CP19/2 - Draft Specific Direction 9 - Crisis Communications (Visa)

05/02/2019 Size: 89.049 KB


On 1st June 2018, Visa Europe (Visa) experienced an incident resulting in a partial failure to its ability to process authorisations. Authorisations were affected for around 6 hours. As a result, many consumers across Europe were unable to complete card purchases.

Visa systems are designed to a high level of reliability and the subsequent review of the incident confirmed that Visa had a robust and resilient authorisations system intended to prevent incidents impacting authorisations. However, the incident highlighted issues with Visa’s communications during the outage.  Reflecting this, we are proposing to issue a specific direction in respect of its communications which would apply to the operator of Visa. 

The aim of our proposed direction is to make sure Visa does all it can to ensure that its participants, service users and other stakeholders are given enough information. This is to allow them to take appropriate action if any future incident occurs where Visa’s services are unexpectedly unavailable. We are proposing to give the specific direction to Visa, but we recognise that effective communication to all participants and consumers is likely to require effective co-operation with a number of organisations.

We are consulting on the specific direction and we invite you to provide comments by 1 March 2019. More details on the issue and our consultation are set out below.

We expect this consultation to be of interest to payment service providers who process card payments, including

  • Issuing banks,
  • E-money institutions,
  • Payment institutions, particularly acquirers and payment facilitators,
  • Other payment system operators (PSOs) and their participants.

Consumer and merchant organisations may also be interested in our consultation.

What is the Visa system?

Visa is the most widely-used card payment system in the UK. In 2017 around four out of five card transactions in the UK were debit card transactions: there were approximately 13.2 billion debit card transactions in the UK and 3.1 billion credit card transactions. 97% of debit cards issued in the UK were issued under the Visa brand in 2017.

Visa licenses payment service providers to issue debit, credit and other payment cards to consumers using the Visa brand, and licenses acquirers to process payments on behalf of merchants.

Visa branded cards are also often used to withdraw cash from ATMs, however, only a small number of UK withdrawals will go across the Visa system.   Typically, a cash withdrawal will only go across the Visa system if Visa branded cards are used by UK visitors overseas or overseas visitors to the UK.  

The 1st June incident

The 1st June incident represented a serious disruption to Visa’s services. During the incident, 2.4 million UK transactions attempted failed. Merchants lost potential sales and consumers lost purchasing opportunities. We noted that some merchants suspended all card payments, including those payments using other card payment systems, for periods during the incident. It may not have been clear to consumers that Visa debit cards continued to work at LINK ATMs during the incident, adding to the general lack of clarity to consumers on how best to respond to the incident. The disruption to Visa’s services could have gone on to cause disruption to other payment systems if the incident had continued for longer.

In Visa’s letter to the Treasury Select Committee (TSC) dated 14 November 2018, Visa recognised that it ‘failed to meet […] the expectations of [Visa’s] various stakeholders’. 

Shortly after 1st June incident, Visa commissioned Ernst & Young LLP (EY) to conduct an independent review of the incident. The resulting report findings and observations (as provided to the TSC in Visa’s letter dated 14 November) confirms that Visa had a robust and resilient authorisations system, but also provides evidence that the partial failure of Visa’s authorisation system caused further disruption than was necessary because Visa’s communications practices were deficient.

In particular, in respect of communications the EY report found:

  • External communications were not timely or regular.
  • External communications were not actionable.
  • Remediation of communications issues identified in a previous incident were still to be completed.
  • Delays in communication approvals.
  • Internal communications were not timely, actionable or delivered through effective channels.
  • Methods used to communicate with clients were not effective or efficient.

If Visa participants do not receive effective and timely communications during incidents that affect the availability of Visa’s services they are unable to fulfil their own obligations for passing information on the incident to consumers and merchants. 

Why we propose to issue a specific direction

EY’s report makes a number of recommendations in order to address the findings. We are encouraged to learn that Visa has accepted all the recommendations and has committed to implementing them in a timely manner. 

However, we consider that the EY recommendations are at a high level and alone may not be sufficiently detailed to ensure that Visa makes the necessary improvements in communicating effectively during an incident.   Additionally, there is a need for assurance that the appropriate steps will be taken to achieve those necessary improvements, and a method for assessing whether Visa’s crisis communication plans continue to evolve to meet changing circumstances.  While Visa has committed to undertake remediation activities, we propose giving the operator of Visa a specific direction, putting a regulatory framework around those activities to enhance the effectiveness of the remediation work. 

The aim of our direction is to ensure that Visa has in place a robust crisis communication plan that takes into account the needs of a wide range of stakeholders, that this plan remains appropriate in light of future changes and experience, and is used in practice.

Reflecting this aim, we propose that Visa s