Does Reg Z's 60-day window outlast your return policy?

Yes: under Reg Z's 60-day window, a cardholder has 60 days from the first statement showing a billing error to tell the card issuer in writing, and the card networks typically allow 120 days to dispute. A 30-day return policy is the shortest clock on the purchase, and the merchant controls only that one.

How long does Reg Z give a customer?

Regulation Z (Reg Z), the federal rule on credit card billing published by the Consumer Financial Protection Bureau, gives the cardholder 60 days. Under 12 CFR 1026.13, the written billing-error notice must reach the creditor within 60 days of the first statement showing the error.

The 60 days start from a statement date, not a purchase date, so the real window is longer than it sounds. A customer who buys on the 2nd, receives a statement on the 28th and notices the charge a week later is still well inside it.

Once written notice arrives, the issuer must acknowledge it within 30 days and resolve it within two complete billing cycles, and in no case later than 90 days. During that period the cardholder need not pay the disputed amount and the issuer may not collect it. Count your return window from the purchase, and the customer's window from their statement.

What do the card networks add?

The networks give the customer longer still. Stripe's documentation says the card networks typically allow cardholders 120 days to dispute, and that issuers usually take 60 to 75 days to decide.

Visa reason code 13.6, "credit not processed", covers a promised credit that never arrived. The issuer waits 15 days from the date on the credit receipt before disputing, and then has until 120 days from that receipt date. What the issuer expects on this code is set out on the Visa 13.6 reason code page.

A merchant who promised a refund and never issued it is exposed for months. A merchant who issued a refund late is exposed too, because the customer may have filed in the gap, so check every promised refund has gone through.

Does Reg Z make you take returns?

No. Section 1026.12(e) deals with what happens after a merchant accepts a return, and does not itself require a merchant to take returns. It does say that a merchant who routinely gives cash refunds must offer card customers a credit or cash refund too, unless the policy was disclosed at the point of sale.

Once a return is accepted, the merchant has 7 business days to send a credit statement to the issuer, and the issuer credits the cardholder within 3 business days of receiving it. A refund can therefore take over a week to appear on a statement without any wrongdoing.

Put the pieces together and the customer's experience is predictable. A buyer returns an item on day 25 under a 30-day policy, the parcel takes eight days to arrive and the warehouse takes a week, so the return is accepted on day 40. The credit goes to the issuer the following week, and the cardholder who checks on day 50 and sees nothing files a billing error or a 13.6 claim.

Why is this dispute cheap to prevent but costly to fight?

The evidence is the refund itself, and it only exists if the refund was issued in time. A full refund issued before the dispute lands, with a date, an amount and ideally an acquirer reference number, is quick to produce.

A merchant still arguing about the return when the dispute arrives has the harder case. Stripe says you cannot issue a refund outside the dispute process while a dispute is open, and Shopify says refunds cannot be issued while a chargeback is open.

Every date in the story above came from the merchant's own process, and every one was inside the customer's rights. Review where your returns spend their days, from carrier to warehouse to refund.

Takeaway: what to do this week

1. Refund when the return is in transit. Issue the refund when the carrier shows the return in transit, rather than when the warehouse processes it.
2. Send the date and amount in writing. Keep a copy, because that record is what an issuer expects when it asks about a credit that has not appeared.
3. Disclose your refund policy at the point of sale. If you routinely give cash refunds, card customers are owed the same unless you disclosed otherwise.

Sources: CFPB, Regulation Z, 12 CFR 1026.13(b)(1), 1026.13(c), 1026.13(d)(1) and 1026.12(e); Visa Core Rules (18 April 2026), Table 11-125; Stripe Docs, "How disputes work"; Shopify Help Center, "Resolving a chargeback". All checked 24 October 2026.