
Visa Compelling Evidence 3.0 (CE 3.0) lets a merchant answer a card-absent "I did not make this purchase" dispute (Visa reason code 10.4) by showing the same card was used in earlier, undisputed purchases that share identifying data, such as IP address or device ID, with the disputed one. If the data matches, liability moves back to the card issuer. If it does not match, or the data was never recorded, the dispute goes ahead as usual.
Industry summaries of Visa's rules report that from 24 October 2026 the two earlier purchases may come from one or more merchants, not only from the store defending the dispute. That lands four weeks before Black Friday. The thing to do this week has nothing to do with legal wording. Check that your store and your payment provider actually record and pass on the data CE 3.0 needs, so that friendly-fraud disputes from the peak season can be defended in December and January.
What CE 3.0 is. Visa introduced CE 3.0 in April 2023. According to Verifi, a Visa company, the merchant needs two prior transactions settled 120 to 365 days before the disputed one. The data must match on "IP Address or Device ID/Fingerprint" plus item information, customer account/login ID or delivery address. When it matches, "dispute liability shifts from the seller to the issuer, and the dispute is deflected." Stripe's help centre describes the same 120-to-365-day window and the same-credential rule. It also notes that submitting CE 3.0 evidence "does not guarantee an auto-win."
What changes on 24 October 2026. Several dispute-management providers (Chargeflow, Fraudbeat and others) report that for 10.4 disputes processed on or after 24 October 2026, the two prior transactions may have taken place at one or more merchants. The same card or a token linked to it must still have been used. We could not check this against Visa's own rules text when reviewing this article, so treat it as reported and confirm the details with your acquirer or payment service provider (PSP). In practice, a first-time customer who has an undisputed history with other merchants might become defensible. That only works if the data travels through the acquirer's systems.
Why the monitoring numbers matter. As of October 2026, Stripe's documentation says the Visa Acquirer Monitoring Program (VAMP) counts both disputes (TC15 reports) and early fraud warnings (TC40 reports) against all captured transactions. Outside the CEMEA region, the "Excessive" threshold is a VAMP ratio of 1.5% with at least 1,500 disputes plus fraud reports in a month. In CEMEA it is 2.2% and 150. The "Non-Compliant" level starts at a 0.5% ratio. Stripe also states that Visa excludes "TC40 fraud eligible for Compelling Evidence 3.0" from the VAMP count, along with disputes resolved through pre-dispute products. Refunds do not remove a dispute from the count, and the outcome of a dispute does not change it either. Mastercard's Excessive Chargeback Merchant level starts at 100 chargebacks and a 1.5% ratio, measured against the previous month's transactions.
The season. Peak trading brings more first-time buyers and more gift orders shipped to addresses other than the billing one. Disputes also arrive weeks after the purchase. Data you fail to capture in November cannot be recovered in January.
| Risk | Owner | Check | Frequency |
|---|---|---|---|
| IP address missing or wrong (proxy IP) | Developer / agency | Test order: stored IP equals the tester's public IP | After every checkout or CDN change |
| Order data not sent to PSP | Developer / agency | Compare a test order in the PSP dashboard with the store admin | Monthly, and after plugin or app updates |
| Retention job deletes evidence | Operations + compliance | Review clean-up schedules against the 13-month need | Quarterly |
| CE 3.0 not enabled or not applied | Finance / payments lead | Written confirmation from PSP | Once, then at contract renewal |
| VAMP or Mastercard ratio rising | Finance / payments lead | Disputes + early fraud warnings / captured transactions | Weekly in peak, monthly otherwise |
| Card-testing spike | Developer + payments lead | Failed payment attempts per hour vs normal | Continuous alerting |
| "Not received" disputes | Fulfilment | Tracking number on every shipped order | Daily in peak |
CE 3.0 READINESS TEST - store: ____________ date: __________ owner: ________
A. PROVIDER
[ ] PSP / acquirer name: ______________________
[ ] CE 3.0 supported on our account (written reply attached)
[ ] Multi-merchant change from 24 Oct 2026 applied? Stages: ________
[ ] Required fields and API names listed: _______________________
[ ] Who submits evidence: PSP auto / app / our team
B. TEST ORDER (real card, small amount, then refund)
[ ] Stored customer IP = tester's public IP
[ ] IP visible on the payment in PSP dashboard
[ ] Device ID / fingerprint present (if collected): yes / no / n.a.
[ ] Customer account ID or email stored and sent
[ ] Delivery address stored and sent
[ ] Item description readable on PSP payment record
C. RETENTION
[ ] Order + IP + device data kept >= 13 months
[ ] Clean-up jobs reviewed: ____________________
[ ] Privacy notice covers this purpose (compliance sign-off)
D. MONITORING (weekly until 31 Jan)
Week | Visa captured txns | Disputes | Early fraud warnings | Ratio | 10.4 share | Notes
| | | | | |
E. SIGN-OFF
Developer: ________ Payments/finance: ________ Date: ________
A homeware store on WooCommerce sits behind a CDN and uses a card plugin connected to its PSP. In early October the payments lead runs the test plan above. The test order shows the CDN's IP address in the order record instead of the tester's. The fix is a server setting that reads the real client IP from the CDN's forwarded header. The developer also finds that a privacy clean-up plugin deletes customer IPs from orders after 180 days. That is shorter than the 365-day lookback.
Both issues are fixed in the first week, before the store's code freeze. The illustrative peak month brings 20,000 Visa transactions. If 120 disputes plus early fraud warnings came in, the ratio would be 0.6%: above the 0.5% "Non-Compliant" level and well below "Excessive". The weekly review shows most of them are 10.4. Repeat customers with matching IPs and delivery addresses can now be defended. Before the fixes, the same disputes could not have been, because the data simply was not there. The numbers are invented for illustration. The point is the order of work: check the data first, then rely on the rule.
Honest limitations. CE 3.0 does not stop disputes. It moves liability for some of them. Guest checkouts, new customers with no history, and shared or changing IP addresses (mobile networks, VPNs) often cannot be matched. The multi-merchant change depends on your acquirer's data and implementation, and acquirers may roll it out differently. None of this is legal advice. Card network rules are published by the networks and applied by your acquirer, so their written answer is the one that counts.
No. CE 3.0 is a Visa rule for reason code 10.4. Mastercard and other networks have their own dispute and monitoring rules. Ask your PSP which evidence options apply to each network.
Published criteria accept IP address or device ID/fingerprint as the core element, plus a second match such as delivery address or account ID. Some processors set narrower field rules, so check yours.
Possibly, in part. Stripe states that TC40 fraud reports eligible for CE 3.0 are excluded from the VAMP count. Ordinary disputes still count whatever their outcome, so prevention still matters most.
Last reviewed: 2026-10-11
For related controls, see fraud controls vs conversion, payment-to-order reconciliation and the ecommerce peak sales readiness checklist. If your store runs on WooCommerce, Pingvera can automate the card-testing row of the table above. It receives order.failed events through its WordPress connector, so a sudden burst of failed orders shows up as an alert on the same timeline as your deploys.
Pingvera watches whether an online business actually works — uptime, checkout, orders, domain, SSL and server — and alerts you in Telegram, email or a webhook before a customer has to tell you.
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