CEDP Deadline: Visa's Level 2 Sunset Is Three Weeks Away

On April 18, Visa officially sunsets its Level 2 enhanced data program. After that date, the only way to achieve interchange savings on Visa commercial card transactions is to pass Level 3 data (now called Product 3 under CEDP). 

If your business processes corporate, purchasing, or business cards and you don't have the technical infrastructure to pass full line-item invoice data automatically, you're about to downgrade to Level 1 commercial interchange rates. Depending on your card mix, that could mean a noticeable cost increase.

A Quick CEDP Recap

Visa launched its Commercial Enhanced Data Program (CEDP) in April 2025, replacing the legacy Level 2 and Level 3 programs with a stricter, verification-driven approach to enhanced data. Instead of rewarding merchants for submitting any additional data fields, CEDP requires invoice-quality line-item data, including item descriptions, quantities, accurate tax amounts, purchase order details, and more. Here’s a brief timeline of Visa’s CEDP rollout:

After April 18, there are only two interchange outcomes for commercial card transactions in the US:

• Product 3 rates if you're passing high-quality line-item data (1.75%–2.20% + $0.10)

• Level 1 rates if you're not (2.50%–2.95% + $0.10)

Don’t forget, if you pass enhanced data but it doesn't meet Visa's quality standards, you still owe the 5 basis point CEDP participation fee. Submitting incomplete or generic data isn't a neutral choice anymore.

Who Gets Hit Hardest

CEDP—like Level 2 and Level 3 data—only applies to B2B, commercial card transactions. As a result, this change only impacts your costs if you process a meaningful share of corporate, purchasing, or business cards. If you process mostly Small Business cards, the rate increase in January actually eliminated your Level 2 savings already. For corporate and purchasing cards, Level 2 still technically saves you 15 basis points over Level 1 until the sunset on April 18th.

The sectors we predict CEDP will hit the hardest include:

• Corporate travel and events, including travel bookings, hotel charges, and event registrations

• SaaS and subscription businesses 

• IT services and cloud hosting

• Professional services, consulting, and advertising agencies

Taking Action Now

Three weeks isn't a lot of runway, but it's worth knowing where you stand before April 18 rather than finding out on your May statement. Here are some actions you can take today:

1. Review your commercial card exposure. Pull your transaction data and look at what share of your volume runs on corporate or purchasing cards. If it's meaningful, this issue is worth prioritizing.

2. Audit what you're actually passing. Talk to your payment provider and whoever owns your billing or ERP system. Find out whether enhanced data is being submitted, and if so, what's in it. The difference between passing Level 2 fields and passing invoice-quality line-item data is significant.

3. Know what a path to Product 3 looks like. Will it be easy to connect ERP invoice data to payment flows? Who needs to get involved? Knowing the lift required helps you make informed decisions about cost mitigation in the meantime.

How Pagos Can Help

Pagos Insights, our payments data visualization and insights platform, includes a Visa CEDP Calculator. It pulls your eligible Visa commercial card volume automatically, then lets you model your net savings or costs by adjusting two inputs: 

• What percentage of your eligible transactions are currently submitting enhanced data 

• What percentage of that enhanced data actually meets Visa's quality standards

The calculator applies the interchange savings from qualifying transactions, subtracts the participation fee on all enhanced-data submissions, and gives you a single net estimate. It's the fastest way to estimate expected costs and model what improving your data quality or participation rate would actually be worth. If you want to dig deeper, the Costs dashboard and custom Charts in Insights let you analyze your total interchange costs over time.

Not yet working with Pagos? Get in touch—we can show you what your commercial card data looks like and help you understand your CEDP exposure before the deadline hits.

The Level 2 sunset is a quiet change that will hit some businesses' statements in a loud way. If your payment flows run on commercial cards and you haven't pressure-tested your enhanced data setup, now's the time.