Visa's Compelling Evidence Update: What It Means for VAMP Compliance and 3DS

If you've been following the conversation around friendly fraud and VAMP compliance, you know the tools available to merchants have been limited at best. But Visa just made a move that deserves real attention.

They've rolled out a significant update to their Compelling Evidence rules, and it carries major implications for how merchants and acquirers can fight back against illegitimate chargebacks while keeping their VAMP ratios under control.

What Changed with Compelling Evidence

The big shift: Visa is expanding eligibility for matching data elements beyond just the same merchant. Previously, to build a Compelling Evidence case, you needed prior transactions from the same cardholder on your own platform. The matching data elements (IP address, device ID/fingerprint, delivery address, and customer/account login) had to come from your own transaction history.

Now, transactions across different merchants, including agentic payment providers, can qualify for Compelling Evidence. The requirement is that related credentials were used and those core data elements match.

The Important Limitation

This is still restricted to the same acquirer. The expanded matching only works with data from transactions that the acquirer accepted and processed. So it's not a free-for-all across the entire Visa network. But even with that constraint, this dramatically opens up a much larger pool of transactions for merchants to draw from when building their cases.

Why This Matters for VAMP

The original Compelling Evidence 3.0 only helped a small subset of merchants: those with high repeat purchase volumes on their own platform. If you didn't have enough historical transactions with matching data from the same customer, you were out of luck.

This update changes the math entirely. Expanded Compelling Evidence is now the only legitimate tool currently available to meaningfully push back at the TC40 level and keep VAMP ratios in check. For merchants who have been struggling to stay within Visa's thresholds, this is a real lifeline.

3DS Is Now a Must-Have

Here's where this gets practical. 3D Secure is the only way to capture and use matching data across merchants, and it's fully automated. When a cardholder authenticates through 3DS, the device fingerprint, IP address, and other identifying data gets captured and stored in a way that can be referenced across transactions and across merchants within the same acquirer.

The more merchants that adopt 3DS, the bigger the shared pool of transaction data becomes. That means stronger defenses against friendly fraud for everyone in the ecosystem. It's a network effect: each new merchant using 3DS adds to the collective evidence base that all merchants can draw from.

What Merchants and Acquirers Should Do Now

• Implement 3DS if you haven't already. This is no longer optional if you're serious about VAMP compliance and chargeback defense.
• Talk to your acquirer. Understand how they're implementing the expanded Compelling Evidence rules and what data they can provide from cross-merchant transactions.
• Review your dispute response workflows. With a larger pool of qualifying transactions available, your win rates on friendly fraud disputes should improve, but only if your processes are set up to take advantage of the new rules.
• Track your TC40 and VAMP ratios closely. This update gives you new ammunition, but you still need to stay on top of the numbers.

The Bottom Line

Credit where it's due: Visa is evolving the rules to better address friendly fraud in a more connected payments world. This update to Compelling Evidence is a meaningful step forward that should genuinely help legitimate businesses fight back more effectively.

But the merchants and acquirers who benefit most will be the ones who are already collecting the right data through 3DS authentication. If you're not there yet, now is the time to get started.