NMI Visa CEDP Compliance: How to Migrate from Level 2 and Level 3 Without Losing Your Interchange Savings

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.
• Filled-in fields no longer count. Visa checks enhanced data with machine learning. Placeholder or generic data can lose the discount.
• There's a new fee. Participating transactions carry a 0.05% (5 bps) Visa fee.
• Discounts can be clawed back. Visa can reclassify transactions up to 45 days after settlement if the data fails validation.
• NMI is ready, but your data has to be right. NMI's Level III Advantage maps data for CEDP, but it can't fix inaccurate source data or a processor that doesn't support CEDP.

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 merchants got lower interchange on purchasing, corporate, and business cards by sending Level 2 data (tax amount, customer code) or Level 3 data (line-item detail). Visa largely took that data at face value.

CEDP changes the rules. Instead of rewarding merchants for filling in fields, Visa now validates the data itself. Transactions must carry what Visa calls "invoice-quality" data to qualify for Product 3 rates, the new name for Level 3. In practice, that means data that is:

• Complete, with every required field populated
• Accurate, with line items, tax, and subtotals that add up to the transaction total
• Descriptive, with real product descriptions and codes instead of generic text
• Error-free, since Visa returns more than 100 validation error codes

Compliant transactions can earn an interchange reduction of up to 15 basis points compared with standard commercial rates. Data that fails validation falls back to higher rates.

Why Level 2 and Level 3 are going away

Under the old programs, many merchants and gateways sent "dummy" enhanced data, such as a single generic line item or a flat tax rate, to unlock lower rates. Corporate buyers got little useful reconciliation data, 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.

The Visa CEDP timeline

Level 2/3 vs. CEDP at a glance

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.

A few bad transactions won't cost you verified status. Repeatedly sending incomplete or incorrect data without fixing it will. Acquirers receive monthly verification reports from Visa, and those reports are the best early warning that something in your data pipeline is broken.

What NMI Visa CEDP compliance looks like

NMI has confirmed that its Level III Advantage service supports CEDP. It can automatically fill enhanced data fields from a merchant-level template, using fixed values or dynamic ones such as order ID, PO number, order date, product cost, and tax amount. The gateway only fills fields that are blank and never overrides data you send through the API or Virtual Terminal.

Being on NMI alone doesn't make you compliant, though. You also need:

1. A processor that supports CEDP data. Not every processor behind the NMI gateway accepts and passes CEDP-compliant data. If yours doesn't, your enhanced data is dropped before Visa ever sees it.
2. A correctly configured Automatic Level III template. A template left with generic descriptions or a flat tax value is exactly the kind of data CEDP is designed to reject.
3. Accurate source data. Your ERP, invoicing, or order system has to send real item descriptions, quantities, and tax so line items add up to the total.
4. An error-correction process. Someone has to review Visa's verification feedback and fix the causes before you lose verified status.

How TouchSuite helps you migrate securely

TouchSuite has worked with the NMI gateway 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 and how to fix it without disrupting your payments.

A TouchSuite CEDP migration covers:

• A Level 2/3 audit. We review how your transactions qualify today and find the ones losing money under the new rules.
• Processor and gateway checks. We confirm your processor supports CEDP and that Level III Advantage is enabled and set up correctly.
• Data mapping. We map line-item, tax, and PO data from your ERP or invoicing system so it reaches the gateway at authorization in the format Visa expects.
• Secure implementation. Changes are made through NMI's tokenized, PCI-compliant tools, so card data never touches 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, so you know where Product 3 saves money and where it doesn't.
• Ongoing monitoring. We help you track verification status and fix errors before Visa claws back your savings.

Your CEDP migration checklist

1. Pull recent statements and see how much commercial card volume is still settling at Level 2 or standard commercial rates.
2. Confirm processor support for CEDP data on your NMI merchant account.
3. Turn on and configure Level III Advantage with real, accurate template values.
4. Send true line items from your ERP or invoicing system at authorization, not after settlement.
5. Check that line items, tax, and subtotals match the transaction total.
6. Review Visa verification reports monthly and fix errors quickly.
7. Re-price your B2B pricing model against the new schedule, including the participation fee.