Principles based surcharging, where there is no surcharging allowed for low cost systems (eftpos and scheme debit) assuming that the Reserve Bank of Australia (RBA) will require acquiring banks to separate debit and credit and not allow blending of these rates by the acquiring banks. Businesses are permitted to apply a surcharge which reflects the cost of acceptance for credit.


To ensure that there is no cross subsidisation, blended surcharging should not be permitted.


Any regulation must apply equally to all payments systems, including American Express, Diners, Union Pay, JCB, PayPal, Apple Pay, Google etc.


A threshold set at no greater than 1.5% of retail payment transactions market share before regulation is applied and regulation to capture new forms of payment systems under this model as they emerge.


It is important for both the RBA and Government to be able to quickly act on new technology and game changers in the payments sector with an appropriate mechanism set up allowing this process.


A significant and meaningful reduction in the disparity which currently exists between large and small merchants, therefore we submit our proposal around transparency on strategic merchant rate settings. A defined range of interchange rates applied to industries and products. The reset to ensure regular compliance with a weighted average of 50 basis points for interchange rates. Allowance of ‘special rates’ for a defined period of time, to allow schemes to incentivise new technologies and innovations in the market (to recognise that large merchants can assist with early adoption through leverage of their scale). We support the proposals to separate debit and credit rates in the provision of pricing to all merchants. To develop secure technologies in the payment sector minimising loss to retailers while maintaining smooth customer transactions.

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