Dispute Condition 10.5: When Visa Files the Chargeback
Condition 10.5 is triggered by Visa, not your customer. There are no invalid disputes, no compelling evidence, and it can be filed twice.
By Jeffrey Anderson
- Condition 10.5 is triggered by Visa notifying the issuer that a transaction was identified by the Visa Fraud Monitoring Program. The cardholder's position is not part of the dispute reason.
- The invalid disputes table for this condition lists None. There is no scenario the rules recognise as making a 10.5 dispute invalid.
- Pre-arbitration permits exactly two arguments: an unaddressed credit or reversal, or that the dispute is invalid. Compelling evidence, delivery proof and AVS matches are all outside the list.
- The 120 calendar day clock runs from the date of the monitoring report, not the transaction, and merchants have no visibility of when that report is generated.
- It is the only condition carved out of the rule that an issuer must not dispute the same transaction more than once.
- The only real control is upstream. Keep transactions out of fraud monitoring reports, and keep refund records clean enough to prove an unaddressed credit.
Dispute condition 10.5 is the one nobody warns you about. Every other chargeback starts with a cardholder claiming something. This one starts with Visa telling the issuer to file it.
It sits in section 11.7.6 of the Visa Core Rules and Visa Product and Service Rules (18 April 2026), and reading the four short subsections back to back is genuinely startling. The merits of the transaction never come up. Not once.
The Trigger Is Visa, Not Your Customer
The dispute reason reads in full: Visa notified the issuer that the transaction was identified by the Visa Fraud Monitoring Program, and the issuer has not successfully disputed the transaction under another dispute condition (ID# 0030258).
That's the whole test. There's no requirement that the cardholder complained, no requirement that they deny the purchase, and no requirement that anything went wrong at your end. A transaction gets caught in a monitoring report, and a chargeback follows.
The second half matters too. It applies where the issuer hasn't already won under another condition, which makes 10.5 a fallback. If the ordinary fraud route didn't work, this one is still available.
There Are No Invalid Disputes
Here's the part that stopped me.
Every dispute condition in the rulebook has an "Invalid Disputes" table listing the circumstances where the issuer isn't entitled to file. Condition 13.8 excludes mobile push payments. Condition 11.1 excludes ATM disbursements, contactless-only devices and EMV liability shift transactions. They all have a list.
For 10.5, the table has one entry, and the entry is None (ID# 0030626).
There is no scenario the rules recognise as making a 10.5 dispute invalid. That isn't an oversight in how the table was written. It's the rule.
The Clock Runs From The Report, Not The Sale
The time limit is 120 calendar days from the date of the Visa Fraud Monitoring Program report (ID# 0030259).
Read that against a normal dispute window, which runs from the transaction or the delivery date. Here the clock starts when a report is generated, and you have no visibility of when that happens. A transaction from months ago can produce a fresh 120 day window the moment it appears in a report you never see.
Your Pre-Arbitration Options Are Two, And Neither Is The Merits
When an acquirer attempts pre-arbitration on a 10.5, the rules permit evidence of either of the following, and nothing else (ID# 0030260):
- A credit or reversal issued by the merchant was not addressed by the issuer in the dispute
- The dispute is invalid
That's the complete list. Compare it to what you can submit against ordinary card-absent fraud, where compelling evidence covers AVS matches, delivery records, device identifiers, transaction history and more.
None of that applies here. Proof of delivery is irrelevant. An AVS match is irrelevant. A signed order form is irrelevant. The customer having used your service for a year is irrelevant.
And look at the second permitted argument next to the previous section. You may argue the dispute is invalid, and the rules say no 10.5 dispute is invalid. In practice you have one real defence: you already refunded, and the issuer didn't account for it.
It's The Only Condition That Can Be Filed Twice
One more carve-out, in the general dispute rules rather than the 10.5 section, which is probably why it gets missed.
Section 11.2.1 states that an issuer must not initiate a dispute for the same transaction more than once, "except for a Dispute initiated under Dispute condition 10.5 (Visa Fraud Monitoring Program)" (ID# 0030209).
Every other condition is once per transaction. This one isn't. A transaction already disputed and resolved can come back under 10.5.
What This Actually Means For You
Put the four rules together and the shape is clear. This isn't a dispute you defend. It's a consequence of being in a monitoring report.
Which means the work happens upstream, not at the dispute desk. Anything that keeps your transactions out of fraud monitoring reports in the first place is the real control: screening quality, dispute ratio management, and understanding the monitoring programs themselves.
Two practical habits follow.
Reconcile your refunds carefully. Your single viable pre-arbitration argument is an unaddressed credit, so a clean, timestamped record of every refund is the only ammunition the rules give you. If your refund records are messy, you have nothing.
And treat a cluster of 10.5s as a signal about your portfolio rather than a run of bad luck. They mean transactions of yours are appearing in reports. That is worth a conversation with your acquirer immediately, because the chargebacks themselves are the least of what follows.
Frequently Asked Questions
Does the cardholder have to claim fraud for a 10.5 dispute?
No. The trigger is Visa notifying the issuer that the transaction was identified by the Visa Fraud Monitoring Program. The cardholder's position is not part of the dispute reason.
Can I submit compelling evidence against a 10.5?
No. The pre-arbitration requirements permit only two things: evidence that a credit or reversal you issued wasn't addressed by the issuer, or that the dispute is invalid.
What makes a 10.5 dispute invalid?
Nothing. The invalid disputes table for this condition lists "None", which is unusual across the rulebook.
How long does the issuer have?
120 calendar days from the date of the Visa Fraud Monitoring Program report, not from the transaction date. You have no visibility of when that report is generated.
Can the same transaction be disputed twice under 10.5?
Yes. It's the only condition carved out of the rule that an issuer must not dispute the same transaction more than once.
So how do I actually defend against these?
Mostly you don't, at the dispute stage. The control is upstream: keep your transactions out of fraud monitoring reports, and keep refund records clean enough to prove an unaddressed credit if one exists.
Seeing 10.5 disputes and want to understand what's putting your transactions in those reports? Apply free or talk to a specialist, and see how we approach chargeback defense.
Jeffrey Anderson, Merchant Placement Specialist
Merchant placement specialist at Gray Merchants. Jeffrey works directly with acquiring-bank underwriting teams across the firm’s 70+ banking relationships to place high-risk and hard-to-place businesses, structure multi-MID accounts, and keep flagged merchants processing. His writing draws on the placement files he works every week: what underwriters ask for, why accounts get declined, and what keeps an approved account open.