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Department of Finance public consultation on Regulation (EU) 2015/751 on
Interchange Fees for Card-based Payment Transactions
Response of Visa Europe
Visa Europe welcomes the opportunity to comment on the potential impact of Regulation (EU)
2015/751 on Interchange Fees for Card-based Payment Transactions (the Regulation) in Ireland and
on how Ireland should apply the Member State discretions contained within the Regulation.
In this paper, we set out first some relevant background which we believe will assist the Department in
considering these issues. We then respond to the specific questions raised in the consultation. The
key points that Visa Europe wishes to raise in this response are summarised below.
Executive Summary
Visa Europe operates in a highly competitive Irish market, which includes a wide and diverse range of
traditional and new payment options. This competition drives investment and innovation for the
benefit of both merchants and consumers. Against this background, Visa Europe believes it is
important that any decision regarding the Member State discretions contained within the Regulation is
taken with a view to promoting the further development of the payments sector in Ireland. In
particular:
(a)
(b)
(c)
The scope of the Regulation should not exclude three party schemes because:

providing three party schemes with unjustified preferential treatment in the form of an
exemption from the Regulation would not guarantee a level playing field for participants in
the sector – contrary to one of the overarching central objectives of the Department of
Finance in regulating the Irish market to promote a competitive environment;

such an unnatural market distortion would present a real risk of disrupting the current
competitive dynamics of the payments sector and undermining its pro-consumer market
incentives by creating allocative inefficiencies; and

merchants would continue to be charged higher prices by three party schemes, resulting in
inflated costs for merchants which are being passed on to consumers.
Ireland should opt for a weighted average fee cap of 0.2% of the annual average transaction
value of all domestic debit card transactions because:

a weighted average allows flexibility to set higher and lower rates to promote innovation
and security;

a weighted average is straightforward to calculate and monitor;

0.2% is the appropriate average level given the history of interchange rates in Ireland – and
setting the fee too low risks unintended consequences as explained in (c) below; and

a weighted average allows for minimum and maximum fees, which protect card use for
high value and low value transactions.
Ireland should not opt for a per transaction fee cap of lower than 0.3% with regard to
domestic credit card transactions because:

this risks serious unintended consequences – because it is around the marginal cost of a
transaction, to set a cap lower than 0.3% is likely to mean card issuers making a loss on
each transaction, which would lead to likely increases in fees and/or reduction of
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cardholder benefits and this in turn could discourage card usage. These changes would
adversely affect retailers and cardholders; and

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1.1
it would not allow payment service providers to make structurally necessary investments in
innovation (including in security for the encouragement of fraud reduction).
Background
In this background section we cover the following:
(a)
what Visa Europe is and how it operates as a four-party payment scheme;
(b)
the indispensable role of interchange in a four-party payment scheme;
(c)
how interchange rates have been set in the past in Ireland; and
(d)
the principles that Visa Europe believes should apply to proposed new legislation in this
area.
Visa Europe
1.2
Visa Europe is a pan-European membership association, owned and operated by over 3,000
banks, financial institutions and payment service providers across Europe. While Visa Europe is
a dedicated European payment system, responding to the needs of European service-users, it
is also the sole licensee of Visa Inc. in Europe and works closely with Visa Inc. to enable the
global interoperability of Visa payments anywhere in the world.
The four-party model
1.3
1.4
Visa is a four-party payment scheme. By way of background, we set out below how a four-party
card payment scheme functions. Whenever goods are purchased between a cardholder and a
merchant through a four-party card payment scheme, the following parties are involved:

the cardholder;

the issuer (i.e. the institution which issues the card to the cardholder);

the merchant; and

the acquirer (i.e. the institution which manages card transactions for the merchant).
For ease of reference, we set out below a diagram showing how a four-party card payment
transaction is carried out in practice.
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The market on which card payment schemes operate is a two-sided market characterised by
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“network effects”: the more merchants that accept a particular card, the more consumers will
use that card; and the more consumers that use that card, the more merchants will accept it.
Interchange fees and merchant service charges
1.5
The interchange fee is a fee payable by the acquirer to the issuer. Among other things, it
contributes to the cost to the issuer of providing a payment guarantee to the acquirer; this could
be compared to a factoring service. The levels of the interchange fee that acquirers pay to
issuers for Visa transactions are based on objective legally compliant methodologies and also
take into account the economics of the four-party model. This interchange fee needs to work
equally for both the issuer and acquirer and be set at the optimal level in order to support the
two-sided economic model for cardholders and merchants.
1.6
Merchants are charged a merchant service charge (MSC) by their acquirer. The MSC is
composed of several components which may include the interchange fee. The MSC is
deducted, by the acquirer, from the amount that the merchant receives for the transaction with
the cardholder. The MSC may be used by the acquirer to recoup its costs relating not only to
the processing of the transactions but also to other factors, including risks such as those
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associated with the fact that most transactions are guaranteed.
Costs of payment methods
1.7
1
2
Cash and cheques are not “free” to merchants or to society, although the costs are not always
obvious and they can easily be understated. From an economic standpoint, a typical merchant
will save money if they reduce their cash and cheque usage, as well as receiving other benefits
if they get faster, more efficient and “guaranteed” card payments. The acceptance of cards also
brings particular benefits to smaller merchants for higher-value transactions, for which they may
not be able to take the security risk of taking cash or cheques. Accordingly, card payments are
more efficient than cash, reduce the “shadow” economy and overall save costs.
A direct network effect arises where the value of a product increases with the number of other customers consuming the
same product.
The value of this payment guarantee is often promoted by consumer groups with well-publicised examples being when,
for example, travel companies fail, those paying with a Visa card normally get their money back.
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Merchant indifference methodology
1.8
The European Commission considers that, for immediate debit cards, a weighted average
interchange fee of 0.20% satisfies the “merchant indifference test” and brings about efficiencies
and consumer benefits. In the Visa Europe 2010 Commitments Decision, the European
Commission stated that “the interchange fee level compatible with the merchant indifference
test aims to generate benefits to merchants and subsequent purchasers and allows the
promotion of efficient payment instruments. By ensuring that overall merchants are indifferent
between accepting and handling card payments and other means of payments, such an
interchange fee creates a level playing field for competition between alternative payment
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instruments…” If a merchant is to be “indifferent” between different payment types, it is
appropriate that a MSC reflects the cost they save.
1.9
It is important against this background to ensure that there is economic balancing: the lower the
interchange fee, the less attractive card transactions will be to card issuers who may then start
to reduce card issuance and/or pass on costs to consumers which would lead to an increased
use of cash. In other words, too low an interchange fee level may lead to a scenario of card use
effectively subsidising cash.
Merchant cost considerations vary
1.10
It is important to emphasise that there are wide differences in individual merchant operating
models and this needs particularly to be taken into account in a market such as Ireland, where
card usage is spread across so many retail and business sectors; some, such as supermarkets,
typically often have lower cash costs, whereas others, such as hotels, have potentially higher
cash costs. On this basis, to attain the correct level of indifference, the interchange fee for
retailers should reflect these differing cost bases and, therefore, should not necessarily be equal
across all sectors.
1.11
Moreover, different interchange fees have the benefit of encouraging optimal behaviour; for
example, a lower rate for higher transaction security, as used in the past years to promote EMV,
secure e-commerce and contactless. Without a different fee for secure transactions, there will
be less encouragement to reduce fraud and disputes. This is relevant to a number of the
questions below regarding the appropriate approach to setting interchange rates in Ireland.
Visa interchange in Ireland
1.12
In the period from 2002 to 2007, no specific Visa interchange rates were set in Ireland. Instead,
interchange rates in Ireland defaulted to the Visa Europe intra-regional multilateral interchange
fee (MIF), which was set by the Visa Europe Board in accordance with the European
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Commission’s exemption decision.
1.13
On 2 March 2007, the Visa Europe Board resolved that domestic consumer debit transactions in
Ireland would from 25 August 2007 no longer default to the Visa interchange intra-regional MIF.
Instead, specific MIFs were set by the Visa Europe Board for domestic Visa consumer debit
transactions in Ireland (which also supported the launch of Visa Debit in Ireland in the second
quarter of 2007).
1.14
On 27 February 2009, the Visa Europe Board resolved that the domestic Visa credit and
deferred debit consumer interchange fees in Ireland would no longer default to the Visa Europe
intra-regional MIF with effect from 7 November 2009. Specific domestic Visa credit fees for
transactions in Ireland were approved by the Visa Europe Board with effect from 7 November
2009.
3
4
2010 Commitments Decision, paragraph 61. See also paragraphs 57 to 68.
Commission Decision of 24 July 2002 - Visa International - Multilateral Interchange Fee.
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1.15
The Visa Europe Board formally agreed Commitments with the Commission regarding the Visa
Europe intra-regional debit MIF in December 2010 and regarding the Visa Europe intra-regional
credit MIF in February 2014. The Visa rates in Ireland have always been set in accordance with
applicable methodologies as agreed with the European Commission, and as set out in the
Commitments in 2010 and 2014. Thus, as a result, Visa Europe’s interchange fees in Ireland
have effectively been regulated.
Legislative principles
1.16
1.17
Visa Europe always assesses proposed new legislation using five key principles:
(a)
all market participants should operate on a level playing field enabling full and open
competition;
(b)
both the supply and the demand side of payments should be motivated to promote the
use of more electronic innovative payments instead of cash;
(c)
a viable balance between payment security and consumer convenience should be
established;
(d)
legal certainty is necessary to ensure that the supply side can make the necessary
investment decisions and can continue to foster innovative solutions; and
(e)
operational requirements should be fully commercially viable, technically neutral and
capable of being delivered within a realistic timeframe.
Against this background, Visa Europe sets out below its specific comments on the questions
raised in the consultation.
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Article I – Scope
Question 1: With regard to domestic payment transactions, do you think Ireland should
avail of the discretionary exemption contained within Article 1, paragraph 5 in relation to
three party payment card schemes that operate here via other licensed payment service
providers, with co-branding partners or through an agent?
2.1
No, for the reasons set out in response to Question 2 below.
Question 2: Can you identify potential positive and negative impacts of your preferred
approach?
2.2
Visa Europe operates in a highly competitive Irish market, which includes a wide and diverse
range of traditional and new payment options, including, among others, three party schemes,
online payments, mobile, bank transfers and cash. This competition has and continues to drive
investment and innovation for the benefit of both merchants and consumers. Thus, Visa Europe
is concerned at the damaging impact that would ensue from allowing the discretionary
exemption contained within Article 1, paragraph 5 of the Regulation in relation to three party
schemes. The consequences of granting the discretionary exemption to three party schemes
are set out below.
(a)
Significance of three party schemes (whether operating via other licensed payment
service providers or otherwise) within the payments network infrastructure and the
risk of inflated costs for consumers and merchants
2.3
The highly competitive payments market has changed substantially over the years. The
competitive significance of three party schemes in relation to Visa Europe is particularly relevant
in relation to credit card payments; and, it is this significance which makes it appropriate for
them to be considered within the scope of the Regulation. Indeed, it is important that all market
participants (including three party schemes, whether or not they are operating via other licensed
payment service providers, and any new models of payment schemes in the future) operate on
a level playing field so as to enable full and open competition.
2.4
Whilst historically, some three party schemes, like American Express, have focussed on
providing commercial credit cards and targeting so-called “affluent” consumers who make high
value purchases, the business model has evolved in recent years. Today, American Express,
for instance, increasingly focuses on a wider range of consumers through a number of different
approaches. American Express’ “Global Network Services” (GNS) business operates its third
party issuing and acquiring business and, in this context, operates a four-party model like Visa
Europe. The GNS model provides more immediate access to larger numbers of consumers and
merchants through American Express’ three-party model. Visa Europe understands that in
2012, 78% of all non-US American Express cards were issued by GNS partners.
2.5
At present, three party systems do not have an explicit interchange fee, however such systems
already charge merchants higher prices than those charged by four party systems. Allowing the
discretionary exemption of three party systems from the Regulation would mean merchants
would continue to be charged higher prices by three party payment card systems. Indeed,
merchant service charges may increase overall if four party scheme cards are replaced by more
profitable (higher cost) three party scheme cards. These inflated costs for merchants would be
passed on to consumers.
(b)
2.6
Conflict with the central objectives of the Irish Department of Finance
Two of the central objectives of the Department of Finance in regulating the Irish market are to
promote a competitive environment for this market to help deliver financial products at the
lowest possible cost, and to implement regulation in order to facilitate an efficient financial
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services sector. If three party schemes are considered within the scope of the Regulation,
Ireland will safeguard a level playing field amongst current and future market players in the
payments industry, benefit users such as consumers and merchants, and promote a
competitive market.
2.7
However, if three party schemes are not considered within the scope of the Regulation, there is
a real risk of market distortion and increased costs for consumers and merchants, which is not
in alignment with the central objectives of the Department of Finance.
(c)
A level-playing field would not be guaranteed
2.8
It is a fundamental principle of EU administrative law that similarly placed parties be treated
equally. This ensures fair treatment and avoids distorting competition between operators to the
detriment of service-users, including consumers. Indeed, a market distortion such as that which
would arise from granting an exemption to three party schemes harms competition in the long
run as market success would depend no longer upon which system is beneficial to consumers,
but upon which system has the least regulatory constraints. Such an outcome would clearly be
perverse and, thus, Visa Europe considers it essential that parties offering comparable services
should be treated in a comparable way under the Regulation.
2.9
Specifically, if an exemption were to be granted to three party schemes it would provide them
with unjustified preferential treatment by allowing them to exploit market opportunities that arise
simply because they are outside the scope of the Regulation. Indeed, it is unclear why such a
discretionary exemption should be granted to third party schemes given such an approach
would create a real risk of extreme market distortion. This would not be in the best interests of
market users and contrary to the overarching objectives of the Department of Finance in
promoting an efficient financial services sector.
(d)
Negative impact on the competitive dynamics of the payments sector and
innovation
2.10
The payments market in Ireland is dynamic, involving change driven in large measure by
technology and the launch of new products which is facilitating market entry. Thus, as well as
three party and four party scheme competitors, Visa Europe also competes with several newer
payment entrants such as PayPal (as well as with traditional methods of payment such as
banks and interbank transfers). Recent developments in online and mobile banking also mean
that interbank transfers can act as a substitute for a range of payments which can also be made
using cards (e.g. payment of utility bills). This competitive and dynamic market environment is
characterised by effective levels of switching by all stakeholders in its scheme. All players
offering payment services solutions must continually innovate to meet the evolving needs and
options of service-users. Such market dynamics create compelling incentives for Visa Europe
to act in the interest of its service-users by innovating to compete more effectively.
2.11
However, any unnatural market distortion may risk undermining these pro-consumer market
incentives and create allocative inefficiencies. By not granting the discretionary exemption to
three party schemes, Ireland will safeguard the current effective drivers that advance
innovation, ensure service-user objectives and promote effective competition.
(e)
2.12
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Working towards a digital single market
The case for a pan-European approach to regulation, particularly with regard to payment
systems, is widely acknowledged; e.g. the former Commissioner for Internal Market and
Services, Michel Barnier, stated in terms that “we need a real single market in payment
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services, in particular online.” Further, the Digital Agenda for Europe, produced by the
Michel Barnier, Commissioner for Internal Market and Services, "Toward an integrated European market for card,
mobile and internet payments", Conference, 4 May 2012.
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Directorate General for Communications Networks, Content and Technology, states in relation
to payment systems that “the Commission will continue to forcefully address transformation and
change of this current patchwork system to enable the development of a fully-fledged Digital
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Single Market.”
2.13
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Accordingly, the Department of Finance should seek to harmonise its regulatory proposals with
the workings of the European Commission, national competition authorities and other European
regulatory bodies within the markets for payment systems. Such a harmonised approach is
important for regulatory consistency and certainty; it is critically important that any measures
imposed upon Visa Europe that will impact its scheme are applied in a directly proportionate
way to its competitors, including three party schemes as well as any new models of payment
schemes in the future, in order to prevent the market from becoming fragmented.
DG Communications Networks, Content & Technology, The Digital Agenda for Europe – Driving European growth
digitally, 18 December 2012, page 5.
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Article III - Fee cap for Domestic Debit card transactions
Question 3: With regard to domestic debit card transactions, do you think Ireland should
opt for:
(i)
a per transaction fee cap of lower than 0.2% and impose a fixed maximum fee as a
limit on the amount resulting from the applicable percentage rate; [Article 3.2 (a)];
(ii)
a combination fee cap of up to 5c (combined with a maximum percentage rate of up
to 0.2%) provided that the sum of interchange fees of the payment card scheme does not
exceed 0.2% of the total annual transaction value of the domestic debit card transactions
within each payment card scheme [Article 3.2 (b)]; or
(iii) a weighted average fee cap of up to 0.2% of the annual average transaction value
of all domestic debit card transactions within each payment card scheme. [Article 3.3].
3.1
For the reasons explained in response to Question 4 below, Visa Europe believes Ireland
should opt for a weighted average fee cap of 0.2% of the annual average transaction value of
all domestic debit card transactions (i.e. option (iii)).
Question 4: Can you identify potential positive and negative impacts of your preferred
approach?
3.2
Visa Europe’s objective is to establish domestic debit rates which best suit the commercial
environment in each market. In Visa Europe’s view, for the majority of markets, a weighted
average based model is the most appropriate and Visa Europe has been applying this already
in many markets including Ireland. There are three underlying reasons for this.
(a)
The rate needs to be set at a level that supports the priority of encouraging card
payments
3.3
The Irish National Payments Plan (NPP), launched in April 2013, seeks to reduce the cost of
Ireland’s payment system (estimated at 1.4% of GNP) through the increased use of more
efficient payment methods which will lead to increased competitiveness and efficiency. The
NPP estimates that if Ireland were to match best practice in Europe, savings of up to €1 billion
per annum could be made across the economy.
3.4
Cashless, more efficient, payment methods are an important aspect of this policy. Setting
interchange rates too low risks reducing card issuance and thereby restricting the growth of
card usage – contrary to the aim of increasing card payments. Card payments are more
efficient than cash, reduce the “shadow” economy and overall save costs.
3.5
Cash and cheques are not “free” to merchants or to society, although the costs are not always
obvious and they can easily be understated. From an economic standpoint, a typical merchant
will save money if they reduce their cash and cheque usage, as well as receiving other benefits
if they get faster and more “guaranteed” card payments. The acceptance of cards also brings
particular benefits to smaller merchants for higher-value transactions, for which they may not be
able to take the security risk of taking cash or cheques
3.6
For this reason, it is important that interchange fees are not set at too low a level, as explained
further in our response to Question 6 below. If the rates are optimal and lead to more
cardholders carrying out more card transactions at more merchants, the greater the scope that
exists to innovate and to see such innovation become a success, at the same time driving down
cash usage.
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3.7
While the methodology of having an ad valorem interchange rate structure will inevitably result
in merchants accepting low value secure transactions paying relatively low rates and merchants
accepting high value non-secure transactions paying higher rates – overall, the weighted
average interchange rate will remain at an appropriate level, consistent with the aim outlined
above of encouraging card issuance and usage. Simply setting a fee of 0.2% with a cap will,
arithmetically, lead to an average below 0.2% and thus the lower the cap, the lower the
average. Therefore, to set an interchange fee significantly lower than a weighted average cap
of 0.2% would be detrimental. The lower the interchange fee, the less attractive card
transactions will be to card issuers who may then potentially start to reduce card issuance
and/or pass on costs to consumers which would lead to an increased use of cash. Thus, too
low an interchange fee level may lead to a scenario of cards effectively subsidising cash.
3.8
In fact, the average Visa domestic debit interchange rate is already less than 0.2% in Ireland,
and would be expected to remain at around this level under the new Regulation.
(b)
A weighted average allows minimum and maximum fees to be set
3.9
One of the key advantages of the current system in Ireland, as in the UK, is being able to pay
high value transactions, such as tax invoices, utilities and licensing bills, remotely by card.
Thus, without a cap to limit the amount of interchange fee that could be levied, higher value
transactions would effectively be “shut out” to the detriment of all parties in the payments
system, particularly consumers.
3.10
Indeed, in line with the NPP’s objective, reducing the use of cheques (which are typically used
as an alternative for high value transactions) would be beneficial as they are slow and costly to
clear for merchants and are particularly prone to fraud and credit risk.
3.11
Therefore, while being straightforward to calculate, a weighted average fee cap has the benefit
of retaining the ability to support high value transactions. It would still allow for a cap on high
value transactions – indeed, this would be necessary to maintain the average at the appropriate
level.
3.12
Further, without a small per transaction fee that guarantees a minimum level of interchange
revenue, issuer income would become negative for certain transactions which would
significantly impact the use of cards for lower value payments. This is because issuer income
would become so low as to discourage the promotion of such low value payments and card
usage.
3.13
A weighted average that allows for minimum and maximum fees, therefore, has the benefit of
encouraging optimal behaviour with regard to payment methods.
(c)
3.14
It is important to retain some flexibility in the setting of interchange fees to reflect specific
circumstances and priorities. A weighted average approach provides a straightforward way of
allowing for this. While staying within the rate cap on a weighted average basis, different rate
structures for secure and non-secure transactions can encourage fraud reduction and promote
an infrastructure enabled for current and future innovation. This method allows for the setting of
rates specific to certain transaction segments – for example, special rates for low value and/or
contactless transactions – or according to the risk of a given channel – for example, higher rates
for less secure transactions such as mail or telephone payments.
(d)
3.15
A weighted average approach is a straightforward way of retaining necessary
flexibility
A weighted average would be straightforward to monitor
A weighted average sounds complicated but it is actually calculated (and monitored) very easily.
Indeed, Visa Europe has been monitoring average interchange fees in relation to Visa
Consumer debit rates in Ireland since February 2011, as a condition of the Commitments
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agreed with the European Commission, and we would of course be very happy to discuss with
you the process we have used and continue to use to monitor weighted average fees.
3.16
Put simply, to calculate the weighted average a scheme (and/or processor) just needs to total
all the interchange fees paid/received and divide this by the total of cardholder spend at
merchants; two numbers, one divided by the other, gives the effective (and therefore weighted)
average result.
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Article IV - Fee cap for Domestic Credit card transactions
Question 5: With regard to domestic credit card transactions, do you think Ireland
should opt for a per transaction fee cap of lower than 0.3% [Article 4]?
4.1
No, for the reasons set out in answer to Question 6 below.
Question 6: Can you identify the potential positive/negative impacts of your preferred
approach?
4.2
Visa Europe has engaged with the European Commission over the past two decades in order to
ensure clarity, consistency and viability of interchange and while a 0.3% cap was the result of
the Commitments between Visa Europe and DG Competition in 2014 in respect of credit card
transactions, to go lower would not be economically viable and risks serious unintended
consequences.
4.3
First, because this would be at around or even below the marginal cost of a transaction, to set a
cap below 0.3% would mean card issuers would likely increase fees (or reduce cardholder
benefits) to recover some of their lost revenues and this is likely to discourage card usage.
These changes would adversely affect retailers and cardholders. The lower the interchange
fee, the less attractive card payments will be to card issuers who may then start to reduce card
issuance and/or pass on costs to consumers which would lead to an increased use of cash.
Thus, as with debit, too low an interchange fee level for credit card transactions may lead to a
scenario of cards effectively subsidising cash. Such a trend is also likely to restrict innovation in
the card issuing market, with issuers discouraged from introducing new card benefits given the
additional costs that these would involve.
4.4
Second, a transaction fee cap of lower than 0.3% for credit would not allow payment service
providers to make structurally necessary investments in innovation (including in security for the
encouragement of fraud reduction) which would be to the detriment of consumers, merchants
and all participants in payments. The competitive dynamics of the marketplace have driven
Visa Europe’s significant investment and innovation strategies over the past decade. The focus
of its investments has been on: (i) ensuring the resilience and reliability of its systems and
scheme in a fast moving market, characterised by a constant flow of new payment options both
in face-to-face transactions as well as online and mobile transactions; and (ii) developing
innovative products for merchants and consumers. Clearly, both investment streams are
closely inter-linked to ensure the effective and resilient operation of Visa Europe’s schemes and
pan-European products.
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