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New Visa CEDP Level 3 requirements: What B2B merchants must do

Visa Level 3 Data Mandatory October 2025: Complete CEDP Compliance Guide Visa Level 3 Data Mandatory October 2025: Complete CEDP Compliance Guide Visa Level 3 Data Mandatory October 2025: Complete CEDP Compliance Guide
TL;DR: Starting October 2025, Visa’s new Level 3 interchange rates are live and Level 2 is being phased out (gone by April 2026). AI-powered systems now verify every transaction’s data quality. For B2B merchants processing $500K monthly, non-compliance could cost $60,000+ annually. This guide covers what changed, why it matters, and exactly what to do about it.

If you process B2B credit card transactions, October 2025 isn’t just another month on the calendar—it’s the moment your payment processing costs could silently skyrocket.

Visa’s Commercial Enhanced Data Program (CEDP) has officially entered its next phase, and the stakes have never been higher. Starting this month, new Level 3 interchange rates are in effect, and the traditional safety net of Level 2 processing is disappearing. For many B2B merchants, this could mean the difference between optimized payment costs and bleeding thousands of dollars monthly in unnecessary fees.

Here’s everything you need to know—and what you need to do about it.

What just happened in October 2025?

As of October 2025, Visa implemented two critical changes that fundamentally reshape B2B payment processing:

1. New Level 3 interchange rates are live

The discounted interchange rates that B2B merchants have relied on for years have been restructured. These new rates reward merchants who submit complete, accurate enhanced data—and penalize those who don’t.

2. Level 2 is on its way out

While Level 2 interchange rates won’t be fully discontinued until April 2026, Visa is systematically eliminating Level 2 as an interchange tier, pushing all B2B transactions toward the more rigorous Level 3 requirements.

The message from Visa is crystal clear: adapt to Level 3 data requirements now, or pay the price.

Understanding CEDP: The new rules of B2B payments

Visa’s Commercial Enhanced Data Program (CEDP) isn’t a minor policy tweak—it’s a fundamental reimagining of how B2B transactions are processed and priced.

The traditional system

For years, B2B merchants could qualify for reduced interchange rates by submitting varying levels of transaction information:

  • Level 1: Basic card information (highest rates)
  • Level 2: Additional data like tax amount, customer code, merchant tax ID (mid-tier rates)
  • Level 3: Detailed line-item data including product descriptions, quantities, unit costs, freight charges (lowest rates)

The system was forgiving. Submit some enhanced data, get some savings. Miss a few fields? You’d downgrade a level but still maintain reasonable rates.

The new reality: CEDP-powered processing

In the age of AI, Visa has introduced highly sophisticated verification and data-quality standards that rival the precision of a Swiss watchmaker.

Under CEDP, AI-powered systems now scrutinize every detail of enhanced data—no random selection, no manual spot checking, just algorithmic precision on every transaction, every time.

The system verifies:

  • Invoice numbers and dates
  • Item descriptions and product codes
  • Quantities and unit costs
  • Tax amounts and rates
  • Freight and shipping charges
  • Discount information
  • Customer reference numbers
Here’s the critical difference: In the past, simply populating Level 3 data fields was often enough to secure better rates. Today, if your data doesn’t meet Visa’s quality and formatting standards, the transaction is flagged as non-compliant and automatically downgraded.
  • Generic placeholders like “Misc Item” or “Service”? Downgraded.
  • Incomplete tax information? Downgraded.
  • Formatting errors in line items? Downgraded.

The financial impact: real numbers

This isn’t theoretical. Let’s look at a B2B merchant processing $500,000 monthly in corporate card transactions:

Scenario 1: Compliant Level 3 data

Interchange rate: ~1.95% + $0.10 per transaction

Monthly interchange cost: ~$9,800

Scenario 2: Non-compliant data (downgraded to standard commercial rate)

Interchange rate: ~2.95% + $0.10 per transaction

Monthly interchange cost: ~$14,800

Monthly difference: $5,000

Annual difference: $60,000

For a business processing $500,000 monthly, non-compliance with Level 3 requirements could cost $60,000 annually in unnecessary interchange fees. And that’s a conservative estimate—actual rates vary by card type and merchant category.

The Hidden Multiplier Effect

Beyond direct interchange costs:

  • Processor markup fees often scale with interchange, compounding your costs
  • Cash flow impact reduces profit margins on every transaction
  • Competitive disadvantage if competitors are compliant and you’re not
  • Time and resources spent investigating downgrades and fixing data issues

1 What Level 3 data actually requires

Level 3 data is comprehensive—and that’s by design.

Required fields:

Order-level information:

  • Purchase order number
  • Merchant tax ID
  • Customer reference or code
  • Tax amount and rate
  • Freight/shipping amount
  • Duty amount (if applicable)
  • Destination zip code
  • Invoice date

Line-item information (for each product/service):

  • Item description (meaningful, not generic)
  • Product code or SKU
  • Quantity
  • Unit of measure
  • Unit cost
  • Extended line amount
  • Discount amount (if applicable)
  • Tax rate and amount

What “quality data” actually means:

Submitting the fields isn’t enough. The data must be:

Accurate

Numbers must match your actual invoice. Tax calculations must be correct. Line items must add up properly.

Specific

“Office Supplies” won’t cut it. Visa wants “HP LaserJet Toner Cartridge – Black, Model CF287A.” Use manufacturer SKUs or specific part numbers, not generic placeholders.

Complete

Every field should contain real data. Don’t use default values like “0” or “N/A” unless genuinely applicable.

Properly formatted

Follow Visa’s requirements for dates, amounts, and text fields. Inconsistent formatting triggers AI flags.

Common mistakes that trigger downgrades:

  • Generic item descriptions: “Services rendered,” “Products,” “Miscellaneous items”
  • Missing or incorrect tax information
  • Placeholder product codes: Using “00000” or “N/A” instead of real SKUs
  • Incorrect line-item math: Extended amounts that don’t match quantity × unit cost
  • Missing customer reference data
  • Inconsistent formatting: Mixing date formats, incorrect decimal places
  • Copy-paste errors: Same description for multiple different items
Visa’s AI checks all of this automatically, and it’s far less forgiving than any human reviewer.

2 The timeline: What’s coming next

What’s already happened:

  • October 2024: CEDP launched with light enforcement and data quality monitoring
  • April 2025: Visa began actively verifying merchant data accuracy using AI-driven systems
  • October 2025: New Level 3 interchange rates took effect—financial impact of non-compliance significantly increased

What’s coming soon:

April 2026:

Visa will completely discontinue Level 2 interchange rates, expand qualifying BINs, and enforce Level 3 requirements across a broader range of commercial cards.

After April 2026

There won’t be a “middle tier.” You’ll either qualify for Level 3 rates or pay standard commercial rates—and the gap between those two will be substantial.

The window is closing

While April 2026 might seem far away, you need compliant systems and processes now. It takes time to upgrade payment systems, train staff, and test data submissions. Every day you delay means paying higher rates.

3 Action plan: What to do right now

1. Audit your current setup

Talk to your payment processor, gateway provider, IT, and accounting teams. Determine what level of data you’re actually submitting and how many B2B transactions qualify for Level 3 rates. Request a downgrade report from your payment provider showing where and why transactions are being downgraded.

Most merchants discover that fields they assumed were being sent actually aren’t—and fixing this alone can save thousands.

2. Evaluate your tech stack

Your ability to submit compliant Level 3 data depends on your systems. Key questions:

  • Is your payment processor CEDP-capable and updated?
  • Does your ERP sync properly with your payment system?
  • Are you manually keying data or using outdated software?

If yes to the last question, it’s time to upgrade or add integration tools. Automate and validate as much as possible—manual processes are error-prone and don’t scale.

3. Clean up your data at the source

Even perfect systems can’t fix bad input. Review:

  • Product catalogs: Accurate descriptions, codes, and prices
  • Customer information: Complete billing and shipping details
  • Invoices: Full line-item detail with proper tax calculations

Clean data at the source means better qualification rates and lower fees.

4. Get your team aligned and monitor continuously

Train your sales and finance teams on what quality data looks like and why it matters. Run test transactions, review reports monthly, and flag downgrades immediately.

CEDP compliance isn’t a one-time project—it’s an ongoing process. Work with payment providers and tech partners who understand Level 3 optimization and can help you stay compliant as requirements evolve.

Why Visa is making these changes

Before dismissing this as a revenue grab, understand Visa’s rationale:

Corporate card transparency

Finance teams need detailed data for automated reconciliation, audit compliance, fraud detection, and spending analysis—not hours matching receipts to statements.

Reducing risk and disputes

Complete transaction data significantly reduces chargebacks. When cardholders and their companies can see exactly what was purchased down to individual line items, there’s less confusion and fewer contested charges.

Industry standardization

For years, merchants submitted wildly inconsistent data quality. CEDP enforces standards that benefit the entire payment ecosystem.

Understanding Visa’s motivations doesn’t pay your bills, but it does explain why these requirements are here to stay.

The bottom line

Visa’s CEDP program and the October 2025 interchange changes aren’t going away. The era of “close enough” enhanced data submission is over.

For B2B merchants, the choice is clear: invest the time and resources to comply with Level 3 requirements, or pay thousands—potentially tens of thousands—more annually in unnecessary processing fees.

The good news? This is entirely within your control. With the right payment systems, processes, and attention to data quality, you can qualify for the best possible interchange rates and turn CEDP compliance into a competitive advantage.

Don’t let compliance cost you thousands in processing fees

Get your free Level 3 audit today

Disclaimer: The information in this article is current as of October 2025 and based on Visa’s announced CEDP requirements and publicly available interchange documentation. Payment processing rules and rates may change. Always consult with your payment processor and financial advisors for guidance specific to your business. For the most current information, visit Visa’s official commercial payment resources at visa.com.

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