Card Surcharge Ban: Practice Billing in 2026
Review your practice’s invoices and payment settings under the card surcharge ban. See which card rules apply and how to explain revised charges.
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The card surcharge ban means your practice must remove separate fees for paying by card wherever the network’s no-surcharge rules apply. Review outstanding invoices as well as new bills, then check that the payment page and receipt show the agreed amount.
Which Card Rules Apply
The Reserve Bank of Australia (RBA) changed its framework so designated card networks can prohibit surcharging. eftpos, Mastercard and Visa have introduced those rules. The networks set the merchant requirements through their rules and payment arrangements.
American Express has also adopted a no-surcharge position through its own arrangements. It is outside the RBA’s designated-network framework. The RBA’s card surcharge FAQs give the precise commencement boundaries and explain exemptions.
A fee triggered by choosing a card is a card surcharge. A genuine charge that applies independently of payment method needs separate assessment under pricing law. Non-card payments have their own provider terms. The RBA does not regulate surcharges on those methods under this framework.
Business clients are covered too. Billing a company does not create an exemption. The designated networks’ business guidance covers commercial cards, online payments and cards stored in mobile wallets. Any exception must have a basis in the applicable rules, law or regulation.
Review Practice Invoices and Engagement Terms
Find every place your practice adds or promises a card-payment charge before changing the billing settings. Give one staff member responsibility for the review and access to the relevant payment accounts.
- Inspect a recent invoice, an unpaid invoice and a recurring bill template. Search for card fees in both line items and payment instructions.
- Open each payment link as a client would. Compare the amount requested before and after a card is selected.
- Read the fee clauses in your proposal and engagement letter templates. Remove wording that promises a surcharge your practice can no longer apply.
- Identify affected unpaid bills. Confirm the permitted amount with your payment provider, then send any correction to the client and retain both versions.
Payment timing matters. An invoice issued before the network’s rules commenced does not preserve a right to surcharge a later card payment. Apply the payment boundary in the RBA guidance when reviewing those bills.
Keep the agreed service fee distinct from the removed payment charge. Removing a surcharge does not authorise staff to increase an existing agreed fee. Record any separately agreed fee change through the practice’s normal approval procedure.
For new clients, put the accepted payment methods and payment terms in the accountant engagement letter. Keep those terms consistent with the invoice they will receive.
Change the Payment Settings
Remove the card surcharge at the place that calculates it, then check each payment route that uses that setting. You need permission to edit billing settings and a provider-approved test method before making changes.
- Ask the provider which settings it disables automatically. Identify any charge calculated by your invoicing software or a connected checkout.
- Save the existing configuration and identify the staff member approving the change. Disable the card-specific charge, including any manually created fee that performs the same job.
- Create an illustrative invoice in a test environment. Check a new invoice and a recurring invoice using the practice’s actual template settings.
- Complete the provider’s supported test payment. Compare the invoice total, client charge, confirmation and accounting entry before using the revised settings for client payments.
Consider this hypothetical example. A practice agrees a $550 service fee, including GST. The invoice and card checkout must both request $550 when no other agreed charge applies. If the provider deducts an assumed $8 merchant fee, the bank receives $542. The accounting records show the $550 payment and the separate $8 merchant expense.
The client’s invoice remains paid in full.
These figures illustrate reconciliation, not a provider’s fee schedule or a completed payment test. Check the fee’s tax treatment against the provider’s statement.
If the checkout still requests more than $550 in this example, find the extra charge before sending the link. If the receipt is correct but the invoice remains partly unpaid, investigate how the payment and merchant fee were posted.
If your existing system cannot handle the required billing and reconciliation, compare time and billing software for accountants against those requirements.
Explain Fees and Payment Choices to Clients
Tell clients what amount they must pay and which payment methods your practice accepts. Use a short notice after confirming the settings match it.
For a practice retaining its agreed fees, an illustrative notice reads:
We have removed the separate card-payment charge. Your agreed service fee stays the same. You can pay using the methods shown on your invoice. If an existing payment link requests an extra card fee, contact us before paying so we can correct it.
Only send that notice if its claims match your practice’s arrangements. Explain any general fee increase separately, including when it applies to the client’s engagement.
The ACCC’s card surcharge guidance distinguishes changes to general prices from charges tied to a payment method. It also explains price displays and discounts.
A general fee change applies under the agreed service terms regardless of how the client pays. A payment-method discount reduces the full price for an eligible method. A card surcharge adds a charge because the client selects a card.
Incorrect: rename a card-only fee an administration fee while continuing to add it at card checkout. Correct: remove the card-only fee and assess any genuine general fee change separately. The fee’s purpose and application determine whether it is a card surcharge.
When you give a discount, show the full price clearly. Explain the qualifying payment method without presenting the discounted amount as the price every client will pay. Avoid claiming that the rules require your practice to increase its service fees.
Provider and Card-Network Differences
Check the card network rule and the provider setting separately because a disabled surcharge switch does not correct every invoice or fee clause.
The designated networks’ joint guidance covers eftpos, Visa and Mastercard. Their no-surcharge rules extend across the relevant debit, prepaid and credit cards, including business cards. American Express reaches its no-surcharge position separately. Use the network’s applicable merchant terms when resolving a claimed exception.
Square’s support guidance says its automatic removal covers its card surcharge setting. Manually created charges and partner integrations need separate attention. Its guidance also gives a device refresh step when a removed charge still appears. A charge built as a service charge can therefore survive the automatic change.
NAB’s merchant guidance describes removal of surcharging functionality from its facilities while directing merchants to review third-party providers separately. A practice using a bank terminal and a separate invoice payment service must review both.
Ask for confirmation covering your actual facilities, including payment links and recurring collections. Retain the provider’s answer with the configuration record. A statement showing card acceptance costs does not itself permit your practice to pass those costs on as a surcharge.
Correct an Unexpected Charge
Preserve the affected transaction and find where the extra amount was added before changing future invoices.
- Save the original invoice, payment confirmation and transaction reference. Record the card network and whether the extra fee appears on the invoice, checkout or receipt.
- Compare that evidence with the configured fee settings. Ask the payment provider to trace the charge and confirm the correction or refund procedure.
- Correct the affected client’s charge through that procedure. Send the client a clear explanation and retain the adjustment with the original records.
- Fix the source setting or template separately. Repeat the same payment-route check and inspect the next affected recurring bill.
If the provider says the charge is permitted, request the applicable rule or legal exception in writing. Escalate an unresolved scheme-rule issue through the provider or card network. For misleading price displays, use ACCC guidance and the relevant state or territory consumer protection agency.
Close the task when the client’s adjustment agrees with the payment record and the corrected payment route requests the agreed invoice amount.
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