Background

Ezypay is a Payment Facilitator (PayFac) and Payment Service Provider (PSP), offering billing services on behalf of merchants to their customers.

We currently operate under two primary models:

• Merchant paid fees - where Ezypay charges the merchant a transaction fee based on processed payments.
• Customer paid fees - where Ezypay includes a service fee within the customer’s total payment.

In both models, customers enter into a direct agreement with Ezypay when signing up and providing their payment details, governed by Ezypay’s standard Terms and Conditions.

This memorandum outlines Ezypay’s current understanding of the reforms and the operational approach Ezypay intends to adopt in response. It should not be perceived as legal advice to merchants.

RBA Final Position (March 2026 Update)

On 31 March 2026, the Reserve Bank of Australia (RBA) released its Conclusions Paper following its Review of Merchant Card Payment Costs and Surcharging.

The Payments System Board has now confirmed a package of reforms aimed at improving efficiency, competition and transparency across the payments system.

Key Changes

• Removal of surcharging on debit, prepaid and credit cards across designated card networks (eftpos, Mastercard and Visa), effective 1 October 2026. American Express has indicated that it supports the RBA’s payments reform and will remove surcharging from 1 October 2026.
• Changes to interchange fee caps, including domestic interchange cap changes from 1 October 2026 and foreign card interchange cap changes from 1 April 2027.
• Increased transparency across card networks and payment providers.

Why This Change?

The RBA concluded that the current surcharging framework is no longer effective due to:

• Widespread use of surcharges across all card types.
• Increasing use of blended or flat surcharges regardless of actual cost.
• Reduced use of cash.
• Increased customer confusion and frustration.
• Limited ability for consumers to avoid fees.

Timing of Changes

• 1 October 2026 - removal of card surcharging and domestic interchange cap changes.
• 1 April 2027 - foreign card interchange caps and additional transparency measures.

What This Means for Ezypay

Ezypay has reviewed the impact of the reforms against our current fee models and the way card fees are presented to customers.

The reforms are focused on the customer experience of card charges. Ezypay has considered how the reforms may apply to customer-facing charges associated with card payments.

As a result, Ezypay will update its approach for card payments from 1 October 2026.

This means:

• Based on Ezypay’s current assessment of the reforms, customer paid fees that apply specifically to card transactions will need to be transitioned before 1 October 2026.
• This does not apply to customer paid load fees or failed payment fees that are not card-specific surcharges.
• Impacted card transaction fees will need to move to a merchant paid model.
• Merchants currently using customer paid card fees should begin planning for this transition now.
• Bank payment methods, including Direct Debit and PayTo, are not impacted by these card surcharging reforms.

This is a shift in how card payment costs are recovered and presented. It does not change Ezypay’s ability to support flexible pricing structures for merchants, but it does mean that separate customer paid card transaction charges will not continue after 1 October 2026.

What Merchants Should Know

While these changes do not take effect until October 2026, the direction is now clear.

Merchants should review their current pricing structure and identify whether customers are charged a separate fee when paying by card. If so, those card fees will need to be transitioned away from a customer paid model before 1 October 2026.

Our Recommendation

We recommend merchants:

• Seek their own independent advice regarding the impact of the reforms on their business.
• Review current pricing structures.
• Identify any customer paid fees that apply specifically to card payments.
• Plan to transition impacted card fees away from a customer paid card model before 1 October 2026.
• Consider whether broader membership, subscription or product pricing should be adjusted to recover payment costs in a more transparent way.
• Align any pricing updates with broader membership or product pricing changes where possible.
• Consider how bank payment options, including Direct Debit and PayTo, can support overall payment cost management.

Interchange Fees - What to Expect

The RBA has confirmed changes to interchange fee caps, with some reducing while others remain unchanged.

While this may reduce some underlying card acceptance costs over time, the overall impact will depend on the mix of card types being processed and the broader cost components within card pricing.

It is important to note:

• Interchange is only one component of total transaction costs.
• Other costs, including scheme fees, fraud, risk and infrastructure, remain significant.
• Merchants should not assume that interchange movements will fully offset the cost of removing separate customer paid card fees.

Ezypay will continue to monitor the impact of these changes on overall pricing.

Final Thoughts

The direction of the market is now clear.

While there is still time before these changes take effect, this is the right moment to start planning.

For Ezypay merchants, this means reviewing any customer paid card transaction charges and moving impacted card fees away from a separate customer paid card model before 1 October 2026.

Whether it is reviewing pricing, adjusting fee structures, or considering broader pricing changes, Ezypay will support merchants through the transition.

Bottom line: Card surcharging on designated card schemes will be prohibited from 1 October 2026, and separate customer paid card transaction charges will not continue after 1 October 2026. Pricing strategy will matter more than payment strategy.

Jane Theunissen
​Chief Operating Officer
​Ezypay

Note: This memorandum is provided for general information purposes only and does not constitute legal, tax or financial advice. Merchants should seek their own independent advice regarding the impact of the reforms on their business.