CIT/MIT Compliance Framework guide
This page explains how you can become compliant with the Stored Credential Framework.
CIT/MIT Compliance for Australia and NZ Partners
The Stored Credential Frameworks by Visa, introduces a number of policies and procedures relating to the processing of stored customer credit/debit card information that were previously not required, in an attempt to reduce fraud and improve customer experience and trust. Both merchants and payment facilitators are obligated to adhere to this framework as a way to enforce responsible usage of cardholder data. The same requirements apply for all card types, such as Visa, Mastercard and AMEX.
This framework has already been rolled out globally, and will eventually become mandatory for all merchants and payment facilitators. Further information on the framework can be found in this document from Visa: Visa Stored Credential Framework
Framework Summary
One of the key points of this framework is the differentiation of these two ways that a transaction on a stored card can be triggered:
Customer Initiated Transaction (CIT) - this is a payment on a stored card that has been actively triggered by your customer themselves (i.e. it involves the active participation of the cardholder).
Merchant Initiated Transaction (MIT) - this is a payment on a stored card that you as the business have initiated yourself as part of collecting money based upon a pre-agreed contract between your business and the cardholder as part of whatever product or service you are providing them.
In practice, the framework requires doing the following:
Specifying whether you are processing a CIT or MIT.
Specifying the type of authorization you are performing.
Linking all subsequent payments on a stored card using an authorization reference.
Compliance Requirements
There are two critical parts to ensuring compliance with the Stored Credentials Framework:
1. Data Element Configuration
Ensuring all the relevant Data Elements relating to tagging a transaction as a Customer initiated transaction or a Merchant initiated transaction should be properly set.
The first step is to audit all your transaction flows and correctly tag each as a Customer Initiated or Merchant Initiated Transaction. If the first transaction isn't tagged correctly, all the associated recurring transactions will create a chain of non-compliant transactions.
A simpler way to think about it: If a customer is actively participating in the transaction in real-time, that's a Customer Initiated Transaction. Even when using a saved card, if the customer is actively making the purchase, it's still considered a CIT.
2. Specific Data Elements Required for Visa and Mastercard
For Initial Transactions (Both Visa and Mastercard):
Credential On File (COF) Indicator
Cardholder Authentication
Consent Verification
For Subsequent Transactions:
Credential On File (COF) Indicator
Transaction Identifier
a. For Visa: Network Transaction ID (NTI)
b. For Mastercard: Mastercard Trace ID
Transaction Type: Specify the type (RECURRING, INSTALMENT, UNSCHEDULED)
Impacted REST API endpoints
We have built out CIT/MIT compliance on our side for REST API, electronic Direct Debit Request (eDDR) and the Hosted Payment Page (HPP) to assist you in becoming compliant and have highlighted the specific REST API function that require amendment or a change to a different API flow due to depreciation.
POST - Add or update a Payers card details via token - (Depreciation)
superseded with POST Generate HPP Token
Next Steps
If you are integrated using the REST API, eDDR or HPP, then the following pages will direct you in the small technical uplift required to become CIT/MIT compliant.
If you are integrated using SOAP API, there is a higher portion of technical uplift required to become CIT/MIT compliant as your application will need to convert a few functions from SOAP to REST. The dedicated SOAP to REST API conversation developer guide is here below:
CIT / MIT - FAQ
Q: Do we have to re-authenticate all the existing cards?
A: At this stage, existing payers with card details stored are not affected and will not need to be re-authenticated. This is subject to change should card scheme mandate this requirement for existing payers and is not particularly in our control. If this does change, we will attempt to provide a solution that impacts the partner and account holders minimally.
Q: Do we have to create $0 transactions for all card updates?
A: For payment details that are updated moving forward, yes it will require the $0.00 (Zero-Dollar Authentication) to store new card details as part of the CIT/MIT compliance framework.
Q: Do partners need to implement CIT/MIT changes if they only create payer records and do not store card details?
A: No. Partners who only create payer or customer records (for purposes such as assigning payment references) and do not store any card details fall outside the scope of CIT/MIT requirements.