“With such broad-based support and clear economic benefits, why has surcharging not become ubiquitous already? Many merchants who are eager to get started with surcharging assume that it simply entails ‘adding a fee.’ However, through implementation, they quickly realize that this assumption overlooks numerous requirements or best practices in operations and IT — how they will address customer messaging about surcharges, incorporate surcharges into their online checkout experience or invoicing tools, reconcile deposits to their bank account or handle cash application for transactions that now include surcharges, as well as handle the implications for receipts and refunds. On top of these requirements, the staggering compliance overhead raises the barrier to entry for surcharging; card brand rules from Visa and Mastercard, along with the evolving state law landscape, regulate surcharging practices and create complexity for merchants.”