Visa Compelling Evidence 3.0 is expanding: what the October 2026 change means for chargebacks

What’s changing with Visa Compelling Evidence 3.0?

Visa’s Compelling Evidence 3.0 (CE3.0) program, the main tool merchants use to fight card-not-present fraud disputes under reason code 10.4, is reportedly being expanded so merchants can use a cardholder’s transaction history with other participating merchants as evidence, not just transactions with your own business. Payments-industry sources have been citing an October 24, 2026 rollout date for this change. Visa hasn’t published the date in a press release we could independently confirm, so treat it as likely but not locked in, and ask your processor whether it’s live on your account before you plan around it.

How does CE3.0 work right now?

CE3.0 only applies to reason code 10.4 (Other Fraud, Card-Absent Environment) disputes, the ones where a cardholder claims they didn’t make or authorize a card-not-present purchase. To win one, you currently have to show Visa two prior transactions that:

• Were made with the same card or account as the disputed purchase
• Happened between roughly 120 and 365 days before the disputed transaction
• Share at least two matching data points with the disputed transaction, things like the customer’s account or login ID, delivery address, device ID or fingerprint, or IP address
• Weren’t themselves disputed or reported as fraud

If you can show that pattern, you’re arguing the same cardholder clearly used this card for legitimate purchases before, so the disputed one probably wasn’t fraud either. The catch today is that all of that history has to come from transactions with your own business. A cardholder who buys from you once and then disputes it has no prior history with you to point to, even if they’ve shopped elsewhere with the same card dozens of times.

What would the multi-merchant expansion mean?

The reported change lets that prior-transaction evidence come from other participating merchants, not just your own sales history. In practice, a payment network or acquirer-side system would be able to pull in qualifying transactions the same cardholder made elsewhere, as long as they match the same data elements and qualifying window, and submit that as supporting evidence on your dispute. For a merchant whose customers are mostly one-time or infrequent buyers, that’s the difference between having no usable evidence and having a real case.

This would matter most to:

• Online and subscription businesses with a lot of first-time customers
• Marketplaces and platforms where buyer and seller histories are thin
• Any card-not-present merchant currently losing 10.4 disputes simply because they lack a prior-purchase trail to point to

What should you do before October 24?

1. Ask your processor or acquirer directly whether your account has multi-merchant CE3.0 evidence enabled, and whether it’s automatic or something you need to opt into.
2. Keep collecting your own first-party evidence regardless. AVS and CVV matches, delivery confirmations, device and IP logs, and customer communications are still the foundation of a strong case, and multi-merchant evidence supplements that, it doesn’t replace it.
3. Don’t change your dispute response process yet based on a date that hasn’t been confirmed by Visa directly. Build the expansion in once your processor confirms it’s active on your account.
4. If you’re currently losing 10.4 disputes for lack of prior-transaction history, flag that to your processor now so you’re near the front of the line once the expanded evidence source is available.

Why this matters beyond October

This is one more step in a run of CE3.0 changes over the past couple of years, moving from a 2023 rule that required merchants to manually assemble matching data points, toward a system that increasingly automates qualification and widens what counts as valid evidence. For a business fighting even a handful of card-not-present disputes a month, that direction is worth paying attention to, because it changes how much work you have to do to win one.

None of this changes how disputes are won in the meantime: strong documentation, submitted before the deadline, still decides most cases. If your business is seeing a rise in card-not-present disputes and wants help tightening up its evidence process, reach out and we can look at what you’re currently submitting.

This is general information, not legal advice.

Sources: Chargeflow, Visa Compelling Evidence 3.0 Explained Riskified, Updates to Visa Compelling Evidence: What to Know about CE 3.0 Merchant Risk Council, Webinar: Compelling Evidence 3.0