Determine eligibility for TRA exemption: your PSP's fraud rate for the relevant transaction type must be at or below the network reference fraud rate threshold for the applicable transaction value band (e.g., below 0.13% for transactions up to €100, below 0.06% for up to €250, below 0.01% for up to €500).
For low-value exemption, the transaction must be below €30 and neither the cumulative total of consecutive exempted transactions since last SCA nor the count (5 transactions) must be exceeded — tracking these counters is your responsibility.
Signal the exemption in your payment request using the appropriate exemption indicator field recognized by your PSP or 3DS requestor; for TRA use the transaction_risk_analysis exemption, for low-value use the low_value exemption.
Issuers may override your exemption request and step up to SCA (soft decline with authentication_required); handle this response by initiating a 3DS2 challenge flow and resubmitting.
Maintain a real-time fraud rate monitoring system to verify your PSP remains within the TRA thresholds; exceeding thresholds invalidates your right to apply TRA exemptions until the rate recovers.
Document exemption usage and outcomes for regulatory reporting and PSP compliance audits.
Known gotchas
TRA exemptions are only available to PSPs monitoring their own fraud rates — merchants cannot self-apply TRA; the exemption must be applied by the PSP on the merchant's behalf after rate verification.
Low-value counters reset only after a successful SCA-authenticated transaction; if the issuer declines with a counter-exceeded reason, the next transaction must go through full SCA before exemptions resume.
Recurring fixed-amount transactions after the initial SCA-authenticated mandate setup may qualify as MIT rather than SCA exemptions — confusing the two frameworks leads to incorrect flagging.
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