Least-cost debit routing: what to ask your processor

What the rule says

Federal debit rules (Regulation II) say each debit card must be able to run on at least two unaffiliated networks, and card issuers and networks may not stop a merchant from choosing which one to use. Since July 2023 this also covers online and other card-not-present debit.

12 CFR 235.7(b): "An issuer or payment card network shall not, directly or through any agent, processor, or licensed member of the network, by contract, requirement, condition, penalty, or otherwise, inhibit the ability of any person that accepts or honors debit cards for payments to direct the routing of electronic debit transactions for processing over any payment card network that may process such transactions."

What it means for you

In practice your processor makes the routing choice for you. The Federal Reserve reports single-message (PIN network) debit averaged about 25 cents per sale in 2024, against about 37 cents for dual-message debit. The cheapest network can differ by sale size.

On a flat rate, routing savings go to your processor, not to you.

What to ask

Ask your processor whether it sends your debit sales over the lowest-cost network for each sale, and whether PINless debit routing is turned on for your account. FeeHound's rate review letter asks both questions.