Visa reason code 11.1: Card Recovery Bulletin and how to respond
Visa code 11.1 covers a below-floor-limit sale made without authorization while the account was on the Card Recovery Bulletin. See defenses and deadlines.
What Visa reason code 11.1 means and when it applies
Visa reason code 11.1, “Card Recovery Bulletin (CRB)Visa’s regional bulletin listing account numbers subject to recovery. For 11.1, the relevant bulletin is the one for the merchant outlet’s region on the date specified by the rule.,” applies to a sale completed without authorization while the account was listed in that bulletin. The issuer may file this dispute only when all three of these requirements are met:
- The sale was below the merchant’s Floor LimitThe amount above which a sale requires an authorization request. For 11.1, the transaction must be below this limit..
- The merchant did not obtain authorization. The sale was completed without an approval response for that transaction.
- The account was on the CRB. On the Transaction Date, the account number appeared in the bulletin for the Visa Region where the merchant outlet was located.
These three requirements are cumulative. If any one is missing, the situation does not qualify for 11.1. An authorization obtained for the sale or proof that the account was not on the bulletin on the correct date therefore defeats the condition without requiring a second form of proof.
Two additional rules complete this test. If Visa blocked a group of accounts in the CRB under the same prefix, the code may apply even when the specific account number does not appear individually. If the Transaction Date was not submitted in the Clearing RecordThe record the acquirer submits after the purchase to present the transaction to Visa and calculate settlement between participants., the account must have appeared in the CRB at some point during the 10 calendar days before the Transaction Processing DateThe date Visa processes the transaction. It starts the issuer’s 75-day filing window and, when the Transaction Date was not submitted, serves as the reference point for the prior 10 days..
Source for the three requirements and two additional rules: Visa Core Rules §11.8.1.1, Table 11-36 (ID# 0030261).
This wording applies to disputes processed through October 23, 2026, as stated in the headings of Tables 11-36 through 11-39. For disputes processed on or after October 24, 2026, confirm the current edition of the Visa rules before deciding whether the condition or a defense applies.
Effective-date source: Visa Core Rules §11.8.1, Tables 11-36 through 11-39 (ID# 0030261 through 0030264).
Deadlines for each party under Visa 11.1
1 block represents 5 calendar days.
- IssuerFile the 11.1 disputeThe clock starts when Visa processes the transaction.Up to 75 calendar days
- AcquirerSubmit a defense path allowed by VisaThe clock starts when Visa processes the dispute.Up to 30 calendar days
- IssuerRespond to the acquirer’s defenseThe clock starts when Visa processes the acquirer’s defense.Up to 30 calendar days
- AcquirerAsk Visa to decide the caseThe clock starts when Visa processes the issuer’s response.Up to 10 calendar days
Who files the dispute and what happens next
The issuer, the bank that issued the card, files the 11.1 dispute in VROLVisa Resolve Online is Visa’s system where the issuer files the dispute and the acquirer submits the response and case documents.. For Category 11, the issuer, rather than necessarily the cardholder, must have suffered the financial loss.
This code follows the Allocation flowThe flow in which Visa initially assigns financial responsibility to the acquirer. In Category 11, the defense begins with a Pre-Arbitration Attempt, with no separate representment step.. When the issuer files a valid dispute, financial responsibility initially moves to the acquirer, the institution that represents the merchant in the Visa card scheme. The merchant gives its records to the acquirer; it does not respond directly to Visa.
The issuer has 75 calendar days from the Transaction Processing Date to file an 11.1 dispute. The acquirer may then submit a Pre-Arbitration AttemptThe acquirer’s formal request for the issuer to reconsider the dispute before the case goes to Visa for a decision. within 30 calendar days of the Dispute Processing Date. The issuer has another 30 calendar days from the Processing Date of the attempt to respond. If that response does not resolve the case, the acquirer has 10 calendar days from the Processing Date of the response to ask Visa for Arbitration.
Source for the issuer’s financial loss: Visa Core Rules §1, ID# 0003287. Source for the flow and deadlines: Visa Core Rules §11.2.2, Table 11-1 (ID# 0030212), and §11.8.1.3, Table 11-38 (ID# 0030263).
Before building a defense, check whether this dispute is invalidProving any one condition is enough to challenge the dispute's validity.
- The transaction was an ATM Cash Disbursement.
- The transaction was a Mobile Push Payment.
- The transaction was completed at a Contactless-Only Acceptance Device — a dual-mode terminal with chip and contactless capabilities does not qualify.
- The transaction occurred at a Chip-Reading Device AND qualifies for the EMV liability shift (Core Rules §1.10.1.2) — both conditions must be met together.
Source:Visa Core Rules §11.8.1.2 — Invalid Disputes, Tabela 11-37, ID# 0030262
How to reduce the risk of Visa 11.1 disputes
The most direct way to prevent an 11.1 dispute is to request authorization before completing the sale. Without the failure to obtain authorization, one of the three required elements is missing.
When a transaction is below the merchant’s Floor Limit, Visa requires the merchant to check the appropriate CRB. Under the rule in effect through October 23, 2026, this check is not required when the transaction occurs at a Chip-Reading Device. Outside that exception, record which edition of the bulletin was checked, the date of the check, and the result linked to the sale.
Source for the requirement and its exception: Visa Core Rules §5.7.1.1, Merchant Requirement to Check the Card Recovery Bulletin (ID# 0003010). Merchant guidance source: Visa Dispute Management Guidelines for Visa Merchants, Condition 11.1, p. 26.
Also retain the authorization request and response, terminal data, and Clearing Record. If a credit or reversal was processed, retain the amount, date, and link to the original sale. These records do not replace prevention, but they allow the acquirer to determine quickly whether the dispute meets the rule and whether a valid defense exists.
Evidence the merchant and acquirer need to gather
In the Allocation flow, the merchant gives its documentation to the acquirer, which submits everything in a single Pre-Arbitration Attempt in VROL. There is no separate representment of the sale. Before gathering attachments, compare the case with the three filing requirements. If all three are present, the defense must follow at least one of these three paths:
- A credit or reversal the issuer did not address. All records are required: the amount, the processing date, and proof that the issuer did not account for the credit or reversal when it filed the dispute.
- The dispute is invalid. Proving any one of Visa’s listed situations is enough: an ATM Cash Disbursement; a Mobile Push PaymentA Visa transaction initiated by the cardholder on a phone or other mobile device to pay for goods or services or move funds.; a transaction completed at a Contactless-Only Acceptance DeviceA terminal that accepts payments only through contactless technology. A terminal that also reads chips is not in this category.; or a transaction that occurred at a Chip-Reading DeviceA payment terminal or other acceptance device capable of reading the card’s physical chip. and, at the same time, qualifies for the EMV liability shiftEMV is the technical standard for chip cards. The liability shift determines which party bears the loss when the transaction meets the standard’s conditions..
- The account was not on the CRB in a multi-authorization transaction. This path applies only to car rental, cruise, or lodging transactions with multiple authorizations. The merchant must prove every fact: the merchant type, the multiple authorizations, the applicable date, and the account’s absence from the CRB on that date. Use check-in for lodging, vehicle pickup for a car rental, and embarkation for a cruise.
Source for the three Pre-Arbitration paths and the logic between them: Visa Core Rules §11.8.1.4, Table 11-39 (ID# 0030264). Source for the four invalid-dispute situations: Visa Core Rules §11.8.1.2, Table 11-37 (ID# 0030262). Source for the credit or reversal amount and date: Visa Dispute Management Guidelines for Visa Merchants, Condition 11.1, p. 26.
For the two terminal-based defenses, ask the acquirer for the POS Entry ModeThe field in the transaction record that shows how the card data was captured, such as by chip or contactless technology. and the terminal capability codeThe field that tells Visa which technologies the terminal accepts. Here, it distinguishes a chip reader from a contactless-only terminal. in the Clearing Record. For the chip path, both facts in the rule are required: having a chip-capable terminal is not enough if the transaction does not qualify for the EMV liability shift. A purchase where the terminal tried to read the chip but completed using the magnetic stripe also does not satisfy this path by itself.
Source for the terminal documentation: Visa Dispute Management Guidelines for Visa Merchants, Condition 11.1, EMV-compliant-terminal response, p. 26. Source for the two cumulative conditions in the chip path: Visa Core Rules §11.8.1.2, Table 11-37 (ID# 0030262).
If none of the three paths is documented and the sale did meet the requirements for 11.1, Visa’s guidance is to accept the dispute. If the issuer declines a valid Pre-Arbitration Attempt, the acquirer may ask Visa for Arbitration within 10 calendar days of the Processing Date of the response.
Source for the instruction to accept the dispute: Visa Dispute Management Guidelines for Visa Merchants, Condition 11.1, p. 26. Arbitration deadline source: Visa Core Rules §11.2.2, Table 11-1 (ID# 0030212).
Frequently asked questions
When does Visa chargeback code 11.1 apply?
The code identifies the dispute condition "Card Recovery Bulletin." The issuer files this dispute when three facts occur together. The transaction was below the merchant’s Floor Limit, and the merchant did not obtain authorization. In addition, on the Transaction Date, the account number was listed in the Card Recovery Bulletin for the Visa Region where the merchant outlet was located.
When must a merchant check the Card Recovery Bulletin (CRB)?
The CRB is Visa’s regional bulletin listing account numbers subject to recovery. Under the rule in effect through October 23, 2026, the merchant must check the appropriate bulletin when the transaction is below its Floor Limit. The check is not required if the transaction occurs at a Chip-Reading Device.
How can the acquirer challenge an 11.1 chargeback?
Category 11 follows the Allocation flow, with no separate Dispute Response or representment step. The acquirer’s only defense is a Pre-Arbitration Attempt in VROL within 30 calendar days of the Dispute Processing Date. It is available only when one of the three grounds in Table 11-39 is documented.
When is an 11.1 dispute invalid?
Any one of four Visa exclusions is enough: an ATM Cash Disbursement; a Mobile Push Payment; a transaction completed at a Contactless-Only Acceptance Device; or a transaction that both occurred at a Chip-Reading Device and qualifies for the EMV liability shift. Outside this list, the conditions for 11.1 are also not met if any one of the three filing requirements is missing.
How long does the issuer have to file an 11.1 dispute?
75 calendar days from the Transaction Processing Date.
What should the merchant do when no permitted remedy applies?
Visa’s guidance is to accept the dispute when the transaction was not authorized, the CRB was not checked, and there is no documented basis for a Pre-Arbitration Attempt.
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