Review of Card Surcharging: A Consultation Document – June 2011 5. Summary of Issues for Consultation
Reflecting the discussion in the previous section, the Board is seeking input from interested parties on the following issues:
- Is there a case for modifying the Standards to allow schemes to limit surcharges?
- Is a surcharge cap best implemented by the Board setting a transparent and specific permissible cap that is specified in the Standards, and may then be imposed in scheme rules? Or, should the Standards allow scheme rules to limit surcharges to an amount that is either reasonably related, or equal, to each particular merchant's cost of card acceptance?
- Should there be some level of tolerance allowed around any surcharge cap?
- Is the merchant service fee an appropriate measure of the cost of card acceptance (that can be applied consistently across all merchants)?
- Should the no-surcharge Standards clarify that, notwithstanding any surcharging cap, scheme rules cannot prohibit merchants from applying a surcharge that is either a blended rate for each card scheme or the cost of accepting each card within a card scheme? Are there alternative ways to allow for differential surcharging?
- Should the no-surcharge Standards require acquirers to pass on information about the merchant's cost of acceptance for each different card type if it is requested by the merchant? And, for those on ‘interchange-plus’ pricing, should the no-surcharge Standards require acquirers to pass on information about the weighted-average merchant service fee if it is requested by the merchant?
- Is there a case for disclosure of the cost of card acceptance by merchants? Or, would it be sufficient for the Bank to collect and publish more detailed data on merchant service fees, such as the range and average of merchant service fees across merchant categories for each card scheme?