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COVID-19: Merchant and Program Participant Policy Changes 

American Express Merchant Reference Guide - US [April 2019]

Specific guidance and procedures for handling chargebacks and inquiries are located beginning page 44..


Globally, the spread of the novel coronavirus (COVID-19) has caused widespread disruption. 

We are adjusting our Program policies to provide needed relief to our merchants and Program participants and announcing the following changes for the United States, Puerto Rico and U.S. Virgin Islands. We encourage you to extend these changes to your merchant customers: 

  • Disputes Response Time: American Express is extending our “reply by” time frames from twenty (20) days to thirty (30) days, giving you and your merchants an extra ten (10) days to respond, for all disputes issued between March 1, 2020 and May 31, 2020. This change applies to all disputes (fraud and non-fraud). All other dispute policies remain unchanged at this time. 


American Express is working quickly to apply this rule systematically. We anticipate this being in place by March 30, 2020. Dispute notifications issued through March 30, 2020 may not reflect this time frame extension. For all dispute notifications you received between March 1, 2020 and March 30, 2020, American Express will provide you with ten (10) additional days to respond. 

If you received a No Reply Chargeback associated with a dispute notification issued on or after March 1, 2020, please provide support through a second presentment. Please refer to Chapter 16, “Disputed Charges, Chargebacks and Inquiries” of the Operating Regulations for more information on “reply by” time frames. 

  • Chargeback-Related Fees: Excessive Chargeback Fees as indicated in Section 11.5, “Additional American Express Fees” of the Operating Regulations will continue to be assessed, however, American Express will issue a credit for all Excessive Chargeback Fees assessed through June 30, 2020, for any Program participant or merchant that exceeds the threshold during this period. 

  • Data Security Non-Validation Fee: We are extending the requirement for submitting PCI validation documentation to June 30, 2020, as well as suspending the American Express Data Security Non-Validation fee for the reporting period through June 30, 2020. More information regarding the Data Security Non-Validation Fee can be obtained in the American Express Data Security Operating Policy. 

  • Contactless Payments: We are increasing our contactless transaction thresholds in the U.S. from $50 USD to $200 USD in order to reduce physical contact at the point of sale. For more information regarding contactless threshold changes, please contact your American Express Payment Consultant Group representative. 

  • No Signature Required:  we also want to remind you that American Express-accepting merchants can choose not to collect Card Members' signatures at the point of sale for any purchase transaction.  This merchant-facing policy is communicated in Chapter 4, "Transaction Processing" of the American Express Merchant Operating Guide. 


  • Program Operating Regulations. In order to give our Program participants ample time to review and plan for changes, we will be holding to our regular schedule of publishing our Program operating regulations (applicable to OptBlue® and Payment Aggregator Program participants) on or about April 17, 2020.      

  • There will be no items with effective dates before October 16, 2020. 

  • We will extend the timeline for Program participants to review changes and contact American Express with questions or concerns as indicated in Section 1.3.5 of the Operation Regulations to July 17, 2020. 

  • The Merchant Operating Guide ( dated October 2019 will remain in effect until July 17, 2020. 

We value your health, safety, and our relationship with you. As the COVID-19 situation evolves, we will continue to assess our policies and actions. If you have any questions related to specific disputes or other program-related matters, please direct them to your Partner Manager. 

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