CMSPI - State of the Industry Report - 2025

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STATE OF THE INDUSTRY REPORT

Regulatory Interventions as of July 2025

United States

European Union

Country

Australia Japan

Interchange Caps

Network Routing Requirements

Partial

Types of Intervention

Surcharging Allowed

Partial

Partial

Government Grants for Payments -Related Costs

Requirements to Publish Fee Schedules

Decreases to Some Merchant Fees

Impact

Evidence of Increased Market Share of Domestic Payment Networks Increases to Non-Regulated Fees (e.g., Network Fees, Commercial Card Interchange, Credit Interchange)

Routing Limitations by Entry Method

Limited Availability of Network Routing for Certain Channels Where the Domestic Network Could Support the Channel

Benefit Erosion Factors Observed Since Regulation

Issuance of Single-Network Cards

Partial

Partial, depending on country

Introduction of Consumer Routing Choice

Limitations to Routing When Network Tokens are Used

Limited Processor Routing Capabilities

Loss of a Domestic Network (including Consolidation)

Partial

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