The Reserve Bank of Australia (RBA) yesterday (Thursday 11 September, 2025) published Commonwealth Bank’s latest submission to its review of merchant card payment costs and surcharging, now in its second round of consultation.
In its 22-page submission, CBA says it supports the RBA's broader objective to reduce costs for small businesses while reaffirming its backing for the proposal to ban surcharging on both debt and credit card payments.
As the RBA itself has acknowledged, the price signal of surcharging to consumers has become less effective. It is challenging for the Australian Competition and Consumer Commission to enforce compliance of the current regime, while some payment service providers have gone beyond the spirit of the regulations.
However, we are concerned that the proposed changes to interchange fees may not deliver the expected benefits and could result in unintended consequences – particularly a value shift away from Australian businesses and infrastructure providers to offshore entities. This could undermine the resilience of our domestic payments system at a time when global uncertainty demands stronger local capability.
In our submission, CBA has proposed an alternative model that we believe could maintain globally competitive interchange costs, deliver targeted support and lower costs to small businesses, and ensure a fairer distribution of economic impacts across the payments value chain. We believe this approach supports the RBA’s objectives and the national interest.
We look forward to continuing our engagement with the RBA and industry stakeholders to help shape a payments system that meets the needs of consumers, businesses and the broader economy.
To read CBA's submission in full please go to: Submissions on Review of Merchant Card Payment Costs and Surcharging | RBA