Refund Policy Disclosure: The Rule That Wins Disputes
A footer link to your refund policy is not a compliant disclosure, and the disclosure is the evidence you submit to defend a cancellation dispute.
By Jeffrey Anderson
- The rule only triggers where a merchant restricts the return of goods or cancellation of services. Any window, deadline, restocking fee or non-refundable deposit counts as a restriction.
- For ecommerce the disclosure must appear during the sequence of pages before final checkout and carry a click to accept button, checkbox or other acknowledgement. A footer link is not compliant.
- A link may satisfy the rule only if it forms part of the acknowledgement itself and refers to the return, refund or cancellation policy.
- For card-present, the policy may sit on the front of the receipt, but only with a space for the cardholder to indicate acceptance.
- Under dispute condition 13.7 your response evidence is proof you properly disclosed the policy and the cardholder did not cancel according to it. A non-compliant disclosure removes the defence.
- A merchant must not require a cardholder to waive the right to dispute a transaction with the issuer, so no-chargeback clauses do not work.
Refund policy disclosure is usually treated as a legal checkbox. It isn't. Under Visa's rules the disclosure is the evidence you hand over to defend a cancellation dispute, and if you got the format wrong there's nothing to submit.
A link in your site footer does not satisfy the rule. Section 5.4.2.5 of the Visa Core Rules and Visa Product and Service Rules (18 April 2026) is specific about where the disclosure has to appear and what the customer has to do with it.
The Rule Only Applies If You Restrict Something
Worth being precise about the trigger, because it's narrower than people assume.
The obligation reads: if a merchant restricts the return of goods or cancellation of services, it must clearly disclose its return, refund, and cancellation policies (ID# 0008771).
So a merchant with genuinely unrestricted returns has nothing to disclose under this rule. The moment you add a condition, a window, a restocking fee, a non-refundable deposit, or a cancellation deadline, you're restricting, and the format requirements below apply.
What Counts, By Channel
The rules set a different mechanism for each acceptance environment.
| Channel | What the rules require |
|---|---|
| Card-present | At the point of transaction before the cardholder completes it, or on the front of the receipt. If it's on the receipt or a separate contract, it must come with a space for the cardholder to indicate acceptance |
| Ecommerce | During the sequence of pages before final checkout, with a click to accept button, checkbox, or other acknowledgement |
| Card-absent but not ecommerce | Through mail, email, or text message |
| Agentic | Per section 4.1.24.6, covering an agentic payment provider accepting a policy on the cardholder's behalf |
Notice what the card-present branch does. Putting the policy on the receipt is allowed, but only if there's somewhere for the customer to signal they accepted it. A policy printed on the back of a receipt with no acknowledgement isn't a compliant disclosure.
The Ecommerce Requirement Most Sites Fail
This is the one worth checking on your own checkout today.
The disclosure has to appear during the sequence of pages before final checkout, and it has to carry a click to accept button, a checkbox, or another acknowledgement. The rules do allow it to be a link to a separate page, but only "if that link forms part of the 'click to accept' acknowledgement and refers to the return, refund, or cancellation policy."
Read that condition carefully. The link has to be part of the acknowledgement itself. A footer link on every page, a policy page in your navigation, or terms buried in an account signup flow from six months ago are all outside what the rule describes.
The common compliant pattern is a checkbox at checkout whose label contains the link. The common non-compliant pattern is a beautifully written policy page nobody was ever asked to agree to.
This Is Really a Dispute Rule
Here's why the format matters more than it looks.
When a cardholder disputes under condition 13.7, cancelled merchandise or services, the documentation you're allowed to submit in response includes the transaction receipt "or other record to prove that the Merchant properly disclosed a limited return or cancellation policy at the time of the Transaction, as specified in Section 5.4.2.5", and evidence "to demonstrate that the Cardholder received the Merchant's cancellation or return policy and did not cancel according to the disclosed policy" (ID# 0030354).
The dispute rule points straight back at the disclosure rule. Your defence is that you disclosed properly and they didn't follow the policy. If the disclosure wasn't in the right place, in the right format, with an acknowledgement, then the first half of that defence is missing and the second half doesn't matter.
That's the practical case for fixing this. It isn't compliance for its own sake. It's the difference between having a representment case and not having one.
Guaranteed Reservations Carry More
If you take guaranteed reservations, the same section adds requirements on top.
You must disclose the date and time the stay or rental begins and where it will be provided. You must agree to hold the reservation unless it's cancelled per the agreed policy. That policy has to state the date and time by which the cardholder must cancel to avoid a penalty, and the amount payable if they don't cancel by the deadline and don't claim within 24 hours of the agreed time.
And if you can't honour the reservation, you have to provide the agreed accommodation, merchandise or services, or comparable ones, at no additional cost to the cardholder unless they agree otherwise.
You Cannot Make Someone Waive A Dispute
The section closes with a sentence worth quoting on its own.
"A Merchant must not require a Cardholder to waive the right to dispute a Transaction, including an Agentic Transaction, with the Issuer."
That rules out a familiar class of terms. All sales final with no right of chargeback, agreements not to initiate disputes, arbitration clauses drafted to cover card network disputes. You can restrict refunds. You cannot contract away the cardholder's dispute rights with their issuer, and a term that tries to isn't going to help you when the dispute arrives.
What To Fix This Week
Three checks, none of which take long.
Open your own checkout as a customer and look for the acknowledgement. If there's no checkbox or click to accept step covering the refund policy before final checkout, that's the gap.
If you take card-present payments and rely on the receipt, check there's a place for the customer to sign or otherwise indicate acceptance.
Read your terms for anything that purports to remove the right to dispute, and delete it. It's unenforceable against the rules and it signals to an underwriter that nobody has read the rulebook.
Frequently Asked Questions
Do I need this if I offer unrestricted refunds?
The rule is triggered where a merchant restricts the return of goods or cancellation of services. With genuinely no restrictions there is nothing to disclose under it, though most merchants restrict something.
Can I put the policy on the receipt?
For card-present transactions, yes, on the front of the receipt. But if the disclosure sits on the receipt or in a separate contract, it must be accompanied by a space for the cardholder to indicate acceptance.
What about phone and mail orders?
For card-absent transactions that aren't ecommerce, disclosure goes through mail, email, or text message.
Why does the format matter so much?
Because under dispute condition 13.7 your response evidence is proof that you properly disclosed the policy and that the cardholder didn't cancel according to it. A non-compliant disclosure removes your defence.
Can I include a no-chargeback clause in my terms?
No. The rules say a merchant must not require a cardholder to waive the right to dispute a transaction with the issuer.
Want your checkout flow and terms checked against what the rules actually require before a dispute tests them? 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.