The Till School
The Till School / Case notes / Note 02
02

Two doors your customer can use to take the money back, and only one is law

A chargeback is a message between two banks, and it appears in neither the Payment Services Regulations nor the Consumer Credit Act. What the statutes do give your customer is a 13 month window, a next-day refund on unauthorised payments, a £35 ceiling on their own losses and a joint claim against the card issuer that turns on the price of the item rather than the size of the payment.

Published
5 September 2026
Documents read
6, all primary
Length
2311 words

For two years I told shop owners that a chargeback was their customer's legal right. It turns out that it is not. I went looking for it in the Payment Services Regulations 2017 and in the Consumer Credit Act 1974, spent most of a morning in both, and could not find the word anywhere that mattered. What I found instead were 2 statutory routes that behave nothing like a chargeback, and a third route that is a private arrangement between banks.

That distinction decides how much time you have, what evidence counts, and whether anybody is obliged to listen to you at all. So this is the chargeback process uk merchants are actually inside, written from the two instruments and with the gaps marked.

The clock that is written down

Start with regulation 74 of the Payment Services Regulations 2017, because it sets the outer edge of everything. A payment service user is entitled to redress "only if it notifies the payment service provider without undue delay, and in any event no later than 13 months after the debit date".

Thirteen months from the debit date. Do not plan around 120 days. I had assumed the number was 120 days, because that is what every merchant forum repeats, and 120 days comes from scheme rulebooks rather than from any statute. I was wrong about that for two years and I repeated it in a lesson.

There is a hole in that deadline. It matters more than the deadline does. Regulation 74(2) says that where the provider failed to give the customer the information required by Part 6 of the Regulations, the customer keeps the right to redress even though the 13 months went by. So the clock is only as good as the bank's paperwork, and that is the bank's problem rather than yours, but it is the reason a transaction you had written off can come back.

What the statute actually gives the customer

Regulation 76(1) covers unauthorised transactions, which in plain terms means the card was used without proper consent. Where that happened, the provider "must refund the amount of the unauthorised payment transaction to the payer" and restore the account to the state it would have been in. The timing in 76(2) is fast. The refund goes no later than the end of the business day following the day the provider becomes aware of it.

That speed is the part I misread for years. The refund goes out first and the argument happens afterwards, which is why the money can leave your account before anybody has asked you a question.

Regulation 77 sets the customer's own exposure. A provider may hold the payer liable "up to a maximum of £35" for losses from a lost or stolen instrument. The £35 disappears entirely if the loss was not detectable before the payment, and it disappears after the customer reports the card. It goes the other way if the customer acted fraudulently or with gross negligence, in which case the payer carries all of it.

So on the unauthorised route the customer's worst case is normally £35. The rest of it lands somewhere else, and never assume that somewhere is the bank. Read that with the next section and you can see why fraud losses drift towards the merchant.

The other door, which only opens on credit cards

Section 75 of the Consumer Credit Act 1974 is the one people mean when they say the credit card company is jointly responsible. The wording is old and precise. Where the debtor "has, in relation to a transaction financed by the agreement, any claim against the supplier in respect of a misrepresentation or breach of contract, he shall have a like claim against the creditor, who, with the supplier, shall accordingly be jointly and severally liable".

Jointly and severally is the phrase that matters. The customer can go to the card issuer instead of you, the issuer pays, and section 75(2) then gives that issuer the right to be indemnified by you for what it paid out, which means the money comes back down the chain to the same place it would have come from anyway.

I had the money limits wrong for years, and this is the corrected version. Section 75(3)(b) removes the protection where the claim "relates to any single item to which the supplier has attached a cash price not exceeding £100 or more than £30,000". The test is the cash price of the item. Not the amount that went on the card.

Work through what that does to two ordinary sales. A sofa priced at £900 with a £50 deposit on a credit card is covered, because the item is £900 and the deposit is irrelevant to the test. A £90 pair of boots paid in full on a credit card is not covered, because the item is under £100. Two customers, two credit cards, opposite answers, and the difference has nothing to do with how much either of them paid you.

A short digression, because it caught me out. Section 75 applies to credit agreements, not to debit cards. Debit disputes therefore run on scheme rules alone, which is the route with no statute behind it at all. I would guess that most of the disputes a corner shop sees in a year are debit disputes, given how much of British card spending sits on debit, though I am not going to put a percentage on it from memory. Anyway, back to the rulebooks.

The route I said I could not source

When I first wrote this piece I put a paragraph here saying that a chargeback is a message between 2 banks under the rules of a card scheme, that it appears in neither statute, and that I could not find a public quotable rule on the response window. That was true when I wrote it and it is no longer true. I have now gone back and found both documents, so this is the corrected section.

Visa publishes the Visa Core Rules and Visa Product and Service Rules openly. The edition I read is dated 18 April 2026 and runs to 923 pages. On the dispute conditions it states the limit in one line: "Dispute Response Time limit: 30 calendar days from the Dispute Processing Date".

Mastercard publishes a Chargeback Guide the same way. The edition on its site when I read it is dated 26 April 2022 and runs to 703 pages. The acquirer's answer to a chargeback is called a second presentment, and the time frame it gives for most transactions is "Within 45-calendar days of the chargeback settlement date", with shorter windows written in for some domestic markets, including 30 calendar days in one and 2 business days in another.

Now the part that matters for a shop, and the reason my original paragraph was not as wrong as it looked. Those 30 and 45 day windows belong to your acquirer rather than to you. The acquirer has to assemble your evidence, format it and file it inside that window, so the deadline it gives you is shorter, and how much shorter is a decision your provider makes rather than a rule the scheme publishes.

Both documents I read are the public editions published for the United States. I have not found a separately published UK or European edition of either rulebook, and I am not going to assume the numbers carry across unchanged, so treat 30 and 45 as the shape of the thing rather than as your deadline.

Your deadline is in your acquirer agreement under disputes or chargebacks, it is usually 3 or 4 paragraphs, and it names the evidence pack you have to send. That is why two shops on the same high street with two different acquirers get two different answers about how long they have.

My instinct is that 9 owners in 10 have never opened that section of the agreement. That is an instinct and not a finding, and I would bet on it anyway.

What this costs you when it happens

Whether a dispute is worth defending comes down to arithmetic you can do in 5 minutes, and only you have the inputs.

The first is your dispute fee. Look at your statement for a line called chargeback fee, dispute fee or retrieval fee, and check the wording of your tariff on whether it is charged per case or only on cases you lose. Read that line of the tariff twice. The two versions produce very different behaviour when a customer is unhappy about a £40 sale, and the difference is roughly £15 every time somebody complains.

The second is your average transaction value. A dispute fee of £15 against a £40 sale is a different business decision from the same fee against a £900 sale, and defending both takes the same hour of your time.

The third input is your own time. A card-present dispute normally needs the terminal receipt, the till journal and a signed delivery note. That is 3 documents from 2 systems. Evidence for a card-not-present dispute is address verification, the delivery record and the correspondence. If those live in 3 different systems, an hour is optimistic. I have never seen them live in one.

I find it hard to sit through a conversation where a shop owner explains that they stopped defending disputes entirely, because the arithmetic that got them there is usually sound and the outcome still makes the problem worse.

Where each door leads

The table below is the map I keep, and every line in it points at the regulation or section it came from rather than at an opinion of mine.

Here is the arithmetic. Do it on paper, it takes 5 minutes. Take your dispute fee, call it 15 pounds for the sake of the example, and your average sale, call it 40 pounds. Losing the case costs you the 40 pounds plus the 15 pound fee, so 55 pounds. Winning it costs you the 15 pound fee in most tariffs, plus an hour of your time gathering evidence. On those numbers, defending pays only if you win more than roughly three cases in four, and on a card-not-present sale with no delivery signature you will not.

Now run it again at a 900 pound average sale. Losing costs 915 pounds, winning costs 15 pounds and the same hour, and the win rate at which defending pays drops to about one case in sixty. The policy that is right for a coffee shop is wrong for a furniture shop. Both owners will tell you their approach is the obvious one, and both are right about their own shop and wrong about the other.

Those are my own figures on invented sale values and not a benchmark of any kind. Put your own dispute fee and your own average sale into the same 2 lines. The answer changes shape.

Where each door leads, and who is holding the clock
RouteWho decidesThe clockWhere it is written
Unauthorised transaction, refundThe customer’s bank, then the ombudsmanNotify without undue delay, and no later than 13 months after the debit dateRegs 74 and 76, Payment Services Regulations 2017
Customer’s own liability on a lost or stolen cardThe customer’s bankCapped at £35, nil after they report it, unlimited if they acted fraudulentlyReg 77
Section 75 claim against the card issuerThe issuer, jointly and severally with youThe section sets no deadline of its ownSection 75(1), Consumer Credit Act 1974
Section 75 money limitsSet by statuteItem cash price above £100 and not more than £30,000, on the item and not the paymentSection 75(3)(b)
Chargeback, the acquirer’s answerTwo banks, under the rules of a card scheme30 calendar days at Visa, 45 at Mastercard, both belonging to your acquirerVisa Core Rules 18 April 2026, Mastercard Chargeback Guide 26 April 2022
Chargeback, your own deadlineYour provider, inside those windowsShorter than the scheme window, and not published anywhereYour acquirer agreement

The evidence that actually travels

One more thing the statute settles and the rulebook does not. Regulation 76 puts the refund first and the argument second. By the time anybody asks you for evidence the money has usually gone, and what you are doing is applying to have it sent back, which is an uncomfortable position to argue from.

For a card-present sale the pack is small. The terminal receipt with the authorisation code, the till journal line for the same second, and a delivery note if the goods left the shop, and that is genuinely all of it, because a card-present case turns on whether the card and the PIN were physically there rather than on anything you write in the covering note. If the card was inserted and a PIN was entered, say so in one sentence and attach the receipt that proves it.

For a card-not-present sale the pack is larger and weaker. Address verification result, the delivery record with a signature or a photograph, the order confirmation email with a timestamp, and any message where the customer discussed the order after it arrived. I have watched a shop lose a 260 pound dispute holding all of that except the signature. The signature is the part that decides it, which I find genuinely odd, since the photograph showed the parcel on the doorstep of the address the card was registered to.

The 13 month tail in regulation 74 is the reason to keep the pack. A dispute on a sale from last October can land in November of this year, and a folder you cleared out in the summer is a defence you no longer have.

What I would do before the next one arrives

The disputes section of your acquirer agreement belongs in the same folder as your terminal contract. It runs to 2 or 3 pages and it answers the question you will ask in a hurry, at the moment when you have the least patience for reading contracts.

The second job is the terminal. Find out whether it can reprint a receipt copy after 30 days, because a card-present defence without the receipt is an argument you lose on paperwork rather than on the facts.

The third job is a count. Look at your last 12 months. Regulation 74 gives your customers 13 months, so a quiet year is not a finished year, and the number of disputes you actually saw is a floor rather than a total.

I still do not know how the scheme timetables sit alongside the 13 month statutory tail in a case that runs to the edge of both. I have not found a published example that walks through one, and the absence bothers me more than it probably should. If you have been through it, I would rather print your account than keep guessing at mine.

Where each number came from

  1. Payment Services Regulations 2017, regulation 74: notification without undue delay and no later than 13 months after the debit date (read 5 September 2026)
  2. Payment Services Regulations 2017, regulation 76: refund of unauthorised transactions by the end of the following business day (read 5 September 2026)
  3. Payment Services Regulations 2017, regulation 77: the payer's liability capped at £35, and the cases where it is nil or unlimited (read 5 September 2026)
  4. Visa Core Rules and Visa Product and Service Rules, public edition dated 18 April 2026: Dispute Response time limit of 30 calendar days from the Dispute Processing Date (read 5 September 2026)
  5. Mastercard Chargeback Guide, public edition dated 26 April 2022: second presentment within 45 calendar days of the chargeback settlement date for most transactions (read 5 September 2026)
  6. Consumer Credit Act 1974, section 75: joint and several liability of creditor and supplier, and the £100 to £30,000 cash price limits in section 75(3)(b) (read 5 September 2026)

Every line above was read on the date shown. When a rule changes we change the page and move the date, rather than quietly leaving the old number up.