One year in, VAMP enforcement looks graduated rather than absolute.
VAMP enforcement began on 1 October 2025, ending a six-month advisory period that ran from the program's launch on 1 April. A year in, the regime has been less disruptive than the press coverage at launch suggested, and the merchants most exposed to it are largely the ones who were already on regulator radar before the merger.
The structure of who got caught is consistent with that read. The Visa Dispute Monitoring Program and the Visa Fraud Monitoring Program, retired on 31 March 2025, had each maintained watch lists of merchants exceeding the prior thresholds. When VAMP launched, the merger pulled those merchants forward into the new program with their histories intact, and the first wave of enforcement actions was dominated by those names. Merchants who had been below both prior thresholds and remained below the 2.2% (later 1.5%) VAMP threshold experienced no program-side change.
Where VAMP has bitten, the consequences have been graduated rather than terminal. Acquirers receiving Above Standard or Excessive notices have responded with the tools available at the merchant level: rolling reserves, payout delays, written remediation plans, probationary monitoring periods. Outright account terminations are rare and reserved for cases combining persistent threshold breaches with other risk signals. The press coverage at launch suggested a binary fail-or-pass regime; what merchants experience is a graduated band, and the band itself is moving as the April 2026 threshold reduction works through.