Inform
5 min read
The Transparency Playbook: How to Use the RBA's New Fee Disclosure Rules as a Procurement Tool
Sylvia Luchian
Founder & Head of Procurement Practice
From 1 October 2026, the rules around what your payment provider must tell you and what they must tell the public change materially. For the first time, Australian merchants will have access to standardised, publicly available data that makes genuine comparison of payment processing costs possible.
Most businesses will treat this as a compliance event. They will receive a new-format statement, file it with the others, and move on. The businesses that benefit from the October 2026 changes are the ones that treat the transparency data as a procurement tool, a structured basis for asking better questions, running a real market comparison, and negotiating from an informed position.
This blog is a practical guide to doing exactly that.
The October 2026 transparency requirements come from two separate chapters of the RBA's Conclusions Paper.1 Understanding what each one covers, and when it takes effect, is the starting point for using the data well.
The first set of changes, wholesale fee transparency, requires each designated card network to publish quarterly aggregate data on scheme fees, rebates, and interchange fees. This data will bebroken down by domestic and international transactions, debit and credit, and card-present versus card-not-present. Fees for mobile wallet transactions will be listed separately. Card networks must provide this data to the RBA, which will republish it on its website.
The second set of changes, acquiring services transparency, is the one with the most direct practical value for merchants.2 Large acquirers processing above $10 billion in card transactions annually must publish their merchant service fees on a quarterly basis. The RBA will republish this data on its website. Acquirers must provide merchants with additional information on their statements showing the relative costs of accepting domestic-issued versus foreign-issued cards, and card-present versus card-not-present transactions. Large acquirers must also publish a measure of interchange pass-through for four consecutive quarters following the October2026 interchange fee reductions.
A separate but related requirement mandates that card networks publish a Scheme Fee Roadmap by September 2026, detailing how they will simplify their fee schedules and improve billing practices.3
Key Takeaway: Two separate transparency streams take effect from October 2026: wholesale fee data from card networks, and merchant-facing fee data from acquirers. The most immediately useful is the acquirer data specifically the interchange pass-through measure and the itemised statement breakdown.
The absence of publicly available fee data is not an oversight. Interchange fee schedules have become more complex over time. The number of interchange categories has nearly doubled since 2020 and the rationale for that complexity is not always clear.4
Scheme fees have been even less transparent than interchange fees. Full scheme fee schedules are not publicly available and are only provided to participants in the card networks. Even sophisticated network participants with access to these documents find them difficult to interpret or use.5
At the acquirer level, pricing plans are complex and competitive offerings are typically negotiated confidentially at rates below what is advertised. Merchants cannot tell whether the rate they are receiving is comparable to what similar merchants are paying.6 The RBA found the existing public information on merchant service fees insufficient to promote competition and efficiency in the card payment system.7
The October 2026 requirements are designed to break that opacity. For the first time, a merchant who wants to understand whether their payment processing arrangement is competitive will have a public, standardised dataset to compare against. That is a genuinely new tool. The question is whether you use it.
Key Takeaway: The complexity of payment pricing was not accidental. The transparency requirements are designed to break a structure that systematically disadvantaged buyers who were not already paying close attention. Use the new data to close that gap.
The following steps are designed to be run insequence, starting before October 2026 and completing within the first quarterafter the new data becomes available.
Before the new transparency requirements take effect, request a written component breakdown from your current payment provider. Ask for the following specifically:
● The interchange fee component of your current merchantservice fee, by card type.
● The scheme fee component, by network.
● The acquirer margin, what your provider retains after paying interchange and scheme fees.
● Any non-payment services bundled into your currentrate, and their individual value if unbundled.
● Your current transaction profile: monthly volume,average transaction value, card-present versus card-not-present split, domesticversus foreign-issued card split.
If your provider cannot or will not provide this breakdown in writing, that is itself a data point. A provider who is unwilling to disclose how your fee is constructed before a regulatory requirement forces it is telling you something about the arrangement.
This step should be completed before October 2026 so you have a clear baseline to compare against the new public data.
From 30 October 2026, large acquirers must publish their merchant service fee schedules quarterly on their own websites, and the RBA will republish this information at rba.gov.au.8
When this data is available, compare it against what you are currently paying. The relevant comparison is not the headline advertised rate. It is the fee applicable to a merchant with your specific profile. Transaction volume, average transaction value, card mix, and channel split all affect the rate. The published data will give you an average across merchant categories. Use it to determine whether you are above, below, or at that average for a merchant of your size and type.
This comparison is not a final answer. It is the starting point for a more specific market test.
From 30 October 2026, large acquirers must publish a measure of interchange pass-through for four consecutive quarters following the October interchange fee reductions.9 The RBA will republish this data on its website. This is the mechanism specifically designed to identify acquirers that absorb interchange savings rather than passing them on to merchants.
For any merchant on a single-rate or blended plan, this data is particularly important. Interchange fee reductions benefit merchants automatically under interchange-plus pricing, where the interchange component passes through directly. Under single-rate pricing, the saving exist sat the wholesale level but the rate charged to the merchant does not change automatically. Whether the saving reaches you depends on whether your provider adjusts the rate and whether you notice if they do not.
Check the interchange pass-through data for your current provider in each of the four reporting quarters. If your provider is not passing through the savings within two quarters, that is your signal to move the conversation to renegotiation or market testing.
From October 2026, your merchant statement must include a breakdown showing the relative costs of domestic-issued versus foreign-issued transactions, and card-present versus card-not-present transactions.10 This breakdown is the specific transaction profile data you need to obtain an accurate competing quote.
Take that statement data to at least two alternative providers. Request a specific quote based on your actual transaction profile, not a generic rate. The profile data from your new statement makes this straightforward in a way it was not before. You now have standardised information that any provider can use to give you a directly comparable quote.
Run this process annually from October 2026. The market will not stay static. The transparency requirements create a new baseline, and staying on the right side of that baseline requires active use of the data, not passive receipt of it.
The purpose of Steps 1 through 4 is not necessarily to change providers. It is to establish whether your current arrangement is competitive and, if it is not, to create a basis for renegotiation. A provider who knows you have done a market comparison and found a better rate will respond differently to one who is confident you have not looked.
When negotiating, use the specific language the RBA's framework has introduced. Ask for interchange-plus or pass-through pricing where the interchange and scheme fee components are shown separately from the acquirer margin. Ask your provider to confirm in writing how they the October 2026 interchange fee reductions and at what point those reductions will appear in your rate. Ask whether your current plan type is optimal for your transaction profile and ask for the evidence.
Key Takeaway: The transparency data is not the outcome. It is the input to a negotiation. A provider who receives a merchant with a clear benchmark, a specific competing quote, and pointed questions about interchange pass-through will price very differently to one dealing with a merchant who has not looked.
Several steps in the playbook reference interchange-plus pricing. It is worth explaining the mechanics clearly, because the term is often used without enough precision to be actionable.
Under a blended or single-rate pricing model, you pay one percentage on every transaction regardless of card type, network, or whether the transaction is card-present or online. The rate bundles interchange fees, scheme fees, and the acquirer's margin into a single number. You cannot see the components. When interchange fees fall, you cannot verify whether your effective rate falls correspondingly.
Under interchange-plus pricing, also called pass-through pricing, your statement shows each cost component separately. Interchange fees, scheme fees, and the acquirer margin are listed as distinct line items. When interchange fee caps fall in October 2026, the change appears directly on your statement. You can verify the saving. You can confirm the acquirer margin has not been quietly increased to offset the interchange reduction.
Interchange-plus pricing is typically more cost-effective for businesses with a high proportion of lower-cost debit card transactions, or for businesses whose card mix varies significantly between customer segments. It is harder to understand at first, which is partly why single-rate plans became dominant. The benefit is that it makes overcharging visible and verifiable.
When negotiating your next payment processing agreement, specifying interchange-plus pricing is the single most effective way to ensure the October 2026 transparency benefits reach your business rather than stopping at the acquirer level.
Key Takeaway: Interchange-plus pricing makes the components of your merchant service fee visible and auditable. Under single-rate pricing, regulatory fee reductions may not reach you. Specify interchange-plus in your next agreement, or in your next renegotiation.
The playbook above is specific to payment processing. The underlying principle applies to any cost category where the pricing structure has historically obscured the components.
Transparency is a precondition for competitive discipline. You cannot compare what you cannot see. You cannot negotiate effectively on a cost category where the pricing structure makes genuine comparison impossible. The RBA's transparency requirements are an attempt to create, through regulation, the visibility that active buyers should have been demanding through their purchasing behaviour.
The practical question for any business owner is: in which of my cost categories am I operating without the pricing visibility that the RBA has now mandated for payment processing? Where are the equivalent blended rates, the bundled components, the confidential pricing arrangements that make market comparison genuinely difficult?
The published fee data is not a curiosity. It is a tender benchmark. Treat it as one.
Key Takeaway: From October 2026, Australian merchants have access to public benchmarks for payment processing that did not previously exist. The interchange pass-through data, the quarterly fee schedules, and the itemised statement breakdowns are procurement tools. They are only useful if someone in your business treats them that way. The playbook above converts regulatory compliance into commercial advantage. The businesses that benefit from the October 2026 changes will be the ones that were ready to use the data before it arrived, not the ones that noticed it six months later.
The transparency requirements taking effect from October 2026 are, in one sense, a gift from the regulator to merchants who have been operating without adequate pricing information for years. In another sense, they are the minimum standard that informed buyers should have been demanding all along.
The data arrives in October 2026 regardless of whether you are ready for it. The question is whether you treat its arrival as a prompt to review, or as another piece of paperwork to process.
If you would like help designing a payment processing review process based on the October 2026 data, including what to ask your provider, how to evaluate competing quotes, and what an interchange-plus agreement should look like for a business with your profile, D1 Advisory's cost reduction and commercial contract services cover this directly. A discovery call takes around 45 minutes. Book through the D1 Advisory website.
Reserve Bank of Australia 2026a, 'Transparency of Merchant Fees', Review of Merchant Card Payment Costs and Surcharging —Conclusions Paper, Reserve Bank of Australia, Sydney, March 2026, viewed 22 April 2026, <https://www.rba.gov.au/payments-and-infrastructure/review-of-retail-payments-regulation/2026-03/conclusions-paper/transparency-of-wholesale-fees.html>
Reserve Bank of Australia 2026b, 'Competition in Card Acquiring Services', Review of Merchant Card Payment Costs and Surcharging —Conclusions Paper, Reserve Bank of Australia, Sydney, March 2026, viewed 22 April 2026, <https://www.rba.gov.au/payments-and-infrastructure/review-of-retail-payments-regulation/2026-03/conclusions-paper/competition-in-card-acquiring-services.html>
Reserve Bank of Australia 2026c, 'Executive Summary', Review of Merchant Card Payment Costs and Surcharging — Conclusions Paper, Reserve Bank of Australia, Sydney, March 2026, viewed 22 April 2026,<https://www.rba.gov.au/payments-and-infrastructure/review-of-retail-payments-regulation/2026-03/conclusions-paper/executive-summary.html>
Reserve Bank of Australia 2026d, 'Impact and Implementation', Review of Merchant Card Payment Costs and Surcharging —Conclusions Paper, Reserve Bank of Australia, Sydney, March 2026, viewed 22 April 2026, <https://www.rba.gov.au/payments-and-infrastructure/review-of-retail-payments-regulation/2026-03/conclusions-paper/impact-and-implementation.html>
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