Visa Integrity Risk Program (VIRP): What High-Risk Merchants Need to Know

If you’ve landed on this page, you’re likely facing one of these challenges: your payment processor mentioned VIRP compliance requirements, you’ve received notification about new fees or assessments, or you’re exploring high-risk payment processing options and encountered this regulatory framework. We understand these concerns—navigating VIRP can feel overwhelming, but you’re in the right place to get clear, actionable information.   The Visa Integrity Risk Program (VIRP) is Visa’s framework to deter, detect, and remediate illegal activity from entering their payment system. Introduced in April 2023 and effective May 1, 2023, VIRP replaced the Global Brand Protection Program (GBPP) with significantly enhanced requirements for acquirers sponsoring High Integrity Risk merchants. TL;DR Summary Here’s what you need to know about VIRP, organized by the key areas that will impact your business: Program Structure and Classification: VIRP categorizes high-risk merchants into three tiers based on risk level, with Tier 1 (adult content, gambling, online pharmacies, dating services) facing the strictest controls, Tier 2 (cryptocurrency, file-sharing, games of skill) requiring annual reviews, and Tier 3 (financial trading, telemarketing, subscription billing, tobacco) subject to assessment upon request. Financial Impact: Registration fees range from $10,000 for Tier 3 merchants to $500,000 for Tier 1 acquirers, while transaction fees vary by region—US merchants pay $0.10 per transaction plus 10 basis points, EU/UK pay €0.02 plus 10 bps, and other regions pay $0.02 plus 10 bps. Compliance Requirements: Merchants must implement real-time transaction monitoring by 2025, maintain robust content moderation policies with 7-day complaint response times, establish strong age verification systems for restricted industries, and submit monthly compliance reports documenting violations and remediation efforts. Enforcement and Penalties: Non-compliance assessments range from $2,000 monthly for unregistered HIR merchants to $400,000 for CSAM violations, with additional consequences including account termination, addition to the Terminated Merchant File (TMF), and loss of Visa processing capabilities across all relationships. Staying Compliant: Success requires partnering with specialized high-risk payment processors like 2Accept, investing in compliance infrastructure and fraud prevention tools, maintaining comprehensive documentation proving VIRP adherence, and conducting regular internal audits to ensure ongoing compliance. Response to Violations: If flagged, merchants receive notification through their acquiring bank with specific violations detailed, must implement corrective actions within provided timelines, undergo follow-up audits to verify improvements, and face ongoing monitoring periods based on violation severity. Payment Processor Support: Companies like 2Accept offer multiple acquiring relationships for redundancy protection, compliance expertise for audit preparation and documentation, technology solutions for age verification and content moderation, and fraud filtering tools to maintain acceptable chargeback levels. Practical Tip One universally applicable strategy for VIRP compliance: implement automated documentation systems now. Create a centralized repository that automatically logs all compliance-related activities, customer complaints, content removals, and age verifications. This proactive approach saves countless hours during audits and demonstrates your commitment to compliance before issues arise.   The sections that follow will dive deep into each aspect of VIRP, providing you with the detailed knowledge needed to navigate this complex regulatory landscape. Whether you’re already processing payments or preparing to enter a high-risk industry, understanding VIRP is your first step toward sustainable, compliant operations in the Visa ecosystem.

What Is the Visa Integrity Risk Program (VIRP) and Why Does It Exist?

The Visa Integrity Risk Program (VIRP) is a comprehensive framework designed to deter, detect, and remediate illegal activity from the Visa Payment System. Visa introduced VIRP in April 2023, making it effective May 1, 2023, to replace the Global Brand Protection Program (GBPP).    The program ensures acquirers maintain robust controls preventing illegal transactions from entering Visa’s network. Visa created VIRP because the rapidly expanding payment ecosystem requires enhanced requirements for High Integrity Risk Merchants.    VIRP establishes standardized controls across the payment industry while protecting all participants from reputational damage and regulatory noncompliance.

How Does VIRP Define High-Risk Merchants?

High-Integrity Risk (HIR) merchants are classified into a three-tier system based on risk level. The classification determines compliance requirements and monitoring intensity for each merchant category.   VIRP classifies High-Integrity Risk (HIR) merchants into three tiers based on industry category and risk level:

Tier	Risk Level	Merchant Categories	MCC Codes
1	Highest	Adult Content	5967
1	Highest	Dating/Escort Services	7273
1	Highest	Gambling	7995
1	Highest	Online Pharmacies	5122, 5912
2	High	Cryptocurrencies	6051, 6012
2	High	Cyberlockers/File-Sharing	4816
2	High	Games of Skill	5816
3	Moderate	High-Risk Financial Trading	6211
3	Moderate	Outbound Telemarketing	5966
3	Moderate	Negative Option Billing	5968
3	Moderate	Cross-Border Tobacco	5993

Each tier requires different levels of scrutiny and control assessments from acquirers processing these merchant types.

What Are the Main Objectives of the VIRP?

The main objectives of VIRP are protecting Visa’s payment system integrity from illegal activity and financial losses while ensuring adequate transaction controls. The program prevents reputational damage and regulatory noncompliance for payment ecosystem participants including banks, processors, and merchants. VIRP creates a level playing field for acquirers by rewarding those maintaining requisite controls with continued processing privileges.    The framework protects consumers from fraudulent transactions while maintaining trust in electronic payments. These objectives align with global regulatory requirements for financial institutions combating money laundering and illegal commerce.

Who Enforces the Visa Integrity Risk Program?

Visa directly enforces VIRP through regular audits and compliance assessments of acquirers and their merchant portfolios. Acquirers must undergo per-MCC control assessments for each Tier 1 merchant category they wish to process. Annual reviews are mandatory for Tier 2 merchant acquirers to maintain processing capabilities.    Visa can request control assessments for Tier 3 merchants at any time based on risk indicators or market intelligence. The enforcement structure ensures consistent application of standards across all regions and acquiring institutions processing high-risk transactions.

How Does the VIRP Impact High-Risk Merchants?

The VIRP impacts high-risk merchants through substantial registration fees, ongoing compliance costs, and stringent monitoring requirements. Merchants must pay individual registration fees beyond standard acquirer fees.    Real-time transaction monitoring becomes mandatory for HIR merchants in 2025. Acquirers conduct enhanced due diligence during onboarding and throughout the merchant relationship.   The program creates operational burdens through mandatory compliance reporting and system implementations. Technology investments for age verification, content moderation, and fraud prevention become essential. These requirements significantly increase operational costs for high-risk businesses.

What Merchant Categories Are Most Affected by the VIRP?

The merchant categories most affected by the VIRP include:

• Adult content providers – must meet the strictest moderation and age-check standards.
• Online pharmacies – comply with prescription and healthcare regulations.
• Gambling operators – face per-MCC approvals and highest restrictions.
• Cryptocurrency businesses – undergo Tier 2 annual reviews and additional oversight.

What Are the Key Compliance Obligations Under VIRP?

The key compliance obligations under VIRP include:

• Maintaining active content moderation for user-generated material.
• Responding to complaints within 7 days.
• Submitting monthly compliance reports on violations and fixes.
• Implementing robust age-verification tools for restricted content.
• Enforcing clear takedown procedures for user reports.

How Does the VIRP Influence Merchant Account Approval and Monitoring? The VIRP influences merchant account approval through mandatory pre-approval assessments and explicit Visa authorization requirements. Acquirers must receive Visa approval for each Tier 1 merchant category before onboarding. Enhanced due diligence extends throughout the entire merchant relationship, not just initial approval.   Control assessments verify compliance before Tier 1 and Tier 2 merchant activation. An EU bank audit failure resulted in complete portfolio re-underwriting and numerous account terminations. This demonstrates how VIRP failures cascade through existing merchant relationships, affecting account stability beyond initial approval stages.

What Are the Requirements and Standards Under the VIRP?

The requirements and standards under the VIRP are outlined in Visa’s Acceptance Risk Standards document from October 2024. Acquirers must implement real-time monitoring systems to detect suspicious activities by 2025.    Merchants need robust policies for content moderation, age verification, and consent documentation. The infrastructure must support long-term controls ensuring continuous compliance with VIRP standards.

Which Documents and Policies Are Necessary for VIRP Compliance?

The documents and policies necessary for VIRP compliance include content moderation policies with clear guidelines and enforcement procedures. Age verification documentation and consent verification systems form essential compliance components. Merchants must maintain takedown process documentation accessible to users. Monthly compliance reports tracking violations and remediation efforts demonstrate ongoing adherence to VIRP requirements.

How Frequently Are Merchants Evaluated Under the VIRP?

Merchants are evaluated under the VIRP based on their tier classification. Tier 1 merchants face ongoing monitoring and per-MCC assessments. Tier 2 merchants undergo annual review cycles. Tier 3 merchants receive evaluations upon Visa’s request. Regular audits occur without advance notice across all merchant tiers.

What Are Common Reasons for VIRP Violations?

The Common reasons for VIRP violations include:

• Inadequate content moderation allowing illegal material.
• Lack of age-verification systems.
• Processing prohibited transactions.
• Falsifying or altering merchant details to evade registration.
• Missing 7-day complaint response or delayed removals.

What Are the Consequences of Non-Compliance With VIRP?

The consequences of non-compliance with VIRP are financial penalties starting at $2,000 monthly for unregistered merchants and reaching $400,000 for severe violations. Non-compliant merchants face several consequences:

• Account termination by their acquiring bank.
• Inclusion in the Terminated Merchant File (TMF) preventing future onboarding.
• Permanent loss of Visa processing capabilities across all relationships.

 

What Fines or Penalties Can Be Imposed on Non-Compliant Merchants?

The fines or penalties imposed on non-compliant merchants are structured by violation type. Unregistered HIR merchants incur $2,000 monthly penalties. Merchants altering details to evade VIRP face $25,000 fines per affected account.    Child Sexual Abuse Material violations trigger maximum penalties of $400,000. Transaction fees add US $0.10 per transaction plus 10 basis points in the United States, while EU and UK merchants pay €0.02 plus 10 basis points.

How Can Non-Compliance Affect a Merchant’s Processing Capabilities?

Non-compliance affects a merchant’s processing capabilities through immediate account termination after failed audits. Visa adds terminated merchants to the Terminated Merchant File, preventing future merchant account approvals. Merchants lose Visa transaction processing across all acquiring relationships permanently.    Payment processors avoid partnerships with TMF-listed businesses, eliminating access to card payment networks. The combination of TMF listing and processor blacklisting effectively ends a merchant’s ability to accept card payments globally.

Is There an Appeals Process or Remediation Path for Violations?

There is an appeals process providing short timeframes for audit response and remediation actions. Acquirers may re-underwrite portfolios to meet compliance standards after violations. Merchants must demonstrate corrective actions through enhanced controls and documentation.    Visa offers no guaranteed reinstatement after serious violations, particularly CSAM incidents. The remediation path requires merchants to implement missing controls, provide compliance documentation, and sustain improvements through monitoring periods before potential reinstatement consideration.

How Can High-Risk Merchants Stay Compliant With the VIRP?

High-risk merchants stay compliant with VIRP through proactive investment in risk management technologies and specialized payment processor partnerships. Compliance requires regular internal audits, fraud filtering systems, and chargeback prevention tools.    Partnership with processors like 2Accept provides expertise in navigating VIRP’s three-tier classification system. The following practices ensure merchants maintain processing capabilities while avoiding penalties ranging from $2,000 monthly to $400,000.

What Best Practices Should Merchants Follow to Avoid VIRP Issues?

The best practices merchants should follow to avoid VIRP issues are documentation maintenance, automated compliance systems, and prevention tool implementation. Merchants must maintain comprehensive documentation proving VIRP compliance across all requirements. Automated content moderation systems screen user-generated content in real-time. Age verification technologies confirm user eligibility for restricted services.   Clear user terms establish complaint handling procedures meeting the 7-day response window. Chargeback prevention tools maintain transaction disputes below Visa’s thresholds, such as 0.9% for standard merchants. According to a 2024 Visa Acceptance Risk Standards update, merchants processing over 300 monthly transactions face enhanced monitoring requirements.

Are There Tools or Resources Available for VIRP Compliance?

The tools and resources available for VIRP compliance are:

1. payment processor guidance
2. fraud management systems
3. specialized technology solutions. 

Payment processors provide audit preparation expertise and ongoing compliance monitoring.    Advanced fraud filtering systems detect suspicious transactions before processing completion.   Age verification solutions include document scanning, database checks, and biometric authentication. Real-time transaction monitoring platforms flag anomalies requiring review. Content moderation APIs scan text, images, and videos for prohibited material.    Integration tools connect these systems to merchant platforms for seamless compliance reporting. A 2023 industry survey found merchants using automated compliance tools reduced VIRP violations by 67%.

How Can Staff Be Effectively Trained on VIRP Requirements?

Staff can be effectively trained on VIRP requirements through regular education sessions, clear procedures, and defined responsibilities.   Effective staff training should cover:

• VIRP rule education and regulatory updates
• Complaint handling and 7-day protocols
• Content moderation techniques for illegal material
• Monthly reporting and documentation processes
• Role-specific compliance responsibilities

Training programs cover evolving VIRP rules, documentation standards, and violation consequences. Monthly sessions update teams on regulatory changes and industry best practices.   Complaint handling procedures specify 7-day response protocols and escalation paths. Content moderation training teaches illegal content identification across categories including CSAM, drugs, and counterfeit goods.    Staff learn monthly compliance reporting processes, including data collection, violation tracking, and remediation documentation. Role-specific training ensures each team member understands their compliance responsibilities within the VIRP framework.

What Steps Should You Take If You Are Flagged by the VIRP?

If flagged by the VIRP, follow these steps:

1. Review the assessment report for compliance gaps.
2. Engage your payment processor for remediation support.
3. Document all corrective actions thoroughly.
4. Implement enhanced monitoring systems.
5. Submit evidence of compliance within Visa’s timeline.

How Are Merchants Notified of VIRP Flagging?

Merchants receive VIRP flagging notifications through their acquiring bank or payment processor. The notification includes formal assessment documentation detailing specific violations found during Visa’s review. Visa provides explicit timelines for required remediation actions, typically ranging from 30 to 90 days depending on violation severity.    Follow-up audit scheduling appears in the notification to verify compliance improvements. The assessment documentation serves as the roadmap for necessary corrective measures.

What Actions Can Merchants Take to Rectify a VIRP Flag?

To rectify a VIRP flag, merchants should:

• Implement all missing controls.
• Provide proof of remediation (updated policies, screenshots, process docs).
• Work with third-party specialists to validate compliance.
• Maintain continuous monitoring through the evaluation period.

Engaging third-party compliance specialists adds credibility to validation efforts. Sustained compliance demonstration over the monitoring period proves the permanence of improvements. Success depends on addressing every violation point systematically within Visa’s specified timeframe.

How Long Does VIRP Monitoring or Restriction Typically Last?

VIRP monitoring duration varies based on violation severity and merchant tier classification. Initial monitoring periods range from 3 to 12 months for first-time violations. Tier 2 merchants face annual reviews indefinitely under current VIRP requirements.    Tier 1 merchants undergo ongoing per-MCC assessments without predetermined end dates. Serious violations involving illegal content or repeated non-compliance may result in permanent restrictions from the Visa network.

How Should You Approach the Visa Integrity Risk Program With a Payment Solutions Provider?

Payment solutions providers specializing in high-risk merchant services offer critical support for VIRP compliance. Companies like 2Accept, Segpay, PaymentCloud, and Signature Payments provide specialized expertise that standard processors lack.    These providers maintain compliance teams familiar with VIRP’s evolving requirements and offer technology integrations essential for meeting 2025’s real-time monitoring mandates. Multiple acquiring relationships through specialized providers create redundancy protection against account termination risks.

Can 2Accept Help High-Risk Merchants Navigate VIRP Compliance?

2Accept helps high-risk merchants navigate VIRP compliance through comprehensive support services and technology solutions. The company provides access to multiple acquiring banks, creating redundancy that protects against single-point failures during VIRP audits.    2Accept’s compliance team offers legal guidance specifically tailored for high-risk industries such as adult content (MCC 5967), online gambling (MCC 7995), and cryptocurrency businesses (MCC 6051).   Documentation and audit preparation constitute core 2Accept services. The provider assists merchants in establishing content moderation policies, implementing age verification systems, and creating takedown procedures that meet VIRP’s 7-day response requirements.    2Accept’s technology solutions include fraud filtering systems that help merchants stay below Visa’s chargeback thresholds and automated compliance reporting tools for monthly submission requirements.   The platform integrates chargeback management systems that track dispute ratios and prevent threshold violations. These tools become essential as merchants face potential penalties ranging from $2,000 monthly fees to $400,000 for severe violations.

What Are the Key Takeaways About the Visa Integrity Risk Program (VIRP) for High-Risk Merchants?

The key takeaways about VIRP for high-risk merchants center on understanding its comprehensive impact on payment processing operations. VIRP represents a fundamental shift in payment ecosystem risk management that replaced the Global Brand Protection Program in May 2023. The program’s three-tier classification system determines specific compliance requirements, with Tier 1 merchants facing per-MCC assessments and Tier 2 merchants undergoing annual reviews.   Financial penalties create substantial risk exposure for non-compliant merchants. Violations trigger fines from $2,000 monthly for unregistered HIR merchants to $400,000 for Child Sexual Abuse Material infractions. Transaction fees add US $0.10 per transaction plus 10 basis points in the United States, or €0.02 plus 10 basis points in EU/UK markets.   Success under VIRP requires three critical elements: proactive compliance investment, advanced technology implementation, and strong payment processor partnerships. Merchants must maintain real-time monitoring systems by 2025, implement robust content moderation policies, and establish clear complaint handling procedures within 7-day response windows.    Partnership with specialized providers like 2Accept becomes essential for accessing compliance expertise, maintaining multiple acquiring relationships, and implementing required technology solutions that ensure long-term VIRP compliance.