VISA INC. (V) Risk Factors

Recent key developments

Concrete developments — dated events, named agreements and instruments, legal proceedings — that VISA INC. surfaced in its latest filing.

• In October 2022, the Federal Reserve issued a final rule requiring issuers to ensure at least two unaffiliated networks for routing ecommerce debit transactions by July 1, 2023.October 2022
• In October 2023, the Federal Reserve proposed further lowering debit interchange rates with automatic adjustment every two years.October 2023
• In August 2025, the District Court for the District of North Dakota vacated Regulation II’s debit interchange fee standard.August 2025
• A Kentucky District Court ruled the Federal Reserve acted within its discretion in setting the debit interchange cap.
• The Credit Card Competition Act, introduced in 2022 and 2023, may be reintroduced, requiring large issuing banks to offer at least two unaffiliated networks for electronic credit transactions.2022, 2023
• In May 2024, Illinois passed a law restricting interchange assessment on state tax and gratuity portions of a transaction and limiting use of payment transaction data.May 2024
• In 2019, Visa agreed to limit certain cross-border interchange rates in a settlement with the European Commission, extended through 2029.2019
• In 2020, Costa Rica became the first country to formally regulate cross-border interchange rates.2020
• In June 2022, the UK’s PSR initiated a market review on post-Brexit interchange rate increases for UK–Europe e-commerce transactions and is proposing to cap cross-border interchange in that corridor.June 2022
• In July 2025, New Zealand adopted interchange caps on cross-border transactions including commercial credit transactions.July 2025
• In July 2025, the U.S. enacted the GENIUS Act, establishing a comprehensive framework for regulating stablecoins.July 2025
• In 2024, the Greek Parliament limited acquirer fees for certain small-ticket transactions for a three-year period.2024
• Visa entered into a settlement with the European Commission on cross-border interchange rates.
• Visa suspended operations in Russia following U.S., European and UK sanctions in March 2022.March 2022
• The European Central Bank has announced initiatives to reduce reliance on international payment networks, including support for the European Payments Initiative (EPI) and a digital euro.
• The U.S. Federal Reserve launched its FedNow Service in July 2023.July 2023
• Visa is subject to the EU’s Corporate Sustainability Reporting Directive and Corporate Sustainability Due Diligence Directive.
• Visa is subject to California legislation requiring broad disclosure of greenhouse gas emissions and other climate-related information.