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Payments & RiskJuly 17, 2024

Card Scheme Monitoring Programs: A Checklist for Gaming Operators

Card scheme monitoring programs can cost gaming operators thousands in fines. Use this practical weekly checklist to stay below threshold and protect your MID.

Card Scheme Monitoring Programs: A Checklist for Gaming Operators

Visa and Mastercard both operate formal monitoring programs that track chargeback ratios and fraud rates at the merchant level. For gaming operators, the thresholds are tighter than in most other industries, and a single bad month can trigger a cascade of fines, remediation requirements and ultimately merchant account termination. Understanding where you stand this week, not at the end of the quarter, is the difference between a manageable issue and a regulatory crisis.

How Monitoring Programs Work

Both Visa and Mastercard calculate performance metrics monthly using data reported by your acquiring bank. Visa operates the Visa Dispute Monitoring Program (VDMP) and the Visa Fraud Monitoring Program (VFMP). Mastercard runs the Excessive Chargeback Program (ECP) and the Excessive Fraud Merchant (EFM) program. Each program has two tiers: a standard tier that triggers notification and a high-risk tier that triggers escalating fines.

Gaming merchants are flagged under Merchant Category Code 7995. Acquirers dealing with MCC 7995 portfolios face their own scheme-level scrutiny, which means your acquirer has a direct commercial incentive to exit you from their portfolio if your metrics deteriorate. This dynamic makes it essential to monitor your own numbers before your acquirer does it for you.

Key Thresholds to Know Right Now

  • VDMP Standard: chargeback ratio of 0.9% or 100 chargebacks in a calendar month.
  • VDMP High-Risk: chargeback ratio of 1.8% or 1,000 chargebacks in a calendar month.
  • ECP Standard (Mastercard): chargeback ratio above 1.5% with at least 100 chargebacks.
  • ECP Excessive (Mastercard): chargeback ratio above 3% with at least 1,000 chargebacks.
  • VFMP and EFM: calculated on basis points of fraud relative to sales volume; thresholds vary by region and are reviewed periodically by the schemes.

Fines under these programs begin at a few thousand euros per month and escalate significantly the longer a merchant remains in the program. Acquirers typically pass these fines directly to the operator, often with their own administrative surcharge added on top.

Your Weekly Operational Checklist

1. Pull Your Running Chargeback Ratio Daily

Do not wait for your acquirer's monthly statement. Most payment gateways expose dispute data in near real time. Calculate your ratio as total chargebacks divided by total transactions in the same calendar month. If you are above 0.7%, treat it as an active alert, not a future problem.

2. Segment Disputes by Payment Method and Market

A blended ratio hides where the problem actually lives. Separate your data by card type, issuing country and product type. In many cases a single deposit method or a specific player cohort is responsible for a disproportionate share of disputes. You cannot fix what you cannot isolate.

3. Review Your Refund Policy Against Dispute Patterns

Chargebacks often indicate that players who wanted a refund could not easily find or use your standard refund process. If your refund rate is low and your chargeback rate is high, your support flow is probably creating friction that players resolve by calling their bank instead. Streamlining refund access directly reduces scheme risk.

4. Audit Your Descriptor Visibility

Unrecognised transaction descriptors are a primary driver of friendly fraud disputes in gaming. Confirm this week that your billing descriptor is clear, consistent across all payment flows and matches the brand name your players know. Where possible, include a customer service phone number in the descriptor.

5. Confirm 3DS2 Coverage on All Card Channels

Liability shift under 3DS2 protects you from fraud chargebacks when authentication is completed by the issuer. Verify that 3DS2 is active on every card acceptance point, including recurring billing and deposit retry flows. Gaps here convert directly into fraud chargebacks that count against your VFMP and EFM metrics.

6. Document Everything for Representment

When chargebacks are invalid, fight them. Win rates on represented gaming disputes improve significantly when you have session logs, KYC confirmation, geolocation data and communication records ready at the point of dispute. Build this evidence package into your standard player lifecycle record-keeping, not as a retroactive task.

Monitoring program enrollment is a lagging indicator. By the time the scheme notifies your acquirer, the transactions causing the problem are already settled. Operators who manage their ratios in real time rarely enter formal programs at all.

What Happens If You Enter a Monitoring Program

Enrollment triggers a remediation timeline, typically 12 months, during which you must demonstrate consistent month-on-month improvement. Failing to exit the program within the allotted period results in accelerating fines and, eventually, scheme-level termination of your MID. A terminated MID enters the MATCH list, making it substantially harder to obtain new acquiring relationships. Prevention is not just cheaper; for many operators it is existential.

How OnlineShine Supports Operators on Payment Risk

Our operations team works with gaming operators to establish real-time dispute dashboards, acquirer communication protocols and structured representment workflows. If your current acquiring arrangement does not give you the visibility you need to run this checklist, that is itself a risk worth addressing this week.

FAQ

Frequently asked questions

What is the Visa Dispute Monitoring Program and how does it affect gaming operators?

The Visa Dispute Monitoring Program (VDMP) tracks the monthly chargeback ratio and volume of individual merchants. Gaming operators whose chargeback ratio exceeds 0.9% or who generate more than 100 chargebacks in a calendar month can be enrolled at the standard tier, triggering fines and a formal remediation requirement. Operators who remain in the program beyond the allowed remediation window face escalating fines and potential loss of their Visa acceptance rights.

What chargeback ratio should a gaming operator treat as a warning threshold?

Most payment risk specialists recommend treating a running monthly chargeback ratio of 0.7% as an internal alert level, since the formal Visa monitoring threshold begins at 0.9% and Mastercard's at 1.5%. Acting at 0.7% gives the operator time to investigate and remediate before the scheme's calculation period closes. Waiting until the scheme's own threshold is crossed means fines may already be accumulating.

Does 3DS2 authentication protect gaming operators from chargebacks?

When a card transaction is authenticated via 3DS2 and the issuer completes the authentication step, liability for fraud-related chargebacks typically shifts to the card issuer rather than the merchant. This means gaming operators with full 3DS2 coverage on all card deposit channels can significantly reduce the fraud chargebacks that count toward Visa and Mastercard fraud monitoring program thresholds. However, 3DS2 does not protect against chargebacks raised on grounds other than fraud, such as service disputes.

What is the MATCH list and why does it matter for gaming operators?

The MATCH list, which stands for Member Alert to Control High-Risk Merchants, is a shared database maintained by Mastercard that acquiring banks consult before onboarding new merchants. Operators whose merchant accounts are terminated by a scheme or acquirer for excessive chargebacks or fraud are typically added to the MATCH list. Being listed makes obtaining new acquiring relationships considerably harder and can effectively prevent an operator from accepting card payments for up to five years.

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