What is the TRA exemption?

In short

The TRA exemption, short for transaction risk analysis exemption, lets a payment service provider skip strong customer authentication on a remote electronic payment that its real-time risk analysis rates as low risk. The TRA exemption comes from Article 18 of Delegated Regulation (EU) 2018/389 and is open only to a provider whose own fraud rate stays within the regulation's reference rates.

Also called
Transaction risk analysis exemption, TRA, Low-risk transaction exemption
Family
Fraud and disputes
Facts checked

How the TRA exemption works

Three conditions apply together. The provider's fraud rate for that type of payment is within the reference rate, the amount is within the threshold for that rate, and the real-time analysis finds no warning sign, such as abnormal spending, unusual device information, malware or a high-risk payee location.

For remote card payments the thresholds are:

  • Up to EUR 100 with a fraud rate of 0.13% or less
  • Up to EUR 250 with a fraud rate of 0.06% or less
  • Up to EUR 500 with a fraud rate of 0.01% or less

How the fraud rate is measured

Article 19 sets the rate as the total value of unauthorised or fraudulent remote transactions divided by the total value of all remote transactions of the same type, over a rolling 90 days. A provider whose rate is above the reference rate for two quarters in a row stops using the exemption in that threshold range (Article 20).

The UK kept the exemption in the FCA's technical standards, also as Article 18.

Who applies the TRA exemption

The EBA's opinion of 13 June 2018 says that for card payments both the issuer and the acquirer may apply the exemption, that the issuer always has the final decision, and that a merchant can never decide. The acquirer's rate is calculated on all the transactions it acquires, not on one merchant's.

Where the payee's provider does not accept strong customer authentication, Article 74 of PSD2 has it refund the damage to the payer's provider. An exemption asked for by the acquirer therefore generally leaves the fraud loss on the acquirer's side.

TRA exemption or low-value exemption?

Low-value exemption
Covers small remote payments up to a fixed amount, with a cumulative limit, and has no fraud-rate condition.
Frictionless flow
In 3-D Secure, the issuer approves without challenging the cardholder. That can be the issuer's own use of the TRA exemption.

Where the TRA exemption shows up in a platform

Modules that do the work

Platforms that need it

Guides that go deeper

Where it is written

The laws and standards this page's facts come from.

General information, not legal advice: what applies to you depends on your services and your market.

Every term

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