchants’ transactions can qualify, but the rule does not automatically give one acquirer access to every Visa merchant’s history.
Nor is the capability automatic within a provider’s portfolio. Processors and acquirers need technical integration to surface and submit the cross-merchant signals. Merchants should ask their acquirer or processor this week:
Can you retrieve qualifying CE3.0 history from other merchants in your portfolio?
Which transaction fields can you provide for a 10.4 response?
How do you confirm transactions are undisputed and within the 120-to-365-day window?
What information or identifiers must we supply to make a cross-merchant match possible?
The answer may depend on the provider’s systems and implementation, not just the scheme rule. That is consistent with a broader payments lesson: an acquirer’s capabilities are part of the product, not just plumbing. See our analysis of why acquirer capability can shape payment performance.
How do payment tokens and recurring payments affect the evidence?
Payment tokens can qualify as evidence. Visa can pair tokenised transactions using the underlying card account, so an eligible historical transaction does not have to use identical visible credentials to the disputed transaction.
This makes tokenisation more than a security measure. In our interpretation, it can become a chargeback defence asset: when tokenised transactions are linked to the underlying card account, they may contribute to a stronger evidence record. That does not make a transaction automatically eligible; it must still meet the other CE3.0 conditions, and the acquirer must be able to retrieve and submit it.
Recurring payments have a specific evidence consideration. For merchant-initiated transaction (MIT) renewals, the IP address from the original customer-initiated transaction (CIT) can be used as evidence. For subscription businesses, that makes retention and organisation of the initial transaction’s data especially important.
The 120-to-365-day window also has practical consequences. Businesses need to retain relevant transaction records long enough to support a possible dispute, while ensuring their data practices align with applicable obligations. In our view, data retention is becoming part of dispute management strategy, not simply a back-office setting.
What does the CE3.0 expansion not cover?
CE3.0 applies strictly to reason code 10.4 card-absent fraud disputes. It does not apply to reason code 13.2, which covers cancelled recurring transactions. A dispute about a subscription cancellation therefore does not become eligible for CE3.0 simply because it concerns recurring payments.
This distinction matters. A merchant may have relevant recurring-payment evidence, including the IP address from the initial CIT, but the dispute must still be a qualifying 10.4 case for CE3.0 to apply. The expansion is not a universal solution for subscription disputes or all Visa disputes.
It is also too early to treat the rule change as a guaranteed improvement in win rates. The change creates an additional evidence option; it does not confirm that a particular acquirer has implemented the necessary retrieval tools or that every submission will succeed. Providers should test the process with their acquirer and assess the results before forecasting a material change in dispute outcomes.
For a broader look at how payment providers are approaching fraud signals, see our article on Visa’s AI upgrade to account-to-account fraud prevention.
Does the change apply to Australian merchants?
Yes. This is a global Visa rule change, not a rule limited to a particular country. Australian merchants accepting Visa online can use the expanded evidence options for eligible 10.4 disputes where their acquirer supports cross-merchant data retrieval and submission.
The practical qualification is the same in Australia as elsewhere: the evidence needs to meet CE3.0 requirements, and any cross-merchant transaction must be within the same acquirer’s processing footprint for submission at pre-arbitration. Merchants should confirm capability with their acquirer rather than assume that the Visa rule update has automatically changed their dispute workflow.
What should merchants do first?
Start with the acquirer, then check whether your own data is ready. Ask your acquirer or processor whether it can identify qualifying undisputed transactions from other merchants in its portfolio, retrieve the required evidence and submit it for 10.4 pre-arbitration. Ask for a practical explanation of how the process works, not only confirmation that the rule is live.
Then review your own transaction records. Confirm that your systems retain the information needed to identify relevant transactions and support evidence submissions. Recurring businesses should pay particular attention to preserving the initial CIT IP address and connecting it to subsequent MIT renewals where appropriate.
Finally, make sure your dispute team can distinguish 10.4 card-absent fraud from 13.2 cancelled-recurring disputes. The new option only helps in the right dispute category.
Frequently asked questions
What is Visa Compelling Evidence 3.0?
CE3.0 is a Visa evidence framework for qualifying card-absent fraud disputes. When the applicable criteria are met, merchants can use qualifying undisputed transaction history to support a response to a 10.4 dispute.
Can I use transactions from other merchants in a Visa dispute now?
Yes, for qualifying 10.4 disputes, two undisputed transactions from 120 to 365 days before the dispute can come from one or more merchants. At pre-arbitration, however, the acquirer can submit only transaction data it accepted and processed itself. Cross-merchant evidence therefore depends on the acquirer’s portfolio and technical capability.
Does CE3.0 apply to cancelled subscription disputes?
No. CE3.0 applies to reason code 10.4 card-absent fraud disputes. It does not apply to reason code 13.2 cancelled recurring transaction disputes.
What should merchants do first?
Ask your acquirer or processor whether it can retrieve and submit cross-merchant CE3.0 evidence from its own portfolio. Then check your data retention and evidence processes, particularly for tokenised transactions and recurring payments.
Does this change apply in Australia?
Yes. The change is a global Visa rule update. Australian merchants can use the expanded options for eligible Visa 10.4 disputes where their acquirer supports the required data retrieval and submission.
Key Takeaway
Visa has widened CE3.0 evidence beyond a merchant’s own transaction history, but the practical reach is bounded by the acquirer. For merchants, the immediate priority is to verify that their provider can retrieve and submit eligible cross-merchant data, then make sure their own records are ready to support a 10.4 response.