Implement least-cost debit routing for card-not-present transactions under Regulation II's network non-exclusivity rule

Steps

1. Confirm your debit card issuers have enabled at least two unaffiliated payment card networks capable of processing card-not-present (CNP) debit transactions, as required since the July 1, 2023 Regulation II update.
2. In your payment gateway/processor routing configuration, enable PINless/CNP debit network routing options rather than defaulting every online debit transaction to a single global card network.
3. Build or configure routing logic that evaluates the per-network cost (interchange plus network fees) for a given BIN/transaction and selects the lowest-cost eligible network at authorization time.
4. Verify with your acquirer which alternative debit networks are actually enabled for CNP routing on each BIN, since not all issuers enable every network for online transactions even where at least two exist.
5. Monitor authorization approval rates by network after enabling least-cost routing, since routing purely on cost without considering approval-rate differences can increase declines on some networks.
6. Track your realized interchange savings against fees, since single-message network routing still represents a modest share of CNP debit volume industry-wide, so confirm the savings actually apply to your card mix before over-investing in the routing logic.