2024 Visa Compelling Evidence Hot Topics

In January 2024, Visa released an article differentiating requirements for compelling evidence Item 10 and the Compelling Evidence remedy rule for dispute condition 10.4 – Other Fraud – Card-Absent Environment (commonly referred to as Compelling Evidence 3.0, or CE3.0). Visa Business News articles are distributed to issuers, acquirers, and processors. Verifi is making this same important information available to our merchants and partners. 

Highlighted in the VBN article are some common merchant-reported FAQ questions:

Compelling Evidence FAQs

To continue to help clients utilize Compelling Evidence, Visa has compiled the following FAQs that consist of the most common questions Visa receives:

Q: What are the data elements that should be supplied for cardholder-initiated transactions (CITs)?

A: Merchants should be sourcing the data elements of IP address, device ID / fingerprint, account log-in ID and shipping address from the consumer’s data during the transaction. These should be the data elements of the consumer and not the merchant. The data elements for CITs should not be sourced from the account setup or the creation of the card-on-file information unless it is occurring during the financial transaction.

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Q: Does Compelling Evidence 3.0 (CE3.0) work for recurring merchant-initiated transactions (MITs)?

A: Yes, CE3.0 is available for recurring transactions. For subscription merchants processing recurring MITs, the cardholder’s IP address from the initial CIT can be populated for the subsequent MIT being used as evidence of a historic, non-disputed transaction.

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Q: Can the log-in / account ID be the customer’s phone or email?

A: Yes, if that is the credential the customer used to authenticate to the merchant’s e-commerce site for the transaction. If the cardholder established a credential that is not their phone or email, such as a user ID, then that credential should be provided to Visa.

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Q: If the cardholder used guest checkout for the transaction, can the cardholder’s authenticated email or phone number be provided as the log-in / account ID?

A: No, a guest checkout allows the cardholder to purchase without logging into or creating an account. As an account is nonexistent, an email or phone number cannot be used to represent this data.

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Q: Can the shipping address be a store location? What about a PO box address or office address?

A: No, for an online purchase that was picked up in-store, there is no shipping address since it has been picked up at the merchant location. For delivery to PO boxes or offices, those addresses are valid if that is the consumer’s location, not the merchant’s.

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Q: What elements of the shipping address are required?

A: Full shipping address of the cardholder is required: street address, city, state/province (if applicable), postal code and country. If the postal code is not applicable for the region, enter xxxxxxxxx in the postal code field.

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Q: What are the requirements for device IDs?

A: A device ID must be a unique identifier for the device that is accessible by the cardholder.

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Q: Can you provide suggestions on how to generate a device fingerprint?

A: Multiple attributes can make up the device fingerprint, including device model, CPU, memory, sensors, unique device IDs, etc.

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Q: What values are required for the merchandise / service description?

A: The description must include details that are above and beyond the merchant’s name or merchant category code (MCC) and must clearly explain what was purchased, as shown in the following examples:

• Renewed subscription ID: 123456789
• Instant access to Diet 30 Day Plan
• Hotel stay downtown in Asheville, NC, U.S. checking in on 2023-07-23
• Online dating subscription
• Premium video game package for 90 days
• Transfer to wallet 123456789
  
  

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Q: Is it valid if the transaction or transactions being used for the historical footprint were eventually credited back to the cardholder (i.e., merchandise return)?

A: Yes, because the intent of compelling evidence is to show the cardholder had an existing relationship and participated in previous undisputed transactions using the same key identifying fields. The goods / services being returned and credited have no bearing on the validity of these identifying fields.

Additional Verifi-created FAQ document can be found, here:

Differentiating Compelling Evidence Item 10 from Compelling Evidence Remedy Rule 

For pre-arbitration attempts processed on or after 15 April 2023, compelling evidence requirements were modified for 10.4 Other Fraud Card-Absent Environment disputes that do not match criteria to qualify for the CE3.0 remedy rule. 

CE3.0 remedy rule: Compelling Evidence dispute rule changes rolled out by Visa in 2023, to address friendly fraud, effectively shifting dispute liability away from card-not-present merchants when specific criteria are met during a pre-arbitration response. 

	Required data elements	Transaction requirements
Compelling Evidence Item 10   (for disputes not utilizing remedy rule – Compelling Evidence 3.0)	Three or more of the following had been used in an undisputed transaction:  Customer account/login ID  Delivery address  Device ID/device fingerprint  Email address  IP address  Telephone number	One transaction any time period
Compelling Evidence Remedy Rule (Compelling Evidence 3.0) *	At least two of the following are the same in the disputed/undisputed historical transactions:  Customer account/login ID  Delivery address  Device ID/device fingerprint  IP address  One of two must be Device ID or IP address.	Two non-fraud reported transactions between 120-365 days prior to the dispute processing date

*Evidence that qualifies for the Compelling Evidence remedy rule is the same for either the pre-dispute or post-dispute stage. 

Using CE3.0 – for Merchants 

Merchants have the option to leverage CE3.0 dispute liability protections in both pre-dispute and post-dispute environments. 

	Pre-Dispute	Post-Dispute
Who handles this option?	• Verifi (through Order Insight)	• VROL (Pre-Arbitration)
What do merchants need to do?	• Merchant responds to Order Insight request for disputed transaction.    • Merchant responds to Order Insight request for Visa pre-selected historical transactions.	• Merchant will work with acquirer to complete pre-arbitration questionnaire with CE3.0 data elements.    • Merchant will select the historical transactions applicable.
Benefits?	• Liability shift    • Dispute deflection – Prevents 10.4 dispute from being submitted.    • Fraud to be flagged/reversed; will not count against fraud ratio.	• Liability shift    • As dispute was submitted, dispute will count against dispute ratio.    • Fraud to be flagged/reversed; will not count against fraud ratio.