From Cards to A2A to Tokenised Deposits: What the ‘Invisible Payment’ Shift Means for High-Risk Merchants in 2026

For most of the last two decades, the card was the dominant instrument of digital commerce. It was visible, familiar and, for merchants, something to be managed: authorisation rates, interchange fees, chargeback ratios and scheme rules. High-risk merchants built entire operational frameworks around the card model, even when it was expensive or restrictive, because it was the structure they could rely on.

In 2026, that structure will be quietly dismantled. Not replaced overnight, but supplemented, bypassed and in some cases made redundant by a new generation of payment rails. Account-to-account transfers, tokenised deposits, embedded finance flows and the early architecture of wholesale CBDCs are collectively shifting payments away from the front of the customer journey and into the background. Payments are becoming infrastructure rather than a destination, and that shift has consequences that go well beyond processing fees.

For high-risk merchants, the change is not simply a technology question. It reshapes the economics of processing, the structure of disputes, the expectations of PSPs and acquirers, and the compliance environment in which merchants operate. Understanding what is happening and why it matters is no longer optional for merchants who want to build a resilient payment stack in 2026.

The Card Model and Why It Is Under Pressure

What Cards Gave High-Risk Merchants

The four-party card model gave high-risk merchants something genuinely valuable: a standardised framework. Whatever the vertical, geography or product, merchants could expect a defined dispute process, a consistent set of scheme rules, consumer-facing protections and a global network of issuers and acquirers operating within broadly understood parameters. Chargebacks were painful and costly, but they were at least predictable. Merchants knew the rules, knew the timelines and could build evidence and dispute management processes around them.

For high-risk verticals in particular, the card model also offered reach. It was often the only rail that could serve customers across multiple geographies, currencies and devices without requiring market-by-market infrastructure. Whatever its costs, it worked at scale.

Where the Pressure Is Coming From in 2026

That model is now under simultaneous pressure from several directions, and high-risk merchants are feeling it more acutely than most. Interchange and scheme fees for high-risk MCCs have continued to rise, compressing margins that are already thin for many merchants in regulated or complex verticals. At the same time, card scheme thresholds for disputes and fraud are tightening. Visa’s VAMP model now applies a single ratio across fraud and disputes on card-not-present transactions, with thresholds for excessive merchants falling from 220 basis points to 150 basis points in April 2026.

Mastercard’s Excessive Chargeback Programme applies similar scrutiny, requiring additional action from merchants who breach thresholds for consecutive months.

Beyond cost and compliance pressure, there is a structural shift in consumer behaviour. Growing numbers of merchants and consumers are moving towards payment methods that bypass card networks entirely.

Three forces are now compressing the card model from different directions:

• Rising processing costs and tightening scheme thresholds making cards more expensive and less forgiving for high-risk merchants.
• Consumer and merchant adoption of A2A and alternative rails accelerating, with 85% of merchants now offering alternative payment options including A2A transfers.
• New payment infrastructure, including tokenised deposits and embedded finance flows, beginning to offer capabilities that cards were never designed to provide.

The card model is not disappearing. But for high-risk merchants, it is no longer safe to assume it will remain the only rail that matters.

A2A Payments – The Rail That Is Growing Fast

How A2A Works and Where It Is Gaining Ground

Account-to-account payments move funds directly from a consumer’s bank account to a merchant’s account, using open banking APIs or domestic and cross-border fast payment rails. There is no card network in the middle, no interchange fee and no card scheme dispute framework. The consumer authenticates through their own banking app, and funds settle directly and quickly.

The growth numbers are significant. Cross-border A2A transactions are projected to surpass 11 billion in 2026, and A2A’s share of global ecommerce is growing at a 13% compound annual rate, approaching a market size of nearly $850 billion. In markets where real-time payment rails are already mature, such as Brazil with PIX, India with UPI and the EU with SEPA Instant, A2A has moved from an emerging option to a mainstream one. Consumers in these markets are increasingly comfortable paying directly from their bank accounts, and merchants are following that preference because the economics are more attractive than card processing.

What A2A Means for High-Risk Merchants

The appeal of A2A for high-risk merchants is genuine. Processing costs are lower, often significantly so, removing the 2–3% fee burden that card interchange imposes on every transaction. Settlement is faster, with funds moving in seconds rather than days. And because A2A uses bank-grade strong customer authentication, the exposure to certain types of card fraud is reduced at the point of authorisation.

However, the picture is considerably more complex for high-risk merchants than for mainstream ecommerce. The most significant challenge with A2A is that it currently lacks a standardised dispute or chargeback mechanism. When a customer disputes an A2A transaction, the process is handled directly between banks, without card scheme oversight, without a standardised evidence framework and without consistent consumer or merchant protection. Each bank follows its own procedures, and the outcomes can be inconsistent and difficult to predict.

For high-risk merchants, where friendly fraud is already one of the most operationally costly challenges, this gap matters enormously. There is no equivalent of a chargeback representment process, no scheme-level rules about evidence standards, and no defined timeline for resolution. In cross-border A2A disputes, the complexity increases further, as different regulatory frameworks, language barriers and banking practices can delay resolution by months.

Industry analysis suggests that friendly fraud rates on A2A rails are rising year on year, and the absence of a formal dispute structure means that merchants have limited tools to contest illegitimate claims.

None of this means high-risk merchants should avoid A2A. It means they need to adopt it with a clear understanding of where the risks sit, and build their evidence and consent documentation frameworks accordingly, before volume on those rails becomes significant.

Tokenised Deposits – The Next Layer of the Rail Stack

What Tokenised Deposits Are

Tokenised deposits are commercial bank deposits represented in digital token form on ledger infrastructure. In practical terms, they combine the regulatory trust and prudential oversight of a traditional bank deposit with the programmability and near-instant settlement that digital money architectures enable. The token is not a separate asset class; it is a digital representation of a claim on money held within the regulated banking system.

This distinction matters. Unlike stablecoins, which operate as issuer-backed tokens under separate regulatory frameworks, tokenised deposits remain within the existing two-tier banking structure and are subject to the same prudential oversight as conventional deposits. In the UK, a live pilot involving Barclays, HSBC, Lloyds Banking Group, NatWest, Nationwide and Santander is running through mid-2026, covering marketplace payments, remortgaging and digital asset settlement. Bank of England Governor Andrew Bailey has stated publicly that tokenisation of bank deposits offers clearer value than stablecoins, signalling that the UK regulatory direction of travel favours tokenised deposits as the primary vehicle for programmable commercial bank money.

Across the broader digital money landscape, regulators and institutions are converging on what is being described as a digital money triangle: tokenised deposits acting as ledger-based claims on commercial bank money, regulated stablecoins backed by reserves under defined rulesets, and wholesale CBDCs functioning as the ultimate settlement asset between licensed institutions.

Why This Matters for High-Risk Merchants

For high-risk merchants, tokenised deposits are not yet an operational reality in most markets. But they represent the direction in which regulated payment rails are moving, and the implications are worth understanding now rather than later.

Programmable payment rails mean that compliance rules, conditions and restrictions can potentially be embedded at the infrastructure level rather than applied as an overlay by PSPs or merchants. For high-risk merchants, this could translate into payment flows where certain categories of transaction are automatically flagged, conditioned or restricted based on merchant classification, jurisdiction or regulatory status, before the payment reaches the merchant’s account.

At the same time, tokenised deposit rails could offer genuine operational benefits: real-time settlement, programmable reconciliation, reduced intermediary costs and cross-border flows that are faster and more transparent than correspondent banking. The question for high-risk merchants is not whether to engage with this infrastructure, but how to ensure that they are not structurally excluded from it as the rails mature and access criteria are defined.

CBDCs – Still Emerging but Worth Watching

Wholesale CBDCs are progressing faster than retail models, and for high-risk merchants, they matter less as an immediate operational priority and more as a structural signal about where regulated payment infrastructure is heading. Central banks in the EU, UK, US and across Asia are actively building the settlement layer that will underpin the next generation of payment rails, and the design choices being made now will shape how commercial payment flows are structured in the late 2020s.

The digital euro project and equivalent programmes in other jurisdictions raise specific questions for high-risk merchants. CBDCs designed with programmability built in could enable payment flows that are conditioned, monitored or restricted at the protocol level. For merchants in verticals that already face heightened regulatory scrutiny, the prospect of payment rails that carry inherent compliance logic is not abstract. It represents a potential structural change in how payment access is managed for certain categories of business.

Privacy considerations are also relevant. Transactions conducted via CBDC infrastructure could be subject to greater monitoring than those on conventional rails, raising questions about data handling, regulatory visibility and the practical impact on merchants whose transaction patterns are complex or high-volume.

For now, CBDCs are a planning horizon rather than an operational requirement. But high-risk merchants and their PSPs would be well served by tracking how wholesale CBDC settlement connects to tokenised deposit and A2A rails, because that integration will define the payment infrastructure they are operating within by the end of this decade.

The ‘Invisible Payment’ Shift and What It Changes

Payments Becoming Infrastructure, Not a Destination

Across A2A, tokenised deposits, embedded finance and the early wave of agentic commerce, a consistent pattern is emerging: the payment is no longer a distinct moment in the customer journey. It is becoming a background event, embedded in platforms, subscriptions, automated flows and AI-assisted purchasing. Consumers increasingly do not “make a payment”; they simply receive goods, services or access, and the payment happens underneath.

This is what is meant by the invisible payment shift. The rails that carry the money are becoming infrastructure in the same way that electricity or internet connectivity is infrastructure: essential, ubiquitous and largely unnoticed until something goes wrong.

What Invisibility Means for High-Risk Merchants Specifically

For mainstream merchants, invisible payments are mostly an opportunity: lower friction, higher conversion and embedded loyalty flows. For high-risk merchants, the picture is more nuanced and requires careful attention.

When payments become invisible, consumer awareness of individual authorisation events decreases. A customer who does not consciously “make a payment” is more likely to dispute a charge they do not immediately recognise, regardless of whether the authorisation was entirely valid. This dynamic increases the risk of friendly fraud across all rails, not just cards, and it means that the evidence merchants collect at the point of consent and authorisation becomes more important, not less, as payment invisibility increases.

Invisible payment flows also reduce the natural moments where merchants can insert friction, authentication confirmation or explicit consent. In a fully embedded or automated flow, the customer may not see a payment screen at all. For high-risk merchants, who already operate in an environment where dispute and fraud risk is elevated, this compresses the window in which consent evidence can be collected and makes after-the-fact dispute resolution considerably harder.

PSPs and acquirers are responding to this shift as well. Monitoring in an invisible payment environment increasingly focuses on behavioural patterns across flows rather than individual transaction signals. For high-risk merchants, this reinforces the importance of maintaining clean, consistent transaction data and a clear audit trail across all rails, not just card processing.

Practical Implications for High-Risk Merchants in 2026

The shift from cards to A2A to tokenised deposits is not happening all at once, but the direction is clear and the pace is accelerating. High-risk merchants who begin positioning themselves now will have more options and more control than those who wait for the transition to force their hand.

The most immediate practical area is dispute and evidence management. Card chargeback frameworks do not translate directly to A2A or tokenised deposit disputes. Merchants who are processing meaningful A2A volume need to be documenting authorisation trails, consent records and behavioural evidence now, in a format that can support bank-to-bank dispute processes even in the absence of a standardised scheme framework.

Conversations with PSPs and acquirers are also changing. PSPs are increasingly assessing how merchants are positioned across multiple rails, not just evaluating card volumes and chargeback ratios in isolation.

High-risk merchants who can demonstrate a considered approach to multi-rail processing, including how they manage risk and evidence across A2A and emerging rails, are better positioned in those conversations than those who treat card processing as their only relevant metric.

Cost model assumptions also need revisiting. A2A and tokenised deposit rails can reduce processing costs materially, but only if merchants account properly for the operational cost of managing disputes and compliance in the absence of card scheme protection. The saving on interchange does not automatically translate into a net cost reduction if dispute management costs rise to compensate.

In practical terms, four areas require attention from high-risk merchants as this transition accelerates:

• Dispute and evidence frameworks need updating for A2A and tokenised rails, where card scheme processes do not apply.
• PSP and acquirer relationships need to reflect a multi-rail strategy, not just card performance metrics.
• Cost models need to account for operational complexity across rails, not just headline processing fee differences.
• Compliance and monitoring expectations will increase as programmable and real-time rails introduce new regulatory visibility into payment flows.

Conclusion

The invisible payment shift is one of the most significant structural changes in payments in a generation. Cards will remain a major rail for years to come, but the infrastructure alongside them is expanding rapidly, and the economics, dispute structures and compliance expectations attached to each rail are materially different from the card model that high-risk merchants have built their operations around.

For high-risk merchants, this transition carries both risk and opportunity. The risk lies in being unprepared: adopting new rails without understanding where the dispute and compliance gaps sit, or finding that emerging infrastructure is designed in ways that restrict access for certain merchant categories. The opportunity lies in engaging early: building multi-rail capability, updating evidence and consent frameworks, and working with PSPs and acquirers who understand the new landscape rather than those still optimising purely for card performance.

The payments infrastructure of 2026 is being built now. High-risk merchants who engage with that process deliberately, rather than waiting to react when the transition forces their hand, will be in a considerably stronger position when the next phase of that infrastructure becomes operational.

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