Compelling Evidence 3.0 (CE3.0)

CE3.0 is Visa's third-generation framework for merchants to contest Friendly Fraud chargebacks (reason code 10.4 — Other Fraud, Card-Absent Environment) using prior undisputed transaction data. Introduced April 15, 2023, it is the first dispute mechanism that is deterministic: when its criteria are fully met, liability shifts from the merchant to the issuer automatically — unlike probabilistic Representment strategies where matching evidence improves but does not guarantee a win.

How it works

CE3.0 requires a merchant to surface at least two prior undisputed transactions from the same cardholder on the same payment method. Those transactions must:

1. Fall within a 120–365-day window before the disputed transaction date. The 120-day minimum exists because cardholders typically have 120 days to file a fraud dispute — a transaction the issuer has not flagged in that window is held to rest with the issuer. (Chargebacks911, 2025-12-20; Justt.ai, updated 2025-09-15)
2. Share the same merchant descriptor — the first six characters must match across all three transactions. (Checkout.com, 2025-10-30)
3. Have never been previously disputed or flagged as fraud. (Chargebacks911, 2025-12-20)

At least two data elements must match across all three transactions (disputed + both prior), and at least one of the two must be a device-level signal (Checkout.com, 2025-10-30; Stripe docs, current):

Element	Type
Customer IP address	Device (at least one mandatory)
Device ID or fingerprint	Device (at least one mandatory)
Customer account / login ID	Secondary
Shipping / delivery address	Secondary

Stripe formalises this as "main" (IP, device fingerprint/ID) and "secondary" (shipping address, account ID); shipping address + email address alone does not qualify. (Stripe docs, current)

When criteria are met, the outcome is automatic — CE3.0 is described as deterministic rather than probabilistic: if criteria are not fully met, the framework simply does not apply; if met, liability shifts without dispute. (Justt.ai, updated 2025-09-15)

Pre-dispute vs post-dispute submission

CE3.0 can be applied at two stages with materially different ratio outcomes (Chargebacks911, 2025-12-20; as-of 2025-12-20):

Stage	Mechanism	Chargeback ratio	Fraud (VAMP) ratio	Fee
Pre-dispute	Verifi Order Insight — 2-second automated response to issuer inquiry	Not affected	Not affected	No chargeback fee
Post-dispute	Visa Resolve Online (VROL) representment — 30-day window	Counts	Excluded	Fee applies

In the pre-dispute flow, Visa pre-selects up to five qualifying prior transactions and presents them to the merchant via Order Insight; the merchant confirms two matching transactions. Merchants must enrol in Verifi Order Insight to access pre-dispute protection; post-dispute CE3.0 does not require Order Insight. (Chargebacks911, 2025-12-20)

April 2026 expansion: TC40 non-disputed fraud (as-of 2026-04-18)

Effective April 18, 2026, Visa expanded CE3.0 to cover non-disputed fraud — TC40 fraud reports filed by issuers that never escalated to a TC15 chargeback. Before this expansion, merchants had no mechanism to challenge these reports. (Chargebacks911, 2026-04-15)

TC40s without chargebacks arise in three common situations:

• The transaction was 3DS-authenticated (liability already with issuer, so no chargeback incentive)
• Transaction value falls below the cost of processing a chargeback
• Issuer files TC40s as an operational shortcut

Under Visa Acquirer Monitoring Program (VAMP), both TC40 fraud alerts and TC15 chargebacks count against the merchant's dispute-to-transaction ratio: VAMP Ratio = (TC40 + TC15) ÷ Total Settled Transactions (as-of 2026-04-16). TC40s successfully challenged via CE3.0 are excluded from this calculation, directly protecting merchant compliance standing. (Chargebacks911, 2026-04-16)

VAMP context (as-of 2026-07-07)

VAMP replaced VDMP and VFMP on April 1, 2025; enforcement fines began October 1, 2025. From April 1, 2026, the excessive-merchant threshold dropped to 1.5% (down from 2.2%), with fines of $8 per qualifying CNP dispute in any month the threshold is breached. A single fraud dispute generating both a TC40 and TC15 can cost $16 — counted twice in the ratio calculation. (Ravelin, updated 2026-07-07; Forter, 2026-03-25)

CE3.0-qualified TC40 disputes and TC15 non-fraud disputes resolved through pre-dispute solutions (Verifi RDR, CDRN, and third-party equivalents including Ethoca) are the only two categories excluded from VAMP ratio calculations. The exclusion applies only when resolution and dispute fall within the same calendar month. (Ravelin, 2026-07-07)

October 2025 automation (as-of 2025-10-30)

From October 17, 2025, Visa began automatically qualifying transactions for CE3.0 via Visa Secure and Visa Data Only authentication signals across all major regions, reducing manual integration burden for merchants. (Checkout.com, 2025-10-30; Chargebacks911, updated 2026-04-16)

Planned expansion: October 2026 (as-of 2026-03-25)

Per Visa Business News bulletin AI16011 (January 29, 2026), Visa plans two further CE3.0 eligibility expansions in October 2026 (Forter, 2026-03-25):

1. Cross-merchant transactions: qualifying prior transactions will no longer need to come from the same merchant — transactions at different merchants count if related credentials (tokens linked to the same underlying card) match required data elements
2. Related credentials: transactions on all credentials related to the same underlying card (not just the identical token) become eligible

These changes will substantially expand the eligible transaction pool for high-frequency cardholders.

Who benefits — and who does not

CE3.0 is structurally advantageous for merchants with high purchase frequency and consistent data capture (multiple 2025-2026 sources):

High-benefit merchants:

• Subscription and SaaS (recurring billing creates the historical footprint; initial customer-initiated transaction qualifies MIT records) (Chargebacks911, 2025-12-20)
• Digital goods platforms with repeat buyers
• High-frequency retail (apparel, grocery, health)

Limited or no benefit:

• First-time customers — structurally ineligible (120-day minimum means no footprint exists) (Chargebacks911, 2026-04-15)
• Low-frequency / occasional purchase merchants (travel, luxury, large-ticket infrequent)
• Merchants without device ID, IP address, or account identifier capture at checkout (Chargebacks911, 2026-04-15)

A Datos Insights Q4 2024 survey of 840 global merchants found: 20% already using CE3.0; 31% planned to use it; among 165 active users, 93% rated it "effective" or "very effective"; subscription merchants showed the highest adoption intent at 96%. (Chargebackgurus, citing Visa Acceptance Solutions / Datos Insights; as-of Q4 2024)

Nearly 90% of enterprise MRC member merchants now use compelling evidence to challenge invalid disputes (Visa corporate, citing MRC 2025 Global eCommerce Payments & Fraud Report; as-of 2025).

Implementation requirements

• Consistent capture and storage of IP addresses, device IDs/fingerprints, customer account IDs, and shipping addresses at checkout
• Consistent billing descriptor (first six characters identical) across all transactions
• Verifi Order Insight integration for pre-dispute protection
• Historical transaction data retrievable 120–365 days back

Only 31% of merchants used device-based fraud detection tools as of MRC 2023 (Sift, citing MRC 2023; as-of 2023) — a significant data-quality gap limiting CE3.0 uptake.

Friendly fraud context

Visa states first-party misuse can account for up to 75% of a merchant's dispute requests (Visa corporate, citing MRC 2025; as-of 2025). Friendly fraud accounts for approximately 20% of all fraudulent disputes globally and up to 30% for high-volume online merchants (Visa corporate, citing MRC 2025; as-of 2025). CE3.0 is described by Chargebacks911 as the only Visa dispute tool that retroactively reduces the TC40 fraud ratio (Chargebacks911, 2025-12-20).

Visa first introduced the compelling evidence concept in 2013 by enabling sharing of data elements such as IP address, email, and device ID; CE3.0 is the third iteration. (Justt.ai, updated 2025-09-15)

Key terms

Term	Meaning
TC40	Fraud alert filed by an issuing bank; does not require a chargeback to be raised
TC15	A formal chargeback filed by an issuing bank
CE3.0	Compelling Evidence 3.0 — Visa's third-generation prior-transaction evidence framework
VROL	Visa Resolve Online — platform for post-dispute representment
Order Insight	Verifi's pre-dispute response platform; required for pre-dispute CE3.0
MIT	Merchant-Initiated Transaction — recurring or subscription charge
VAMP Ratio	(TC40 + TC15) ÷ Total Settled Transactions; Visa's combined fraud-plus-dispute monitoring metric

Benchmarks (as-of Q4 2024 / 2025)

• 93% of active CE3.0 users rate it "effective" or "very effective" (Datos Insights Q4 2024; n=165 active users)
• 20% of merchants already using CE3.0; 31% planned to (Datos Insights Q4 2024; n=840)
• 96% of subscription merchants using or planning to use CE3.0 (Datos Insights Q4 2024)
• Up to 75% of a merchant's dispute requests may be first-party misuse (Visa / MRC 2025; as-of 2025)
• VAMP threshold: 1.5% excessive-merchant rate from April 2026 (as-of 2026-07-07)
• VAMP fine: $8 per qualifying CNP dispute per month threshold breached (as-of 2026-07-07)

Contradictions