The Credit Card Competition Act: What It Would Change for Acquirers, and Why Nothing Changes Yet

The Credit Card Competition Act is back in the news. On 9 October 2026, PYMNTS, citing a Wall Street Journal report, said President Trump was again urging Congress to pass it, and that merchant lobbyists were meeting White House officials and trying to attach it to other legislation. Banks and payment-industry lobbyists who oppose it have been meeting White House officials and members of Congress too, the report said.

For people who run merchant onboarding, pricing and residuals, the useful questions are narrower than the politics. What does the bill actually say? How far is it from changing anything? And which parts of an acquirer's or ISO's business would it touch? This piece works from the bill text and the congressional record, as they stand on 10 October 2026.

Where the Bill Stands

The Senate bill is S. 3623, introduced on 13 January 2026 by Senator Roger Marshall with Senators Dick Durbin and Peter Welch as original cosponsors. It was referred to the Senate Banking Committee the same day. Senators Bernie Moreno, Cynthia Lummis and Angus King signed on as cosponsors on 7 August 2026. The House version, H.R. 7035, was introduced the same day by Representative Lance Gooden, with Representative Zoe Lofgren as a cosponsor, and was referred to the House Financial Services Committee. Congress's own record lists it as an identical bill.

Neither bill has moved past committee referral. The congressional record shows no hearing, markup or vote on either one. The closest it has come to a vote this year was in January, when Marshall filed a version as an amendment to the crypto market-structure bill in the Senate Agriculture Committee and then agreed not to offer it. Trade reports said White House officials were concerned that the amendment would complicate the crypto bill.

That is why supporters are now trying to attach the bill to another one. A January analysis by the law firm Kilpatrick Townsend named the National Defense Authorization Act and economic relief legislation as possible vehicles. Treat any such report as a sign of where the fight is, not as a timetable.

What the Bill Would Require

S. 3623 would amend section 921 of the Electronic Fund Transfer Act, codified at 15 U.S.C. 1693o-2. That is the Durbin Amendment, the section behind Regulation II for debit cards. The bill tells the Federal Reserve Board to write rules with three main parts.

• No exclusive network. A covered card issuer or a payment card network may not limit a covered issuer's credit card to one network. It may not limit it to two or more networks that are affiliated with each other or with the issuer, or to any network on a national-security list the Board must keep. And it may not limit it to only the two networks with the largest shares of US credit cards issued, as the Board measures them when it writes the rules. In practice, a covered card would need at least one network outside the top two.
• No routing restrictions. A covered issuer or network may not stop anyone who accepts credit cards from choosing which enabled network a transaction goes over. It may not penalize a merchant for that choice, or for failing to send a set number or dollar amount of transactions to a particular network.
• No locking in through security technology. A merchant may not be required to use an authentication, tokenization or other security technology for a card that the card's other networks cannot also use. A network may not stop another network from processing transactions with that kind of technology.

The routing rules cover card-not-present transactions explicitly. The bill defines an electronic credit transaction to include card details entered on a website or used in a mobile app, not only cards presented at a terminal.

Who Would Be Covered, and Who Would Not

The mandate applies to a covered card issuer, which the bill defines as an issuer that, with its affiliates, has more than $100 billion in assets. Community banks and most credit unions would not be covered. Marshall's January press release describes the bill as aimed at large banks with more than $100 billion in assets.

Cards issued in a three-party system are excluded entirely. The bill defines that as a card issued by the network itself, or by an issuer under common ownership with the network. American Express is the obvious example. Capital One is a less obvious one. Since it closed its acquisition of Discover on 18 May 2025, Capital One has owned both an issuing bank and a card network. Read literally, its cards on the Discover network would fall within the exclusion, while its Visa and Mastercard cards would not. Kilpatrick Townsend's analysis says the exclusion could give three-party systems a market advantage. How the Board would apply it is a question for its rulemaking.

There is also a sunset built into the rule about the top two networks. At least every three years, the Board must check whether the two largest networks have changed. If they have, the clause stops having any effect. The bill does not say what would replace it.

Enforcement would also look different. The bill amends the Act so that the Consumer Financial Protection Bureau has no authority to enforce section 921 or the Board's rules under it.

The Clock, If It Passes

Nothing changes on enactment day. The Board has one year from enactment to write the rules, and each set of rules takes effect 180 days after the Board finalizes it. Even if the Board met its deadline exactly, card behaviour would not change until about eighteen months after the bill became law. Issuers and networks would then have to put the second networks on the cards.

Debit routing shows how long that kind of change can take in practice. The Durbin Amendment passed in 2010, and Regulation II's two-network rule for debit cards took effect on 1 April 2012 for most cards. It took a second rulemaking, effective 1 July 2023, for the Board to make clear that the rule also covers card-not-present debit transactions. Our earlier piece on Regulation II covers where the debit rules stand now.

Where Acquirers and ISOs Fit

As drafted, the duties fall on covered issuers and on networks, not on acquirers. But acquirers appear in the text. Issuers and networks may not do the forbidden things directly or through any agent, processor or licensed member of a network. The bill defines a licensed member to include an acquirer, meaning any person authorized to screen and accept merchants, process their transactions and complete settlement. So network requirements that reach a merchant through its acquirer or processor agreement would be within the bill's reach.

If the bill passes, the practical effects for a merchant-services business would show up in a few places.

• Routing becomes a decision for credit as well as debit. Today a credit transaction goes to the network on the card. Under the bill, a covered issuer's card would carry at least two unaffiliated networks, and the merchant could choose between them. Someone would have to build and run that choice, whether in the processor's front end, the gateway or the merchant's own systems, much as merchants already choose between enabled networks for debit under Regulation II.
• Pricing models would determine who keeps the savings. On interchange-plus pricing, a cheaper network shows up in the pass-through. On flat-rate or tiered pricing, a lower cost may not reach the merchant unless the pricing is changed. Expect merchants who follow this issue to ask.
• Network incentive agreements would need review. The bill bars penalizing anyone for not sending a set number or dollar amount of transactions to a particular network. If your business or your processor has volume commitments with a network, read them alongside the bill text.
• Residuals and reporting would need network-level detail. If network mix can change on the same card, residual calculations and portfolio reporting that assume one network per card brand would need another dimension.

What to Do Now

Nothing in S. 3623 binds anyone today, so the right response is preparation rather than a project. Four things are worth doing now:

1. Find out how your processors handle debit routing today, including card-not-present debit. That is the closest working example of what credit routing would look like, and the answer tells you how ready your stack is.
2. Know your pricing book. Be able to say which merchants are on pass-through pricing and which are on flat-rate or tiered pricing, because that decides who would see any savings.
3. List any network incentive or volume agreements, whether yours or your processor's, that you would need to reread if the bill moved.
4. Watch for the bill to be attached to something else. Neither standalone bill has had a hearing. The risk is a late amendment to a must-pass bill, which leaves very little time to react.

If it does pass, there will be about eighteen months before any card changes, and much of the detail will depend on how the Board writes its rules. Teams that already understand their routing, pricing and network contracts will be in a better position when the Board asks for comments.