Authorize.net Visa CEDP Compliance: How to Migrate from Level 2 and Level 3 Without Losing Your Interchange Savings
Visa Level 2 and Level 3 processing are going away. Visa's Commercial Enhanced Data Program (CEDP) replaced Level 3 with "Product 3" rates in October 2025 and shut down the Commercial and Small Business Level 2 programs in April 2026. On Authorize.net, Product 3 data can only be sent through the API, not the Virtual Terminal or hosted payment forms, and Authorize.net doesn't check your data for CEDP compliance. TouchSuite has worked with Authorize.net for more than 10 years and can migrate your setup securely so you stay compliant and keep your fees optimized under the new schedule.
Key takeaways
- Level 2 and Level 3 are being replaced. CEDP replaces Visa's Level 2, Level 3, and non-GSA Large Ticket interchange programs for commercial cards. The data tiers are now called Product 2 (P2) and Product 3 (P3).
- The Virtual Terminal isn't enough. Authorize.net's Virtual Terminal, Accept Hosted, Payment Links, and Invoices only send Level 2 fields. Product 3 line items require the API.
- Filled-in fields no longer count. Visa checks enhanced data with machine learning. Placeholder values, like zero tax or generic item names, can lose the discount.
- There's a new fee. Participating transactions carry a 0.05% (5 bps) Visa fee.
- Compliance is on you and your processor. Authorize.net transmits your data but doesn't validate it against CEDP rules or decide how transactions qualify.
What is Visa CEDP?
The Visa Commercial Enhanced Data Program (CEDP) is Visa's replacement for its legacy enhanced-data interchange programs in the U.S. For years, B2B and government merchants got lower interchange on purchasing, corporate, and business cards by sending Level 2 data (tax, PO number, customer reference) or Level 3 data (line-item detail). Visa mostly accepted that data as submitted.
CEDP keeps the same basic data model but changes how it's judged. Level 1 card data is still the baseline for every authorization. What used to be Level 2 is now Product 2, and Level 3 is now Product 3. The big difference is that Visa now validates the data itself. To qualify for Product 3 rates, a transaction has to carry data that reads like a real invoice:
- Complete, with every required field populated
- Accurate, with quantities, unit prices, and tax that reflect the actual sale
- Descriptive, with meaningful item descriptions and product codes instead of filler text
- Consistent, with line items and tax that add up to the transaction total
Compliant transactions can earn an interchange reduction of up to 15 basis points compared with standard commercial rates. Data that fails validation is downgraded to a standard, higher-cost category.
Why Level 2 and Level 3 are going away
Under the old programs, many merchants and integrations sent "dummy" enhanced data, such as one generic line item or a flat tax value, just to unlock lower rates. Corporate buyers got little useful data for reconciliation, and card issuers paid discounts for data that wasn't real.
CEDP closes that gap. With Level 2 retired for most commercial cards, there's no longer a middle tier that pays for partial data. You either send validated Product 3 data or you pay standard commercial interchange. Visa also ties the benefit to ongoing data quality, so merchants and processors that repeatedly send poor data can face program-level review.
The Visa CEDP timeline
| Date | What changed |
|---|---|
| April 12, 2025 | Launch and initial fee. CEDP goes live with a 0.05% (5 bps) Visa fee on participating commercial transactions that carry Level 2 or Level 3 data. Fleet fuel-only Level 2 and GSA Government Large Ticket transactions are excluded. |
| October 17, 2025 | Level 3 replaced, validation required. Legacy Level 3 becomes CEDP Product 3. Visa begins machine-learning validation of transaction data and verification of merchants. Placeholder data no longer qualifies for discounts. |
| January 2026 | Small Business rate adjustments. Visa raised Small Business card interchange on both Level 2 (reported at about 75 bps) and Product 3 (reported at about 65 bps), penalizing merchants sending unverified or weak enhanced data. |
| April 17, 2026 | Level 2 discontinued. Visa ends the Commercial and Small Business Level 2 interchange programs. For non-fleet commercial cards, Level 2 data alone no longer qualifies for a discount. Only validated Product 3 data does. |
What each Authorize.net tool can send
This is where most Authorize.net merchants get caught. How you take payments decides which data tier you can send, and after April 2026 that decides whether you can still earn a Visa commercial discount.
| Authorize.net method | Data it can send | Qualifies for Product 3? |
|---|---|---|
| Virtual Terminal | Level 2 (P2) order-level fields | No |
| Accept Hosted | Level 2 (P2) order-level fields | No |
| Payment Links | Level 2 (P2) order-level fields | No |
| Invoices | Level 2 (P2) order-level fields | No |
API (createTransactionRequest) | Level 2 and Level 3 (P3) line items | Yes, with a supported processor and accurate data |
If your team keys commercial card payments into the Virtual Terminal or sends customers hosted payment links, those transactions can no longer reach Product 3 rates. Moving that volume to an API integration, often through your ERP or invoicing system, is usually the core of the migration.
What Authorize.net Visa CEDP compliance looks like
Authorize.net lists Level 3 and Visa CEDP as a supported mandate. To qualify on Authorize.net, you need:
- An API integration. Product 3 data is sent with
createTransactionRequest, including thelineItemsarray andpurchaseLevelset to3where your processor requires it. - A processor that supports CEDP. Enhanced data support is enabled per processor connection, and Authorize.net currently lists TSYS for Level 3 and CEDP. If your connection doesn't support it, your line items never reach Visa.
- Complete Level 2 fields too. Product 3 includes the order-level fields: tax, shipping, duty, PO number, and billing and ship-to ZIP code and country. Mastercard also commonly expects
shipTo.zipandshipTo.country. - Real source data. Line items should come straight from your invoicing or order system, with real descriptions, quantities, unit prices, SKUs, and tax. Static defaults are exactly what CEDP rejects.
- The right pricing model. Enhanced data only lowers your cost on interchange-plus pricing. On flat-rate or tiered pricing, you may pay the CEDP fee without seeing the savings.
One point Authorize.net is clear about: it does not validate CEDP compliance or decide interchange qualification for you. Visa and your processor make that call, so the accuracy of your data is your responsibility.
Verified vs. non-verified merchants
Since October 2025, Visa has sorted CEDP merchants into two groups based on how consistently their data passes validation:
- Verified merchants receive the reduced interchange immediately, at daily settlement.
- Non-verified merchants can still earn the incentive, but only after Visa validates each transaction's data, so the savings arrive late.
Visa can also reclassify transactions and reclaim discounts up to 45 days after settlement. Logging the payloads you send to Authorize.net makes it much easier to trace a downgrade back to the field that caused it.
How TouchSuite helps you migrate securely
TouchSuite has worked with Authorize.net for more than 10 years, supporting B2B merchants and ERP-integrated payment workflows on platforms such as Odoo, Microsoft Dynamics, Sage, Epicor, Infor, and Oracle. We know where enhanced data usually breaks on Authorize.net and how to fix it without disrupting your payments.
A TouchSuite CEDP migration covers:
- A Level 2/3 audit. We review how your commercial card transactions qualify today and find the ones losing money under the new rules.
- Processor checks. We confirm your Authorize.net processor connection supports CEDP and Product 3 data, and whether
purchaseLevelis required. - Moving volume off the Virtual Terminal. We help route commercial card payments from the Virtual Terminal and hosted forms to an API-based flow that can carry line items.
- Data mapping. We map line-item, tax, freight, duty, and PO data from your ERP or invoicing system so it reaches Authorize.net at authorization in the format Visa expects.
- Secure implementation. Changes use Authorize.net's tokenized, PCI-compliant tools, so raw card data stays out of your systems.
- Fee optimization. We model your card mix against the new CEDP schedule, including the 0.05% fee and the January 2026 Small Business changes, and confirm your pricing model actually passes the savings through.
- Ongoing monitoring. We help you watch for downgrades and fix data errors before Visa claws back your savings.
Not sure where you stand? If your commercial card transactions used to qualify for Level 2 and now settle at higher rates, or you take B2B payments through the Virtual Terminal, your setup likely needs to move to CEDP. Fill out our short form and a TouchSuite Authorize.net specialist will review your current configuration.
Your CEDP migration checklist
- Pull recent statements and see how much commercial card volume is settling at Level 2 or standard commercial rates.
- Confirm processor support for CEDP and Product 3 on your Authorize.net connection.
- Identify Virtual Terminal and hosted-form volume from business cards and plan to move it to the API.
- Send true line items with
createTransactionRequestand setpurchaseLevelto3where required. - Check that line items, tax, and shipping match the transaction total, and include ship-to ZIP and country.
- Log submitted payloads securely so you can troubleshoot downgrades with your processor.
- Confirm you're on interchange-plus pricing and re-price your B2B model against the new schedule, including the participation fee.
Frequently asked questions
Is Visa Level 2 and Level 3 processing going away for Authorize.net merchants?
Yes. CEDP replaces Visa's Level 2, Level 3, and non-GSA Large Ticket programs. Level 3 became CEDP Product 3 on October 17, 2025, and the Commercial and Small Business Level 2 programs ended on April 17, 2026. The data tiers remain as Product 2 and Product 3, but only validated Product 3 data now earns a discount on most commercial cards.
What does Authorize.net Visa CEDP compliance require?
You need to send complete, invoice-quality line items through the Authorize.net API with purchaseLevel set to 3, on a processor connection that supports CEDP, using data from your real invoicing or order system. Authorize.net transmits the data but doesn't validate it for CEDP.
Can I stay CEDP-compliant using the Authorize.net Virtual Terminal?
Not for Product 3. The Virtual Terminal, Accept Hosted, Payment Links, and Invoices only support Level 2 fields. Line-item Level 3 data requires the API, so commercial card volume taken through those tools generally can't qualify for Visa enhanced-data rates anymore.
What is the CEDP participation fee?
Visa charges 0.05% (5 basis points) on transactions that participate in CEDP, starting April 12, 2025. The lower Product 3 rate usually more than offsets it, but only when your data passes validation and you're on interchange-plus pricing.
Can TouchSuite help me migrate to CEDP on Authorize.net?
Yes. With more than 10 years of Authorize.net experience, TouchSuite reviews your Level 2/3 setup, confirms processor support, builds or fixes your API integration so Product 3 data is sent correctly, and models your costs against the new schedule. Fill out the form to get started.
Make sure your Authorize.net setup is CEDP-compliant
Fill out our short form and a TouchSuite Authorize.net specialist will review your enhanced data setup, confirm CEDP readiness, and show you where you can lower fees under the new schedule.
Fill Out the Form →Also using NMI? Read our guide to NMI Visa CEDP compliance.
← Back to Blog