Reviewing the Chargeback Time Limit for Cardholders & Merchants

by Adam Kaplan

The credit card chargeback time limit refers to the specific time window allowed for parties to respond to each phase of a chargeback dispute. Cardholders, banks, and merchants each need to keep to the deadlines imposed by the card networks or risk losing a claim.

Restricting the time-frame for all responses keeps the process from dragging out and helps ensure that both cardholders’ and merchants’ rights are upheld. Time limits, however, are just one of the many inherent regulations that make fighting chargebacks a complicated and stressful process. Plus, time limits are not standardized across card networks; they can vary by as much as two months, depending on the chargeback type.

To demonstrate how credit card dispute time limits can deviate between schemes, we take a look at a few of the largest networks: Mastercard, Visa, and American Express.

Visa Chargeback Time Limit & Claims Resolution

Until recently, the credit card chargeback time limits for Mastercard and Visa had only minor differences. The new Visa Claims Resolution (VCR) initiative, however, made the differences much more distinct.

VCR was implemented, in part, to speed up the overall chargeback dispute process. That includes cutting the allowable times for responses, as well as equalizing response windows across all parties.

Visa also removed the "timing out" option: under the legacy system, merchants had the option of simply ignoring a request for response until the allowable time ran out, effectively accepting the chargeback by default. Now, Visa imposes a fine on merchants who don't respond in a timely manner--even if that response is an acceptance of the chargeback.

Mastercard Chargeback Terminology & Stipulations

Mastercard uses specific terms for each phase of the chargeback process. Understanding these terms will help anticipate the appropriate chargeback time limit for a transaction.

First Presentment: the merchant processes the original transaction.

First Chargeback: the issuer or cardholder disputes the transaction.

Second Presentment: the merchant “re-presents” the transaction, accompanied by supporting evidence that contradicts the chargeback.

Pre-Arbitration Chargeback: the issuer disputes the merchant’s chargeback representment.

Chargeback Arbitration: the merchant, cardholder and issuer are unable to resolve the case, forcing Mastercard to intervene and make a final decision.

Keep in mind that not all of these steps will apply to every chargeback. Some cases won't proceed beyond the initial chargeback; most won't see the pre- arbitration stage, and very few will last all the way to arbitration.

The majority of Mastercard credit card chargeback time limits are based on the Central Site Business Date, which is considered "Day One" for that phase. Subsequent deadlines start at that date, then go until the phase is completed. The day of phase completion becomes the new Central Site Business Date for the next phase.

The system becomes clearer when put into context. Each specific date depends on the stage of the chargeback process:

When filing a first chargeback, the Central Site Business Date is the day the original transaction was processed, so the deadline is a fixed number of days from that event.
If filing a second presentment, the Central Site Business Date for the entire phase is the day the first chargeback is processed.
When filing an arbitration chargeback, the Central Site Business Date is the day the second presentment is processed.
If the case continues to arbitration, the Central Site Business Date is the day the arbitration chargeback is processed.

An issuer may file only one chargeback per transaction within the applicable timef rame for the given chargeback reason code. However, the process can be expedited in certain situations. For example, if the necessary supporting documentation isn’t provided within eight calendar days of the second presentment, the issuer can submit an arbitration chargeback after the ninth day.

Mastercard Chargeback Time Limits That Apply to the Issuer/Cardholder

The deadlines for chargeback responses are imposed by Mastercard and based on the case's assigned reason code. The issuer has leeway in some cases to alter the time limits offered to the cardholder, but the customer must act within that predetermined time limit.

In most cases, cardholders may only file a chargeback within 120 calendar days of the Central Site Business Date, with some codes requiring shorter timeframes. Note that these limits apply only to the issuer and/or cardholder; acquiring banks and merchants have a set time limit of 45 days to respond to each phase.

Chargeback Reason Code	Time Limit in Calendar Days
4808 - Authorization Related Chargeback	90 Days
4831 - Transaction Amount Differs	120 Days
4834 - Duplicate Processing	120 Days
4837 - No Cardholder Authorization	120 Days
4840 - Fraudulent Processing of Transactions	120 Days
4841 - Canceled Recurring Transaction	120 Days
4842 - Late Presentment	120 Days
4846 - Correct Transaction Currency Code Not Provided	120 Days
4849 - Questionable Merchant Activity	120 Days
4850 - Installment Billing Dispute	60 or 120 Days
4853 - Cardholder Dispute, Defective/Not as Described	120 Days
4854 - Cardholder Dispute, Not Elsewhere Classified (U.S. Region Only)	60 or 120 Days
4855 - Goods or Services Not Provided	120 Days
4859 - Addendum, No-show, or ATM Dispute	120 Days
4863 - Cardholder Does Not Recognize, Potential Fraud	120 Days
4870 - Chip Liability Shift	120 Days
4871 - Chip/PIN Liability Shift	120 Days

Mastercard Chargeback Time Limits: Exceptions

Having different credit card chargeback time limits for different reason codes is confusing enough, but unfortunately, it gets even more convoluted. Although Mastercard's chargeback time limits are fairly strict, there are some exceptions or conditions that can alter that timeframe. Specifically, the codes 4850, 4854, 4855, and 4860 offer varying time limits.

Chargeback Reason Code

4850 Installment Billing Dispute

Time Limit in Calendar Days

Within 120 days from when the ongoing services were stopped, with a maximum of 540 calendar days from the transaction settlement date
Between 15 and 120 calendar dates from the transaction settlement date
Between 15 and 120 calendar dates from the delivery/cancellation date of
goods / services
For payments of interrupted, ongoing services, the maximum time limit is 540 days after the Central Site Business Date

Chargeback Reason Code

4854 Cardholder Dispute, Not Elsewhere Classified

Time Limit in Calendar Days

60 calendar days after the cardholder reports the issue
120 calendar days after the Central Site Business Date

Chargeback Reason Code

4855 Goods or Services Not Provided

120 calendar days after the Central Site Business Date when goods or services were provided
120 calendar days after the latest anticipated delivery date when the provision of goods or services was delayed

120 calendar days after the cardholder’s realization that interrupted services have ceased, but not to exceed 540 calendar days of the Central Site Business Date

Chargeback Reason Code

4860 Credit Not Processed

Time Limit in Calendar Days

120 calendar days after the service was cancelled or the goods were returned

120 days after credit documentation is issued (day zero is the date published on the document, the date of the merchant’s letter, or the date the issuer received the letter)

The issuer must wait to process the chargeback until 15 calendar days have passed from:

The date on the credit document
The date the merchandise was returned
The date services were terminated

The 15-day time limit can be waived if:

The merchant sends the issuer a letter stating a chargeback can be used to provide credit
The issuer has proof of an improperly disclosed in-store credit The TID is voided by the merchant

Mastercard Chargeback Time Limits That Apply to the Acquirers and Merchants

While they have chargeback rights allowing them to dispute the cardholders’ claims, merchants and their acquirers are bound by much more stringent time limits:

The acquiring bank must submit the second presentment within 45 calendar days of the Central Site Business Date (in this case, the day the bank receives the chargeback).
The issuing bank must initiate an arbitration chargeback within 45 calendar days of the Central Site Business Date (the day the bank received the second presentment).

Either party must seek arbitration within 45 calendar days of the Central Site Business Date (the day the arbitration chargeback is presented).
The bank must provide the necessary documentation within eight calendar days of submitting the chargeback, second presentment, or arbitration chargeback.

Visa Dispute (Chargeback) Time Limits

As noted earlier, Visa has predetermined chargeback time limits much like Mastercard. However, under the new VCR initiative, the company consolidated reason codes and recalculated the various time limits to better methodize the system. If you don't feel comfortable with VCR yet, here's a good place to start:

Visa's post-VCR terminology differs from Mastercard's as well:

Mastercard Term	Visa Term
Chargeback	Dispute (Chargeback Dispute)
Second Presentment (Chargeback Representment)	Dispute Response/Pre-Arbitration
Arbitration Chargeback (Pre-arbitration Chargeback)	Dispute Response Reversal

Most of the new time limits for chargebacks--or disputes, as Visa now labels them--are set at 30 days for merchants, and that is scheduled to be made even shorter in 2019. Businesses will need to respond within that time window in order to challenge the dispute.

Visa would like to have all disputes resolved within 31 days, if possible. All responses are tracked through Visa Response Online (VROL).

Visa Chargeback Time Limits That Apply to the Issuer/Cardholder

Under VCR, chargeback disputes are tracked through one of two workflows. While the chargeback time limits for merchants and acquirers has seen a mandatory reduction, the limits for cardholders can vary from one issuer to another. Visa has established core chargeback rules--that's what we show below--but individual issuers have some freedom in setting limits, as well.

Again, these are time limits for cardholders and/or issuers only; acquirers and merchants must respond within 30 days for each phase.

Chargeback Reason Code	Time Limit in Calendar Days
10.1 EMV Liability Shift Counterfeit Fraud	120 Days
10.2 EMV Liability Shift Non-Counterfeit Fraud	120 Days
10.3 Other Fraud — Card Present Environment	120 Days
10.4 Other Fraud — Card Absent Environment	120 Days
10.5 Visa Fraud Monitoring Program	120 Days*
11.1 Card Recover Bulletin or Exception File	120 Days
11.2 Declined Authorization	120 Days
11.3 No Authorization	120 Days
12.1 Late Presentment	120 Days
12.2 Incorrect Transaction Code	120 Days
12.3 Incorrect Currency	120 Days
12.4 Incorrect Transaction Account Number	120 Days
12.5 Incorrect Transaction Amount	120 Days
12.6 Duplicate Processing or Paid by Other Means	120 Days
12.7 Invalid Data	120 Days
13.1 Services Not Provided or Goods Not Received	120 Days
13.2 Cancelled Recurring Transaction	120 Days
13.3 Not as Described or Defective Merchandise	120 Days
13.4 Counterfeit Merchandise	120 Days
13.5 Misrepresentation of goods and/or service	120 Days
13.6 Credit Not Processed	120 Days
13.7 Cancelled Merchandises/Services	120 Days
13.8 Original Credit Transaction Not Accepted	120 Days
13.9 Non-Receipt of Cash/ Transaction Value at ATM	120 Days

*Time limit begins on the day the fraud is identified by the Merchant Fraud Performance Program.

Another new element under VCR involves what is called pre-arbitration: issuing banks and cardholders will now have 30 days to respond to the merchant's rebuttal.

Visa Chargeback Time Limits: Exceptions

As with Mastercard, Visa has some exceptions or conditions that can change the amount of time allowed. The most significant time limit modifiers are attached to three specific codes, 13.1, 13.3 and 13.6.

13.1 Services Not Provided or Goods Not Received

Under this reason code, if the delivery of goods or services can reasonably be expected after the actual transaction date--buying concert tickets a month before the event date, for example--chargeback time limits are calculated based on multiple criteria. First, the issuing bank must wait 15 calendar days before initiating a dispute. This time period starts on either:

The transaction date, if the date the expected goods/service delivery date was unspecified

The date the Cardholder returned or attempted to return the merchandise (if the merchandise was returned due to late delivery)

Additionally, the dispute must be processed either

Within 120 days of the last date the cardholder expects to receive the goods or services, not to exceed 540 calendar days from transaction; or
Within 120 days of the date the cardholder was informed that the goods/services would not be provided, not to exceed 540 calendar days from transaction

13.3 Not as Described or Defective Merchandise

Under this reason code, if the cardholder deems the goods or services defective or not as described, the chargeback time limit is calculated based on one of the following, depending on the situation:

Situation	Start of Time Limit
Where the goods/services were purchased on or before the transaction processing date.	120 calendar days past the date the cardholder expected or was promised to receive goods or services
Where there is a delay in delivery of the goods or services	120 calendar days past the date the cardholder was told the goods/services would not be delivered/provided
Where goods or services were provided after the transaction processing date	120 calendar days past the date the cardholder received the goods or services

13.6 Credit Not Processed

Finally, this reason code deals with chargebacks stemming from a credit not being processed. Issuers must wait 15 calendar days from the Credit Transaction Receipt before initiating a dispute. This does not apply if the CTR is undated ... or if doing so would cause the dispute to go beyond the time limit.

For filing, the dispute must be processed no later than 120 calendar days from either:

The Transaction Processing Date

The date on the Credit Transaction Receipt or--if the CTR is undated-- the date the cardholder returned the merchandise or canceled services

Visa Chargeback Time Limits That Apply to the Acquirers and Merchants

Like Mastercard, all timeframes are measured from Day One of the applicable phase. However, where Mastercard counts days from the actual Central Site Business Date, Visa timeframes start on the day after.

	Legacy Time Limit	Current Time Limit
Dispute Response	45 days	30 days
Pre-Arbitration	30 days	30 days
Pre-Arbitration Response	30 days	30 days
Arbitration	60 days	10 days

Prospering Despite Strict Deadlines

Managing chargebacks is challenging under the best of circumstances, and while chargeback time limits certainly provide a benefit, they can make the process even more stressful for merchants. Visa's new simplified process should help with that in the long run, but having the two major card schemes handling chargeback disputes in significantly different manners makes things much more complicated in the meantime.

Having said that, not fighting illegitimate chargebacks is essentially throwing away profits. Each chargeback representment is a unique attempt to reclaim money that never should have been lost in the first place. This balancing act often leaves merchants feeling helpless.

Discover Chargeback Time Limit For Transaction Disputes

In compliance with the Truth in Lending Act of 1968, Discover card holders are entitled to dispute a payment card charge by filing for a chargeback. Although the company recommends cardholders file a dispute within 120 days of the purchase, Discover does not impose a strict time limit and disputes will be considered at any time.

In some cases, a Discover cardholder might make an inquiry about a transaction, but not necessarily proceed directly to a chargeback. In these cases, Discover will transmit a ticket retrieval to the merchant (referred to as a copy request by Visa and a retrieval request by MasterCard).

Once the merchant receives a ticket retrieval, they have 20 business days to provide Discover with either a copy of the original receipt or refund the transaction. If the original receipt is not available, the merchant may also provide a substitute receipt with the following information:

Card number

Name of the cardholder

Card expiration date

Transaction amount

Authorization code

Merchant name and location

Description of goods or services provided

If the merchant has not responded after 20 days, or any of the above information is missing from the merchant’s response, Discover will typically move the dispute along to a chargeback.

Like other networks, Discover attaches a reason code to each transaction dispute. Some of the most commonly-seen reason codes include:

Reason Code	Description
AL	Airline Transaction Dispute
AP	Automatic Payment
IC	Illegible Sales Data
IN	Invalid Card Number
LP	Late Presentment
NA	No Authorization
RG	Non-Receipt of Goods or Services
RM	Cardholder Disputes Quality of Goods or Services
RN2	Credit Not Received

American Express Handles Chargebacks Differently

There are several ways American Express chargebacks differ from those issued by others like Visa Mastercard. One example of such a difference is the AmEx chargeback time limits for both cardmembers and merchants:

After an inquiry is issued, merchants have 20 days to respond.
After a chargeback is issued, merchants have 20 days to respond.
There is no time limit for cardmembers--a transaction can be disputed at any time.

American Express Chargeback Time Limits That Apply to the Merchant

Like Discover, Amex is both an issuer and it's own card network. They utilize bank identification numbers in the range between 34**** and 37****. Along with that are many other eccentric rules and regulations for merchants. For example, there are two key components in the American Express chargeback process: inquiries and chargebacks.

If the cardmember disputes a transaction, American Express might send an inquiry to the merchant. An inquiry is a request for additional information used to verify the original transaction.

Because American Express acts as both the issuer and card network, there are few situations where the merchant would need to provide additional documentation.

If American Express does send an inquiry, the merchant has 20 days to respond. If the merchant doesn’t reply within the American Express chargeback time limit or the documentation doesn’t sufficiently address the issue, the inquiry will automatically turn into a chargeback.

The merchant won’t always receive an inquiry. In most cases, American Express will issue an immediate chargeback to the merchant; there are few situations where the financial institution doesn’t have sufficient information to address the cardmember’s concerns.

In fact, if a merchant experiences high inquiry rates, American Express will advance the dispute process by only issuing chargebacks to that merchant. Inquiries will no longer be sent.

If the merchant feels the chargeback has been issued in error, there is the opportunity for a chargeback reversal. Each American Express reason code has its own required documents needed to complete a chargeback reversal.

Chargeback reversal paperwork must be submitted within 20 days of the date the chargeback was issued.

American Express Chargeback Time Limits That Apply to the Cardmember

Because card networks are constantly updating their regulations, it is important to consult the most current set of chargeback regulations and policies.

Since the most recent (2014) American Express Merchant Regulations manual didn’t mention time limits that applied to cardmembers, we decided to do some investigating.

According to the card network’s customer service department, there are no AmEx chargeback time limits for cardmembers.

“For U.S. accounts, we will make an attempt to open an investigation regardless of the age of the transaction.”

Bad News for Merchants

Merchants who accept American Express transactions will encounter many challenges regarding chargebacks.

Because there essentially isn’t a deadline for filing a chargeback with American Express, merchants will likely be completely blindsided by a sudden revenue loss months after the original transaction.

A second chargeback management setback is the fact that American Express offers very few representment opportunities for merchants.

In the American Express Merchant Regulations, there is a section in the chargeback chapter that outlines the necessary support required to request a chargeback reversal. The vast majority list “proof that a credit which directly offsets the disputed charge has already been processed.”

Lastly, American Express makes it incredibly easy for cardmembers to dispute a transaction. Most cardmembers are probably ignorant of the fact a “dispute” is actually a chargeback, and the act has severe repercussions for the merchant. If you have any further questions, please contact us at 877-298-6939 or adam@discountccsupply.com.