Merchant Card Payment Costs and Surcharging – Consultation Paper –
July 2025 Appendix A: Questions for Stakeholders

Q1: Would removing surcharging on designated card networks best support the RBA’s objectives to promote the public interest through improving competition, efficiency and safety in the payments system? In particular, the RBA welcomes feedback on whether there are additional public interest considerations that should be taken into account for each policy option.

Q2: Do the proposed changes to interchange regulation promote the public interest by improving competition and efficiency in the payments system?

Q3: Are there further considerations for smaller issuers that the RBA should take into account to enhance competition and efficiency in the payments system?

Q4: Do the proposed changes to the net compensation provisions effectively achieve the RBA’s objectives and promote the public interest? Will Australian issuers sponsored by overseas entities be able to comply with the changes?

Q5: Does the proposal for card networks to publish aggregate wholesale fee data achieve the RBA’s objectives of improving competition and efficiency among the card networks? Does the proposal adequately balance the information needs of the market with commercial concerns?

Q6: Does the proposal for card networks to work with industry to reduce the complexity and improve the transparency of their scheme fee schedules enhance the competitiveness and efficiency of the card payments system?

Q7: Does the proposed expectation on scheme fees achieve the RBA’s objectives of competition and efficiency in the payments system?

Q8: Should the PSB consider further regulatory measures in relation to the level of scheme fees to promote competition and efficiency in the payments system?

Q9: Does the proposed requirement for acquirers to publish their merchants’ cost of acceptance enhance competition and efficiency by helping merchants search for a better plan? In particular, the RBA welcomes feedback on:

• whether the size threshold for acquirers is appropriate
• whether the category breakdowns (merchant size and card type) are likely to be useful to merchants without compromising commercial sensitivity
• whether the quarterly frequency of publication is appropriate
• what an appropriate implementation timeline would be.

Q10: Does the proposal to amend the cost of acceptance reporting on merchant statements to include a breakdown for domestic and international cards promote competition by helping merchants receive more information about the fees they pay? Is there a public interest case to exempt taxi fares from this requirement?

Q11: Are there any changes that should be made to the RBA’s existing industry expectation on LCR implementation to improve competition and efficiency in the debit card market?

Q12: Does the PSB’s preferred package meet its objectives of competition, efficiency and safety in the payments system? Are there any variations to the package that the PSB should consider that would yield higher net public benefits? Is there any additional evidence that the RBA should consider before finalising its decision?

Q13: What is your feedback on the proposed implementation timeline for these reforms?

Q14: Do the draft standards in Appendix D achieve the intended policy objectives? Are there factors that have not been properly addressed or considered in the drafting of the proposed standards?