Compelling Evidence 3.0 (CE3.0)

Visa Compelling Evidence 3.0 is a dispute-response framework that allows merchants to refute chargebacks filed under Visa reason code 10.4 (Other Fraud — Card-Absent Environment) by demonstrating a history of prior, legitimate undisputed transactions with the same cardholder. Launched April 15, 2023, CE3.0 replaced the previous single-transaction evidence standard and, for the first time, enabled pre-dispute deflection as well as post-dispute representment using the same evidence criteria. (Chargebacks911, updated 2026-08-04; Verifi, 2022-08-10)

Background and motivation

Between 2019 and 2021, annual Visa CNP sales grew 51% while chargebacks grew nearly 30% globally. (Verifi citing Visa Internal Reporting, 2022) In 2025, Visa processed 106 million disputes globally — a 35% increase since 2019 — and Americans filed 158 million card-transaction disputes, up 29% since 2021. (Visa press release, 2026-04-01; Bloomberg/Boing Boing, 2026-07-16) Friendly fraud, where cardholders dispute legitimate charges, is estimated to drive 30–80% of all chargebacks (Sift, 2023-04-13) and ~75% of ecommerce disputes specifically. (chargeback.io, 2026)

Under legacy rules (CE2.0), merchants could only challenge a 10.4 dispute using a single prior transaction and had to match all four data elements: IP address, email address, physical address, and telephone number. This set a high bar that was often impossible to clear for digital-goods merchants or those without robust data infrastructure. CE3.0 was designed to lower the evidence threshold while increasing the specificity of what constitutes fraud. (Chargebacks911, 2026-08-04)

Scope

CE3.0 applies exclusively to disputes filed under Visa reason code 10.4 — Other Fraud: Card-Absent Environment. It does not apply to other Visa reason codes, Mastercard, Amex, or Discover chargebacks. (Chargebacks911, 2026-08-04; Verifi, 2022-08-10)

Qualification criteria

To submit CE3.0 evidence, a merchant must provide two prior transactions on the same payment method (identical PAN) that:

Settled at least 120 days prior to the dispute date, but no more than 364 days before it (i.e., within the 120–364 day window). (Stripe Docs, 2026; Chargebacks911, 2026-08-04)
Were not previously disputed or reported as fraud (TC40). (Verifi, 2022-08-10)
Were not validation charges. (Stripe Docs, 2026)
Must share at least two matching data elements with the disputed transaction, of which at least one must be either IP address or device ID/fingerprint:

Main evidence elements	Secondary evidence elements
Customer purchase IP address	Shipping address
Customer device fingerprint or device ID	Customer email address
	Customer account / login ID

Note: Customer Device Fingerprint and Customer Device ID together do not count as a valid two-element combination — only one device-based element may be used; the second must come from the secondary column. (Stripe Docs, 2026)

Subscription exception: For subscription merchants, the initial billing transaction may substitute where recurring transactions do not capture a per-session IP or device ID. (Chargebacks911, 2026-08-04)

New-customer limitation: CE3.0 is structurally unavailable for first-time purchasers — no prior undisputed transaction in the 120–364-day window can exist. (Chargebacks911, 2026-08-04; Sift, 2023-04-13)

Comparison: CE2.0 vs CE3.0

Criterion	CE2.0 (legacy)	CE3.0 (from Apr 2023)
Prior undisputed transactions required	1	2 or more
Matching elements required	All 4: IP, email, physical address, phone	Any 2; one must be IP or device ID
Timeframe for prior transactions	None specified	120–364 days before dispute
Submission stage	Dispute response only	Pre-dispute (via Order Insight) or dispute response

(Chargebacks911, 2026-08-04)

Two submission pathways

Pre-dispute (via Order Insight / Verifi)

When a cardholder contacts their bank to dispute a transaction, Visa pre-selects 2–5 prior transactions on the same account with no active fraud reports or disputes. These are surfaced to the enrolled merchant as Order Insight inquiries. The merchant returns CE3.0 data elements for two or more qualifying transactions. Verifi's Order Insight validates the data and passes the decision to Visa. If criteria are met, the pre-dispute is blocked before a formal chargeback is filed. (Verifi, 2022-08-10)

Benefits of pre-dispute deflection:

No chargeback fee
No impact to chargeback ratio
No impact to fraud ratio
Liability stays with the issuer
No TC40 count toward Visa Acquirer Monitoring Program (VAMP) thresholds (as-of 2025)

An April 2026 update to Order Insight expanded CE3.0 integration, allowing merchants to share packing-level evidence and prior transaction history directly with issuing banks during dispute review. (Visa press release, 2026-04-01)

Post-dispute (representment via VROL)

If a chargeback has already been filed, merchants work with their acquirer to compile CE3.0 evidence for two historical transactions (120–364 days prior). The acquirer submits via Visa Resolve Online (VROL); Visa validates the CE3.0 data elements. If criteria are met, the chargeback is reversed.

Post-dispute differences:

Chargeback fee still applies
Chargeback ratio is impacted
Fraud ratio is NOT impacted (as-of 2025)
Dispute cannot escalate to arbitration if CE3.0 succeeds

(Chargebacks911, 2026-08-04; Verifi, 2022-08-10)

VAMP connection

TC40 fraud disputes successfully resolved via CE3.0 are excluded from Visa Acquirer Monitoring Program (VAMP) calculations (as-of 2025). This makes CE3.0 strategically important not just for individual chargeback wins but for maintaining VAMP compliance ratios. (Search result summary citing multiple sources, 2026)

Adoption and effectiveness

The Datos Insights survey below is from Q4 2024 (840 respondents); the Visa "90%" figure is from a later, separate study. Methods differ.

In a Q4 2024 Datos Insights survey of 840 global merchants:

20% were already using CE3.0 (as-of Q4 2024)
31% planned to use it (as-of Q4 2024)
93% of the 165 merchants actively using CE3.0 rated it "effective" or "very effective" at avoiding chargeback liability (as-of Q4 2024)

A separate figure cited by chargeback.io in 2026 states "Visa says 90% of surveyed merchants now use CE3.0 as part of their chargeback management plan." The source methodology differs from Datos Insights.

CE3.0 adoption rate: Datos Insights Q4 2024 survey (n=840) → 20% of merchants currently using CE3.0. Chargeback.io 2026 citing Visa → "90% of surveyed merchants now use CE3.0." These figures likely reflect different survey populations, time periods, and definitions of "use." Neither can be directly compared.

Reported win rates:

Standard evidence representment win rate: 15–20% (chargeback.io, 2026)
CE3.0 evidence win rate: 40–60%, depending on merchant category and quality of device intelligence (chargeback.io, 2026)

Merchants win an average of 43.8% of chargebacks they represent overall, but the net recovery rate after second-cycle disputes and undetected friendly fraud falls to ~10.7%. (chargeback.io, 2026)

PSP implementation

Stripe: Full API support via the enhanced_evidence object's visa_compelling_evidence_3 sub-object. Stripe autofills eligible disputes from prior transactions it has processed. Status field returns qualified, requires_action, or not_qualified. Limitation: all prior undisputed transactions must have been processed by Stripe. Test card available: 4000000404000038. (Stripe Docs, 2026)

Verifi (Visa subsidiary): Manages the pre-dispute Order Insight pipeline for CE3.0. The Systematic Dispute Deflection feature automatically deflects confirmed first-party-misuse disputes at the pre-dispute stage. (Verifi, 2022-08-10)

Sift: CE3.0 data elements (transaction history, IP addresses, device IDs, shipping addresses) accessible in the Sift Console. Sift's ML models can prioritise the highest-value disputes to fight. (Sift, 2023-04-13)

Merchant challenges

As of April 2023, only 31% of merchants used device-based signals as part of their fraud-detection tools, per the MRC 2023 Global Payments and Fraud Report — meaning the majority could not immediately satisfy the device ID / device fingerprint requirement. (MRC 2023 cited in Sift, 2023-04-13)

MRC figure above is from the 2023 Global Payments and Fraud Report. Device-tool adoption may have changed since.

Other reported challenges:

Higher operational workload to compile evidence within tight representment windows
New-customer exclusion: CE3.0 is ineffective for first-time buyers
Merchants without IP/device collection infrastructure cannot participate
One-off purchase merchants benefit less than subscription merchants (matching prior transactions harder to find)
Stripe limitation: prior transactions must all be on Stripe (no cross-processor lookup)

(Sift, 2023-04-13; Chargebacks911, 2026-08-04; Stripe Docs, 2026)

2025–2026 expansions

October 17, 2025: Visa implemented automatic CE3.0 qualification through Visa Secure and Visa Data Only across Asia Pacific, CEMEA, Europe, and Latin America/Caribbean. (search result citing Chargebacks911 / Visa Business News, as-of 2025-10-17)

April 1, 2026: Visa announced six new dispute resolution tools, including an Order Insight update enabling merchants to use CE3.0 within Order Insight to share packing-level evidence and prior transaction history directly with issuing banks during dispute review — before a chargeback is decided. (Visa press release, 2026-04-01)

April 18, 2026: CE3.0 expanded to cover non-disputed fraud (TC40 without TC15), giving merchants a pathway to challenge fraud reports that haven't yet become chargebacks. (Chargebacks911, 2026-08-04, citing Visa Business News)

Other tools announced April 2026 alongside the Order Insight/CE3.0 update:

Visa Dispute Recovery Manager — GenAI-automated representment with win prediction scoring (pilot expansion late 2026)
Dispute Intelligence — AI for issuers, generally available
Dispute Doc Analyzer — AI summary of merchant documents for issuer analysts; auto-populate response questionnaires for acquirers
Visa Dispute Case Manager — unified cross-network dispute platform (GA North America 2026)
Visa Dispute Resolution Network — streamlined pre-dispute handling (pilot now)

(Visa press release, 2026-04-01)

Consumer and practitioner perspectives

Juniper Research analyst Michael Greenwood, quoted via Bloomberg Businessweek (2026), notes that outright theft is only a small slice of the chargeback surge; the bigger drivers are merchant-name confusion, forgotten subscriptions, deteriorating return policies, junk fees, and poor customer service. (Bloomberg/Boing Boing, 2026-07-16)

Reddit users on r/MiddleClassFinance (Jul 2026) frame chargebacks as a consumer protection tool rather than fraud:

"Using the protections afforded you by your payment method of choice is 'friendly fraud'? Fuck that." — u/whatigotinmyhandnowb "Fraud is when sellers use AI in the product photos to bait and switch." — u/Euphus

This framing — that chargebacks are legitimate consumer protection, not first-party fraud — represents a key tension in how CE3.0 is perceived by merchants vs. consumers. (Boing Boing citing r/MiddleClassFinance, 2026-07-16)

Key terms

Term	Meaning
CE3.0	Compelling Evidence 3.0 — Visa's April 2023 dispute evidence framework
Reason code 10.4	Visa's "Other Fraud — Card-Absent Environment" — the only code CE3.0 applies to
TC40	Visa's fraud report code; CE3.0 resolutions exclude these from VAMP counts
Order Insight	Verifi/Visa tool for pre-dispute deflection; the preferred CE3.0 channel
VROL	Visa Resolve Online — the post-dispute submission portal
PAN	Primary Account Number — the card number; prior transactions must share the same PAN
Device fingerprint / device ID	Device-based identifier; one of the two main CE3.0 evidence elements
Pre-dispute deflection	Blocking a dispute before it becomes a chargeback, via Order Insight

What practitioners report

Subscription merchants benefit most: recurring billing creates ready-made prior-transaction history. (Sift, 2023-04-13; Chargebacks911, 2026-08-04)
Merchants without automated fraud platforms must compile CE3.0 evidence manually, which is time-consuming within the tight representment window. (Sift, 2023-04-13)
Stripe autofill helps but limits merchants to Stripe-processed prior transactions only. (Stripe Docs, 2026)
The April 2026 Dispute Doc Analyzer (for acquirers) enables auto-population of response questionnaires, reducing CE3.0 submission friction. (Visa press release, 2026-04-01)