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What CE 3.0 Actually Unlocks in a VAMP Environment

PAAY Team·March 17, 2026
What CE 3.0 Actually Unlocks in a VAMP Environment

What CE 3.0 Actually Unlocks in a VAMP Environment

Everyone’s talking about VAMP.

But very few people seem to fully understand what CE 3.0 actually unlocked—and why it matters.

That gap is important, because it changes how merchants can deal with one of the hardest parts of fraud today: TC40 impact.

The real issue with TC40s

With VAMP, fraud evaluation is shifting.

It’s not just about confirmed fraud or chargebacks anymore. TC40 data is playing a bigger role in how performance is measured.

The problem is, merchants haven’t really had a way to influence that.

TC40s show up in your metrics. They affect how you’re evaluated. But historically, you couldn’t do much about them.

That’s been the frustration across the industry.

Where CE 3.0 comes in

CE 3.0 (Compelling Evidence 3.0) was introduced to help merchants respond to fraud claims more effectively.

At a basic level, it improves how transaction data is used to:

  • Match activity
  • Support disputes
  • Push back on fraudulent claims

But the real shift isn’t just what CE 3.0 does.

It’s how broadly it can now be applied.

The part most people got wrong

A lot of the industry assumed that multi-merchant CE 3.0 would be limited to each acquirer.

That’s only true in part.

  • Post-dispute CE 3.0 is still constrained by acquirer
  • Pre-dispute CE 3.0 (through EMV 3DS) is not

That distinction changes everything.

Because it means CE 3.0 is no longer limited to a narrow slice of data.

It can work across merchants and data sources—without the same restrictions.

What actually changed

With pre-dispute CE 3.0 enabled through EMV 3DS:

  • There’s no acquirer limitation
  • Data can be used across multiple merchants
  • Matching becomes much more scalable
  • Coverage expands significantly

So instead of being a reactive tool used after the fact, CE 3.0 starts to look more like a proactive, ecosystem-level capability.

Why EMV 3DS is central to this

This is where EMV 3DS becomes much more important.

Not just for authentication—but for data.

When you run EMV 3DS (especially in a data-only or frictionless setup), you’re capturing structured information at checkout:

  • Cardholder authentication signals
  • Transaction details
  • Consistent data points that can be reused later

That data is exactly what CE 3.0 relies on to work effectively.

So the more consistent and widespread that data is, the better the outcomes.

Why this scales (and why that matters)

One of the biggest shifts here is scale.

CE 3.0 becomes more effective as:

  • More merchants adopt EMV 3DS
  • More transactions include the right data
  • Signals become more consistent across the ecosystem

In other words, this isn’t just about individual optimization.

There’s a network effect.

The broader the adoption, the stronger the matching—and the more impact merchants can have on outcomes tied to TC40s.

What merchants should take from this

This doesn’t eliminate fraud.

And it doesn’t remove the need for a strong risk strategy.

But it does change something important:

Merchants now have a more practical way to influence an area that used to feel out of their control.

That shift is subtle—but significant.

It moves the conversation from:

“How do we deal with fraud after it happens?”

To:

“How do we structure our data upfront so we’re in a better position later?”

Final thought

VAMP is pushing the industry toward a more complete view of fraud—one that looks at patterns, signals, and behavior over time.

Within that shift, CE 3.0 is a meaningful step forward.

And EMV 3DS sits right at the center of it.

Not just as a security layer.

But as the data layer that makes everything else work better.


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