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ForeGaze research · Trust · Part 2 · Compliance

The Compliance Stack

20 min read · Data: PCI SSC, Visa, Nacha, CFPB, FTC, CPPA, Texas AG, NAIC and law-firm summaries, read 23 Oct 2026 · US first; Canada in its own short section

Forsmall businesses, from solo owners to 500 peopleUS (California noted)Canada (short section)

What keeps payments trusted, and what a small firm owes: The rules behind every card swipe and bank transfer, sorted into what you owe, what binds your bank, and what only big firms face.

A US firm of 1 to 50 people that takes cards faces 5 payment and data rule sets: card security checks (PCI), processor identity checks, network dispute limits, dispute deadlines and breach notice. Most heavier rules start far above small-firm size. Our estimate for the basics at ~5 people: about $3,455 a year.

100,000Online card payments a month before Visa’s dispute program can flag a merchant: 1,500 fraud reports and disputes at its 1.5% line, from 1 Apr 2026.
20 of 51US jurisdictions with a fixed breach-notice deadline for individuals: 30, 45 or 60 days. The other 31 set no fixed number of days.
$26,625,000Yearly gross revenue at or above which California’s privacy law (CCPA) applies to a firm doing business there. It also applies if a firm buys, sells or shares data on 100,000+ Californians.
$3,455 a yearWhat basic compliance costs a 5-person firm (our estimate): $825 staff time (11 hours), $480 multi-factor sign-in (MFA) and device-management tools, $2,150 cyber insurance. A dental office with HIPAA: about $4,205.
The answer

Five duties reach almost every firm that takes cards; the rest depend on your trade and size.

  1. Card security (PCI DSS). File the short self-assessment (SAQ) your processor asks for, every year. v4.0.1 is the only live version.
  2. Card network rules. Keep disputes and fraud under Visa and Mastercard limits, enforced through your processor.
  3. Processor identity checks (KYC, “know your customer”). Answer document requests fast. A slow reply can delay payouts or lead to a hold.
  4. Dispute deadlines (Reg E / Reg Z). These bind banks, not you, but they set the clock: answer chargebacks inside the window or lose them.
  5. Breach notice. Every state has a breach law. If customer data leaks, you must tell people, on that state’s deadline.

Only if it fits you: Nacha ACH fraud monitoring (if you send ACH from your own bank, 2026) · state privacy laws (above size thresholds) · FTC Safeguards and IRS plan (tax preparers) · HIPAA (dental and health) · AI rules (Colorado from 1 Jan 2027; California hiring; 1 Jan 2027 check) · cyber-insurance conditions (if you buy cyber insurance).

First step: ask your card processor which SAQ (Self-Assessment Questionnaire: the yes/no PCI security form for small merchants) you need, and file it. If you only take cards online through a hosted checkout page, it is usually SAQ A, the shortest. Then write a one-page breach plan.
Dated update · 23 Oct 2026 · US (California called out)

1 Jan 2027: new AI and privacy rules

On 1 Jan 2027, 70 days after 23 Oct 2026, new duties start in California, Colorado and New York. Most firms of 1 to 50 people are outside all three. This is information, not legal advice.

CPPALaw-firm reportCalifornia

Only firms the CCPA covers

  • Who is covered. A for-profit firm doing business in California with gross revenue of $26,625,000 or more a year, or that buys, sells or shares data on 100,000+ California consumers or households, or earns 50%+ of revenue from selling or sharing Californians’ personal data (CPPA FAQ).
  • New rules on cybersecurity audits, risk assessments and automated decision-making technology (ADMT) took effect 1 Jan 2026 (CPPA).
  • From 1 Jan 2027: a covered firm that uses ADMT for significant decisions about people must give notice before use, explain how the tool works on request, and allow an opt-out in some cases (Hunton, 24 Sep 2025; BPM, 6 Feb 2026).
  • Risk assessments for higher-risk data uses: the first attestation and summary go to the CPPA by 1 Apr 2028 (CPPA; Hunton, 24 Sep 2025).
  • Cybersecurity audits, only for covered firms whose data use is high-risk: first certification by 1 Apr 2028 (revenue over $100M), 1 Apr 2029 ($50M–$100M) or 1 Apr 2030 (under $50M) (BPM, 6 Feb 2026; Hunton, 24 Sep 2025).
Law-firm reportColorado

From 1 Jan 2027, if AI shapes a consequential decision (Colorado; 2026 law-firm report)

  • SB 26-189, signed 14 May 2026, repeals and replaces the 2024 Colorado AI Act (Eckert Seamans, 12 Jun 2026).
  • The act has no small-business exemption. Its exemptions are by sector (insurers, HIPAA-covered entities, medical devices), and its duties apply to decisions made on or after 1 Jan 2027 (signed act, Colorado General Assembly).
  • It covers tools that materially influence consequential decisions about Colorado residents: jobs, housing, health care, lending, insurance and similar (Eckert Seamans, 12 Jun 2026).
  • Duties: notice before use; a plain-language explanation within 30 days of an adverse decision; notice of the right to human review; records kept 3 years (Workforce Bulletin; Reinhart, 12 Jun 2026).
  • Only the state Attorney General enforces it, after a 60-day chance to fix; there are no private lawsuits (Workforce Bulletin).
  • No small-business exemption appears in the summaries we read; the bill text is unconfirmed. See the court note in AI rules.
SecondaryNew York

AI developers from 2027; city hiring tools now (New York; secondary reports, read in 2026)

  • RAISE Act, from 1 Jan 2027: covers developers that train frontier AI models, not firms that only use AI tools (CASRAI guide; Wiley, 3 Apr 2026).
  • New York City, already in force: Local Law 144 requires an independent bias audit, published results and notice to candidates before an automated tool screens job candidates (CASRAI state tracker).

Most small firms: not covered in California. If you are below every CCPA line above, California’s ADMT, risk-assessment and audit rules do not apply to you. Colorado and New York City matter only where AI or automated tools are used in consequential decisions, such as hiring, lending or housing. This is information, not legal advice.

Does this apply to you? · 1 Jan 2027 rules

Five yes-or-no questions

1. Do you do business in California (sell to or serve people there)?

2. Is any of these true: gross revenue of $26.6M or more a year; you buy, sell or share data on 100,000+ Californians or households; or 50%+ of your revenue comes from selling or sharing Californians’ personal data?

3. Do AI or automated tools make, or materially shape, decisions about a person’s job, housing, loan, insurance, health care or education?

4. Do any of those decisions affect Colorado residents?

5. Does an automated tool screen or rank candidates for jobs in New York City?

    How this works. It matches your answers to the thresholds in the sources above. It does not test exemptions, bill text or contracts. Your answers stay on this page; nothing is stored or sent. This is information, not legal advice.

    1 · Which rules apply to you · US

    Most rules are the same for every trade; three are not

    We sorted 12 rule sets by nine business types. The first five reach any firm that takes cards. Safeguards, the IRS plan and HIPAA split the trades.

    Figure 1 · rule sets by business type · US · ForeGaze reading of the rules, 23 Oct 2026

    A dental practice owes 6 rule sets outright and a tax practice 7; a plumber owes 5.

    Which rules apply, by business typeDentalCPA, taxLawArchitects, engineersConsultantsCoachesPlumbersContractorsReal estatePCI DSS (SAQ)ForeGaze · Dental · PCI DSS (SAQ): AppliesCPA, tax · PCI DSS (SAQ): AppliesLaw · PCI DSS (SAQ): AppliesArchitects, engineers · PCI DSS (SAQ): AppliesConsultants · PCI DSS (SAQ): AppliesCoaches · PCI DSS (SAQ): AppliesPlumbers · PCI DSS (SAQ): AppliesContractors · PCI DSS (SAQ): AppliesReal estate · PCI DSS (SAQ): AppliesCard network rulesDental · Card network rules: AppliesCPA, tax · Card network rules: AppliesLaw · Card network rules: AppliesArchitects, engineers · Card network rules: AppliesConsultants · Card network rules: AppliesCoaches · Card network rules: AppliesPlumbers · Card network rules: AppliesContractors · Card network rules: AppliesReal estate · Card network rules: AppliesProcessor identity checks (KYC/AML)Dental · Processor identity checks (KYC/AML): AppliesCPA, tax · Processor identity checks (KYC/AML): AppliesLaw · Processor identity checks (KYC/AML): AppliesArchitects, engineers · Processor identity checks (KYC/AML): AppliesConsultants · Processor identity checks (KYC/AML): AppliesCoaches · Processor identity checks (KYC/AML): AppliesPlumbers · Processor identity checks (KYC/AML): AppliesContractors · Processor identity checks (KYC/AML): AppliesReal estate · Processor identity checks (KYC/AML): AppliesReg E / Reg Z disputesDental · Reg E / Reg Z disputes: AppliesCPA, tax · Reg E / Reg Z disputes: AppliesLaw · Reg E / Reg Z disputes: AppliesArchitects, engineers · Reg E / Reg Z disputes: AppliesConsultants · Reg E / Reg Z disputes: AppliesCoaches · Reg E / Reg Z disputes: AppliesPlumbers · Reg E / Reg Z disputes: AppliesContractors · Reg E / Reg Z disputes: AppliesReal estate · Reg E / Reg Z disputes: AppliesState breach noticeDental · State breach notice: AppliesCPA, tax · State breach notice: AppliesLaw · State breach notice: AppliesArchitects, engineers · State breach notice: AppliesConsultants · State breach notice: AppliesCoaches · State breach notice: AppliesPlumbers · State breach notice: AppliesContractors · State breach notice: AppliesReal estate · State breach notice: AppliesNacha fraud monitoring (2026)Dental · Nacha fraud monitoring (2026): Only if…CPA, tax · Nacha fraud monitoring (2026): Only if…Law · Nacha fraud monitoring (2026): Only if…Architects, engineers · Nacha fraud monitoring (2026): Only if…Consultants · Nacha fraud monitoring (2026): Only if…Coaches · Nacha fraud monitoring (2026): Only if…Plumbers · Nacha fraud monitoring (2026): Only if…Contractors · Nacha fraud monitoring (2026): Only if…Real estate · Nacha fraud monitoring (2026): Only if…State privacy lawsDental · State privacy laws: Only if…CPA, tax · State privacy laws: Only if…Law · State privacy laws: Only if…Architects, engineers · State privacy laws: Only if…Consultants · State privacy laws: Only if…Coaches · State privacy laws: Only if…Plumbers · State privacy laws: Only if…Contractors · State privacy laws: Only if…Real estate · State privacy laws: Only if…Cyber-insurance conditionsDental · Cyber-insurance conditions: Only if…CPA, tax · Cyber-insurance conditions: Only if…Law · Cyber-insurance conditions: Only if…Architects, engineers · Cyber-insurance conditions: Only if…Consultants · Cyber-insurance conditions: Only if…Coaches · Cyber-insurance conditions: Only if…Plumbers · Cyber-insurance conditions: Only if…Contractors · Cyber-insurance conditions: Only if…Real estate · Cyber-insurance conditions: Only if…AI rules (Colorado 2027, California hiring)Dental · AI rules (Colorado 2027, California hiring): Only if…CPA, tax · AI rules (Colorado 2027, California hiring): Only if…Law · AI rules (Colorado 2027, California hiring): Only if…Architects, engineers · AI rules (Colorado 2027, California hiring): Only if…Consultants · AI rules (Colorado 2027, California hiring): Only if…Coaches · AI rules (Colorado 2027, California hiring): Only if…Plumbers · AI rules (Colorado 2027, California hiring): Only if…Contractors · AI rules (Colorado 2027, California hiring): Only if…Real estate · AI rules (Colorado 2027, California hiring): Only if…. Housing decisions are covered in Colorado from 2027.FTC Safeguards RuleDental · FTC Safeguards Rule: RarelyCPA, tax · FTC Safeguards Rule: Applies. Tax preparers are named by the FTC.Law · FTC Safeguards Rule: RarelyArchitects, engineers · FTC Safeguards Rule: RarelyConsultants · FTC Safeguards Rule: Only if…. If you give financial advice or credit counseling.Coaches · FTC Safeguards Rule: RarelyPlumbers · FTC Safeguards Rule: RarelyContractors · FTC Safeguards Rule: RarelyReal estate · FTC Safeguards Rule: Only if…. If you also broker mortgages.IRS data-security plan (Pub 4557)Dental · IRS data-security plan (Pub 4557): RarelyCPA, tax · IRS data-security plan (Pub 4557): Applies. Written plan expected of every paid preparer.Law · IRS data-security plan (Pub 4557): Only if…. Only if you prepare returns.Architects, engineers · IRS data-security plan (Pub 4557): RarelyConsultants · IRS data-security plan (Pub 4557): RarelyCoaches · IRS data-security plan (Pub 4557): RarelyPlumbers · IRS data-security plan (Pub 4557): RarelyContractors · IRS data-security plan (Pub 4557): RarelyReal estate · IRS data-security plan (Pub 4557): RarelyHIPAADental · HIPAA: Applies. Covered entity: Privacy, Security and Breach rules.CPA, tax · HIPAA: Only if…. Only as a business associate of a health client.Law · HIPAA: Only if…. Only as a business associate of a health client.Architects, engineers · HIPAA: RarelyConsultants · HIPAA: Only if…. If you handle a health client's patient data.Coaches · HIPAA: RarelyPlumbers · HIPAA: RarelyContractors · HIPAA: RarelyReal estate · HIPAA: RarelyWhich rules apply, phone layoutDENCPALAWA/ECONCOAPLUGCREPCI DSSDental · PCI DSS (SAQ): AppliesCPA, tax · PCI DSS (SAQ): AppliesLaw · PCI DSS (SAQ): AppliesArchitects, engineers · PCI DSS (SAQ): AppliesConsultants · PCI DSS (SAQ): AppliesCoaches · PCI DSS (SAQ): AppliesPlumbers · PCI DSS (SAQ): AppliesContractors · PCI DSS (SAQ): AppliesReal estate · PCI DSS (SAQ): AppliesCard network rulesDental · Card network rules: AppliesCPA, tax · Card network rules: AppliesLaw · Card network rules: AppliesArchitects, engineers · Card network rules: AppliesConsultants · Card network rules: AppliesCoaches · Card network rules: AppliesPlumbers · Card network rules: AppliesContractors · Card network rules: AppliesReal estate · Card network rules: AppliesProcessor identity checksDental · Processor identity checks (KYC/AML): AppliesCPA, tax · Processor identity checks (KYC/AML): AppliesLaw · Processor identity checks (KYC/AML): AppliesArchitects, engineers · Processor identity checks (KYC/AML): AppliesConsultants · Processor identity checks (KYC/AML): AppliesCoaches · Processor identity checks (KYC/AML): AppliesPlumbers · Processor identity checks (KYC/AML): AppliesContractors · Processor identity checks (KYC/AML): AppliesReal estate · Processor identity checks (KYC/AML): AppliesReg E / Reg Z disputesDental · Reg E / Reg Z disputes: AppliesCPA, tax · Reg E / Reg Z disputes: AppliesLaw · Reg E / Reg Z disputes: AppliesArchitects, engineers · Reg E / Reg Z disputes: AppliesConsultants · Reg E / Reg Z disputes: AppliesCoaches · Reg E / Reg Z disputes: AppliesPlumbers · Reg E / Reg Z disputes: AppliesContractors · Reg E / Reg Z disputes: AppliesReal estate · Reg E / Reg Z disputes: AppliesState breach noticeDental · State breach notice: AppliesCPA, tax · State breach notice: AppliesLaw · State breach notice: AppliesArchitects, engineers · State breach notice: AppliesConsultants · State breach notice: AppliesCoaches · State breach notice: AppliesPlumbers · State breach notice: AppliesContractors · State breach notice: AppliesReal estate · State breach notice: AppliesNacha fraud monitoringDental · Nacha fraud monitoring (2026): Only if…CPA, tax · Nacha fraud monitoring (2026): Only if…Law · Nacha fraud monitoring (2026): Only if…Architects, engineers · Nacha fraud monitoring (2026): Only if…Consultants · Nacha fraud monitoring (2026): Only if…Coaches · Nacha fraud monitoring (2026): Only if…Plumbers · Nacha fraud monitoring (2026): Only if…Contractors · Nacha fraud monitoring (2026): Only if…Real estate · Nacha fraud monitoring (2026): Only if…State privacy lawsDental · State privacy laws: Only if…CPA, tax · State privacy laws: Only if…Law · State privacy laws: Only if…Architects, engineers · State privacy laws: Only if…Consultants · State privacy laws: Only if…Coaches · State privacy laws: Only if…Plumbers · State privacy laws: Only if…Contractors · State privacy laws: Only if…Real estate · State privacy laws: Only if…Cyber-insurance conditionsDental · Cyber-insurance conditions: Only if…CPA, tax · Cyber-insurance conditions: Only if…Law · Cyber-insurance conditions: Only if…Architects, engineers · Cyber-insurance conditions: Only if…Consultants · Cyber-insurance conditions: Only if…Coaches · Cyber-insurance conditions: Only if…Plumbers · Cyber-insurance conditions: Only if…Contractors · Cyber-insurance conditions: Only if…Real estate · Cyber-insurance conditions: Only if…AI rulesDental · AI rules (Colorado 2027, California hiring): Only if…CPA, tax · AI rules (Colorado 2027, California hiring): Only if…Law · AI rules (Colorado 2027, California hiring): Only if…Architects, engineers · AI rules (Colorado 2027, California hiring): Only if…Consultants · AI rules (Colorado 2027, California hiring): Only if…Coaches · AI rules (Colorado 2027, California hiring): Only if…Plumbers · AI rules (Colorado 2027, California hiring): Only if…Contractors · AI rules (Colorado 2027, California hiring): Only if…Real estate · AI rules (Colorado 2027, California hiring): Only if…. Housing decisions are covered in Colorado from 2027.FTC Safeguards RuleDental · FTC Safeguards Rule: RarelyCPA, tax · FTC Safeguards Rule: Applies. Tax preparers are named by the FTC.Law · FTC Safeguards Rule: RarelyArchitects, engineers · FTC Safeguards Rule: RarelyConsultants · FTC Safeguards Rule: Only if…. If you give financial advice or credit counseling.Coaches · FTC Safeguards Rule: RarelyPlumbers · FTC Safeguards Rule: RarelyContractors · FTC Safeguards Rule: RarelyReal estate · FTC Safeguards Rule: Only if…. If you also broker mortgages.IRS data-security planDental · IRS data-security plan (Pub 4557): RarelyCPA, tax · IRS data-security plan (Pub 4557): Applies. Written plan expected of every paid preparer.Law · IRS data-security plan (Pub 4557): Only if…. Only if you prepare returns.Architects, engineers · IRS data-security plan (Pub 4557): RarelyConsultants · IRS data-security plan (Pub 4557): RarelyCoaches · IRS data-security plan (Pub 4557): RarelyPlumbers · IRS data-security plan (Pub 4557): RarelyContractors · IRS data-security plan (Pub 4557): RarelyReal estate · IRS data-security plan (Pub 4557): RarelyHIPAADental · HIPAA: Applies. Covered entity: Privacy, Security and Breach rules.CPA, tax · HIPAA: Only if…. Only as a business associate of a health client.Law · HIPAA: Only if…. Only as a business associate of a health client.Architects, engineers · HIPAA: RarelyConsultants · HIPAA: Only if…. If you handle a health client's patient data.Coaches · HIPAA: RarelyPlumbers · HIPAA: RarelyContractors · HIPAA: RarelyReal estate · HIPAA: Rarely
    AppliesOnly if a condition holds (hover for it)Rarely appliesDEN dental · CPA tax · LAW law firms · A/E architects, engineers · CON consultants · COA coaches · PLU plumbers · GC contractors · RE real estate

    Hover or tap a mark for the condition. This is our reading of each rule’s scope, not a legal finding. Sources in each section below.

    Picker and estimate · your numbers

    Which rules apply to me, and what do they cost?

    Your business

    Start from a firm size

    Tap any that are true

    Assumptions. Yearly hours: SAQ 3, breach plan and privacy notice 3, training 1 a person, tax security plan 6, HIPAA review 10, AI notices 4. Cash: MFA and device tools $8 a person a month; cyber insurance $900 + $250 a person. Extras: website scans $300, full Safeguards testing $9,000, California program $10,000. All are ForeGaze assumptions, not quotes. Leaves out lawyers, breach costs and fines.

    2 · The thesis, tested

    Is the trust in payments earned? Mostly, because the rules put loss where it can be stopped

    This series tests a claim: payments stayed fairly safe while breaches hit firms everywhere else. Part 1 of this series covers fraud rates. Here we ask what the rules do.

    WorksWho pays first

    The bank, within days

    • Reg E gives banks 10 business days to investigate a debit dispute (Reg E, 12 CFR 1005.11).
    • Reg Z bars card issuers from collecting a disputed charge until it is resolved (Reg Z, 12 CFR 1026.13).
    • Customers pay without fear, so they keep paying by card.
    WorksNetwork policing

    1.5% is the line

    • Visa flags merchants whose fraud reports plus disputes reach 150 basis points (1.5%) of online transactions, from 1 Apr 2026 (Visa fact sheet).
    • Mastercard’s Excessive Chargeback Program uses the same 1.5% line, with 100 or more chargebacks a month, per a processor’s documentation updated Oct 2025 (Nuvei; secondary, not Mastercard’s own page).
    • Your processor enforces it, and may set stricter limits it does not publish.
    MixedCyber claims, 2025

    0.96 claims per 100 policies

    • 56,323 claims on 5.84 million US policies, up 20% in a year, per the National Association of Insurance Commissioners (NAIC 2026 report).
    • Average small-firm claim fell 34%; middle-market claims rose 23%.
    • Results for 2025, not forecasts.
    FailsOutside the card rails

    192.7 million people

    • Affected by the Change Healthcare attack, as of 31 Jul 2025 (HHS OCR).
    • A health clearinghouse, not a card processor.
    • Payment rules did not reach the data around the payment.

    Our reading. Card rules work because each layer carries a cost it can control. Data rules outside payments rely on notice after the fact. That gap is where small firms get hurt.

    Next in the Trust series: Built to Be Trusted: High-Trust Architecture for a Small Firm wires these controls together. After it come What AI Can Learn From Payments; Safe, Private and Personal AI: a New Small-Business Type; and Robots and Your Business.

    3 · PCI DSS v4.0.1 · US and Canada

    One standard, nine questionnaires; most small firms need the short one

    PCI DSS (Payment Card Industry Data Security Standard) is the card industry’s security standard. Version 4.0 retired on 31 Dec 2024, leaving v4.0.1 (PCI SSC bulletin, 15 Oct 2024).

    What changed on 31 Mar 2025
    • 51 future-dated requirements of the 64 new ones in v4.0 became mandatory (PCI SSC, 20 Aug 2024).
    • Online merchants on SAQ A must run quarterly outside scans by an Approved Scanning Vendor (ASV), or show their provider does.
    • Payment-page script rules (6.4.3, 11.6.1) left SAQ A. Instead you confirm your site is not open to script attacks (PCI SSC, 26 Mar 2025).
    • Hosted pages help. You may rely on a compliant provider’s embedded payment frame, set up as it instructs.

    Skipping it costs money. One law-practice processor charges $19.95 a month after six months without a filed SAQ: $239.40 a year.

    SAQFits a firm that…Typical trade
    ATakes cards online or by phone, fully outsourced; no card data on its systemsCoaches, consultants, invoice links
    A-EPHas a website that shapes the payment page but never receives card dataCustom booking sites
    B-IPUses standalone approved terminals on its own network linkFront desk
    C-VTKeys cards one at a time into a web virtual terminal on an isolated computerPhone payments
    P2PEUses only listed point-to-point encrypted terminalsDental, retail counters
    SPoCUses a phone or tablet with a listed secure card readerPlumbers, contractors in the field
    DFits no other SAQ, or stores card dataAvoid this if you can
    Also B (dial-out terminals) and C (connected point-of-sale). Descriptions from the SAQ Instructions and Guidelines, Apr 2025 (acquirer-hosted copy). Your acquirer or processor decides which you file.
    4 · Card network rules · US and Canada

    The networks police the big merchants; your processor polices you

    Visa’s program counts fraud reports plus disputes against the number of online card transactions. Its count floor is far above a small firm’s volume.

    Figure 2 · card transactions a month, log scale · US and Canada · Visa 2025, Mastercard 2025

    Visa’s floor needs 100,000 online sales a month; a coach at 300 sits 333 times below it.

    Visa VAMP floor (150 bps, from Apr 2026)Visa VAMP floor (150 bps, from Apr 2026): 100,000 card transactions a month100,000Visa VAMP floor (220 bps, Jun 2025–Mar 2026)Visa VAMP floor (220 bps, Jun 2025–Mar 2026): 68,182 card transactions a month68,182Mastercard HECM floor (300 bps, 2025)Mastercard HECM floor (300 bps, 2025): 10,000 card transactions a month10,000Mastercard ECM floor (150 bps, 2025)Mastercard ECM floor (150 bps, 2025): 6,667 card transactions a month6,667Coach: $50 sessions, $15,000 a monthCoach: $50 sessions, $15,000 a month: 300 card transactions a month300~5-staff firm: $40,000 a month, $2,500 average~5-staff firm: $40,000 a month, $2,500 average: 16 card transactions a month16~20-staff firm: $150,000 a month, $6,000 average~20-staff firm: $150,000 a month, $6,000 average: 25 card transactions a month25110010,000100,000
    Visa floorMastercard floorExample small firms

    Floor = minimum monthly fraud and disputes ÷ ratio line. Visa: 1,500 ÷ 1.5% = 100,000 (68,182 at the old 2.2%). Mastercard ECM: 100 ÷ 1.5% = 6,667. ECM and HECM are Mastercard’s “excessive” and “high excessive” chargeback levels. Examples are illustrations. Sources: Visa fact sheet; Nuvei documentation of the Mastercard program, modified 21 Oct 2025; read 24 Oct 2026.

    What it means at small-firm size
    • Visa cut its line by 70 basis points on 1 Apr 2026, to 1.5%. The count floor of 1,500 a month stayed.
    • A coach with 300 sales a month at 1.5% has about 4.5 disputes. No network program sees that.
    • Your processor does. Stripe’s agreement lets it suspend an account where activity may raise fraud risk (Stripe Services Agreement). Processor limits are not published.
    • Mastercard’s lines are a processor’s description. A processor’s Oct 2025 documentation gives 100 chargebacks and 1.5%. Mastercard’s own rules page (Mastercard rules) was not readable by our tools, so confirm with your processor.
    Holds, reserves and payouts in The Small Print →
    5 · Nacha 2026 · US

    Bank transfers now need fraud monitoring by everyone who sends them

    Nacha writes the rules for ACH, the US bank-transfer network. Its 2026 rules require risk-based checks for fake or tricked payments (Nacha).

    In forcePhase 1 · 20 Mar 2026

    Banks and big senders

    • All originating banks (ODFIs).
    • Business originators and processors that sent 6 million or more entries in 2023.
    • Receiving banks that took 10 million or more entries in 2023.
    In forcePhase 2 · 22 Jun 2026

    Every business originator

    • Rule date 19 Jun 2026, a federal holiday, so in practice 22 Jun. No volume threshold.
    • Covers payments that are unauthorized or sent under false pretenses, such as invoice scams.
    • Review the process at least once a year.
    Your caseThrough software

    Ask your platform

    • If you pay staff or vendors by ACH from your own bank, you are likely the originator.
    • If your software collects ACH for you, it may carry the duty. Who is the originator depends on your agreement with the platform, and the rules do not settle it for you. Ask in writing.
    • Nacha says you need not screen every payment, but you need a risk assessment.
    6 · Reg E and Reg Z · US

    Your customer’s dispute rights run on a federal clock

    Reg Z covers credit cards. Reg E covers debit cards, ACH and payment apps. Both bind the bank; you feel them as chargebacks and returns.

    Figure 3 · time limits, calendar days · US · 12 CFR 1005.11 and 1026.13

    Customers get 60 days to report; banks get from 10 business days up to 90 days to answer.

    Reg Z (credit card)Customer reportsReg Z (credit card) · Customer reports: 60 days60 daysIssuer acknowledgesReg Z (credit card) · Issuer acknowledges: 30 days30 daysIssuer resolves, at mostReg Z (credit card) · Issuer resolves, at most: 90 days90 daysReg E (debit, ACH, apps)Customer reportsReg E (debit, ACH, apps) · Customer reports: 60 days60 daysBank investigates (10 business days)Reg E (debit, ACH, apps) · Bank investigates (10 business days): ~14 days~14 daysWith provisional creditReg E (debit, ACH, apps) · With provisional credit: 45 days45 daysPoint-of-sale debit, new accountsReg E (debit, ACH, apps) · Point-of-sale debit, new accounts: 90 days90 days0306090
    Customer’s windowFirst deadlineLongest deadline

    10 business days shown as about 14 calendar days (10 × 7 ÷ 5). Sources: Reg E, 12 CFR 1005.11; Reg Z, 12 CFR 1026.13; read 23 Oct 2026.

    What you owe
    • Nothing directly. These rules bind banks and card issuers, not merchants.
    • Evidence, fast. The bank must decide within its clock, so answer chargeback notices quickly with receipts and signed scopes.
    • Provisional credit. If a bank needs more than 10 business days on a debit dispute, it credits the customer first.
    • Card network deadlines for filing a chargeback were not on a page we could read; we leave them out.
    7 · KYC and anti-money-laundering (AML) checks at the processor · US

    Why accounts get frozen: the processor must know you, and can stop paying out

    Banks owe anti-money-laundering checks under federal law. Processors pass them to you as document requests and account reviews.

    Stripe supportAccount reviews

    “A required step”

    • Stripe calls reviews a condition of processing; it cites no law (Stripe support).
    • It may ask for recent supplier orders or dated inventory photos.
    • It warns that a slow reply can affect your business.
    TermsHolds and reserves

    Up to 180 days

    • PayPal may hold funds up to 180 days; risk holds generally last up to 21 days.
    • Square may add a reserve when sales come in irregular bursts.
    • Read by ForeGaze for a sibling post, 23 Oct 2026.
    Law-firm reportOwnership filing

    US firms exempt

    • FinCEN’s interim rule of 21 Mar 2025 exempts US-formed companies from ownership reports (Greenberg Traurig, 26 Mar 2025).
    • Your processor can still ask who owns you.
    • Whether a final rule followed is unconfirmed.

    Avoidable triggers. A sudden jump in volume, a new kind of sale, or prepayments far ahead of the work. Tell your processor before a big month. Keep a second way to get paid.

    8 · Data rules · US (California called out)

    Breach notice reaches everyone; the security plans depend on your trade

    Payment rules protect the card. Data rules protect everything around it: client files, tax returns and patient charts.

    Figure 4 · US jurisdictions by deadline to notify individuals · Privacy Rights Clearinghouse, 28 Jan 2026

    After a data breach, 20 of 51 jurisdictions (50 states and, likely, DC) give a fixed 30–60 days to tell the people affected; California is one of five at 30 days.

    30 days30 days: 5 jurisdictions (CA, CO, FL, NY, WA)5CA · CO · FL · NY · WA45 days45 days: 10 jurisdictions (AL, AZ, IN, NM, OH, OR, RI, TN, VT, WI)10AL · AZ · IN · NM · OHOR · RI · TN · VT · WI60 days60 days: 5 jurisdictions (CT, DE, LA, SD, TX)5CT · DE · LA · SD · TXNo fixed numberNo fixed number: 31 jurisdictions31Federal clocks on top of state lawFTC Safeguards (500+ people)FTC Safeguards (500+ people): 30 days30 daysHIPAA (individuals, at most)HIPAA (individuals, at most): 60 days60 days
    State, fixed deadlineNo fixed numberFederal rule

    A non-profit’s survey, not statute text; the 51 likely include DC. California’s 30-day deadline is in Civil Code §1798.82(a)(2), as amended by SB 446 (Chapter 319, approved 3 Oct 2025), in force 1 Jan 2026 (Troutman Privacy, Oct 2025). It can be delayed for law enforcement or to scope the breach. With more than 500 residents affected, a sample notice goes to the Attorney General within 15 days of notifying them. Sources: Privacy Rights Clearinghouse, 28 Jan 2026; FTC business guide; HHS breach guidance.

    By rule
    • FTC Safeguards Rule. Tax preparers and other non-bank financial firms need a written security program, MFA and encryption (FTC business guide). Report a breach of 500+ people to the FTC within 30 days.
    • Under 5,000 consumers, the written risk assessment, penetration tests (paid break-in tests), written incident plan and board report do not apply.
    • IRS. Paid preparers must keep a written security plan; the application for a preparer tax ID (PTIN, Form W-12) asks you to confirm it (IRS). Pub 5708 is a free sample plan.
    • HIPAA. Notify patients within 60 days of finding a breach. The Security Rule update is now targeted for July 2027 (Alston & Bird, 10 Jul 2026).
    • State privacy laws. 24 states have one, not all in force yet (Husch Blackwell, 29 Jun 2026). California’s starts at $26,625,000 revenue (CPPA FAQ).
    • Texas is the exception. It has no revenue line; firms that are small under federal SBA size standards are exempt, but must get consent before selling sensitive data (Texas Attorney General).
    Your data and who else sees it, in The Small Print →
    9 · Cyber insurance · US

    Cyber insurance is a contract with its own rules; read the controls it assumes

    What it is: a policy that pays some costs after a hack or data breach, such as forensics, notifying customers, legal defense, restoring systems and sometimes ransom or lost income. Many policies limit or exclude payment scams where you sent the money yourself. It is not required by law. But insurers set conditions, and a claim can fail if the controls you declared were not in place.

    Figure 5 · average claim, US$ · US · NAIC, 2025 results

    The average small-firm claim fell 34% in 2025, while middle-market claims rose 23%.

    Small and mid-sized firms2024Small and mid-sized firms, 2024: about $215,000 per claim$215,0002025Small and mid-sized firms, 2025: about $142,000 per claim$142,000Middle market2024Middle market, 2024: about $619,000 per claim$619,0002025Middle market, 2025: about $759,000 per claim$759,000
    20242025

    Severity figures as quoted in the NAIC report, rounded. Premiums grew 3.5% to about $9.46 billion. Source: NAIC 2026 report, read 23 Oct 2026.

    What insurers ask for
    • MFA everywhere. An IT provider for dental offices calls its absence a near-automatic refusal (secondary report).
    • Endpoint protection (EDR), offline backups with a tested restore, and a written incident plan.
    • Payment verification by a second channel. The NAIC says deepfake fraud puts renewed weight on it.
    • Few small firms buy cyber insurance. The NAIC, citing the Swiss Re Institute, estimates small and mid-sized firm take-up at 10% to 20%.
    10 · AI rules now in force · US (EU as context)

    AI rules reach small firms through hiring and big decisions

    No US law bans a small firm from using AI. The duties start when AI shapes who gets a job, a loan, a lease or care.

    Law-firm reportColorado

    From 1 Jan 2027, notice-based

    • SB 26-189, signed 14 May 2026, replaced the 2024 law (Holland & Knight, 18 May 2026).
    • Tell people before AI materially shapes a consequential decision; explain bad outcomes; keep records 3 years.
    • The start moved 185 days, from 30 Jun 2026 to 1 Jan 2027: 70 days after 23 Oct 2026.
    Law-firm reportCalifornia hiring

    In force since 1 Oct 2025

    • Civil Rights Council rules on automated decision systems in hiring (Mayer Brown, 2 Sep 2025).
    • Keep hiring records, including AI data, for 4 years.
    • Anti-bias testing helps your defense; vendors can count as your agent.
    CPPACalifornia ADMT

    Only CCPA-sized firms

    • Rules on automated decision-making technology (ADMT) took effect 1 Jan 2026 (CPPA).
    • Existing uses must comply by 1 Jan 2027 (Future of Privacy Forum brief).
    • Below $26,625,000 revenue, most small firms are outside.
    ContextEU AI Act

    High-risk rules delayed 16 months (EU AI Act; Future of Privacy Forum, Jul 2026, secondary)

    Court note. A federal court order of 27 Apr 2026 paused enforcement of Colorado’s 2024 law, after a lawsuit (JD Supra, 28 May 2026). The lawsuit’s claims are allegations, not findings.

    11 · Dates · US (EU as context)

    13 deadlines have passed; 5 are still ahead

    Filled dots are in force. Hollow dots are scheduled, and schedules have slipped before.

    Figure 6 · compliance dates · US, EU context · 2024–2028

    Card and bank-transfer rules are done; the open dates are data and AI rules.

    31 Mar 2024: PCI DSS v3.2.1 retired (in force)31 Mar 2024PCI DSS v3.2.1 retiredMay 2024: FTC breach notice duty begins (in force)May 2024FTC breach notice duty begins1 Jul 2024: Texas privacy law in force (in force)1 Jul 2024Texas privacy law in force31 Dec 2024: PCI DSS v4.0 retired; v4.0.1 only (in force)31 Dec 2024PCI DSS v4.0 retired; v4.0.1 only21 Mar 2025: US firms exempted from ownership filing (in force)21 Mar 2025US firms exempted from ownership filing31 Mar 2025: PCI future-dated requirements apply (in force)31 Mar 2025PCI future-dated requirements apply1 Jun 2025: Visa dispute program (VAMP) starts (in force)1 Jun 2025Visa dispute program (VAMP) starts1 Oct 2025: California AI-in-hiring rules (in force)1 Oct 2025California AI-in-hiring rules1 Jan 2026: California ADMT rules effective (in force)1 Jan 2026California ADMT rules effective20 Mar 2026: Nacha fraud monitoring, phase 1 (in force)20 Mar 2026Nacha fraud monitoring, phase 11 Apr 2026: Visa threshold falls to 150 bps (in force)1 Apr 2026Visa threshold falls to 150 bps22 Jun 2026: Nacha phase 2: all business originators (in force)22 Jun 2026Nacha phase 2: all business originators2 Aug 2026: EU AI Act transparency (context) (in force)2 Aug 2026EU AI Act transparency (context)today, 23 Oct 20261 Jan 2027: Colorado AI law; California ADMT duties (scheduled)1 Jan 2027Colorado AI law; California ADMT dutiesJul 2027: HIPAA Security Rule update, target (scheduled)Jul 2027HIPAA Security Rule update, target2 Dec 2027: EU high-risk AI rules (context) (scheduled)2 Dec 2027EU high-risk AI rules (context)31 Dec 2027: California risk assessments due (scheduled)31 Dec 2027California risk assessments due1 Apr 2028: California first audits and filings (scheduled)1 Apr 2028California first audits and filings
    CardsBank transfers, identityData and privacyAIScheduled, not yet in force

    Dates from the sources in each section. The HIPAA and Colorado dates come from law-firm reports. Read 23 Oct 2026.

    12 · Cost of compliance · US

    The basics cost a few thousand dollars a year, mostly your time and insurance

    These are ForeGaze estimates, not quotes. Change the inputs in the picker above to use your own numbers.

    Figure 7 · estimated yearly cost, US$ · ForeGaze estimate · Oct 2026

    At ~5 people: dental $4,205, tax practice $3,905, plumber $3,455 a year.

    DentalSoloDental, Solo: Your time $1,275Dental, Solo: Security tools $96Dental, Solo: Cyber insurance $1,150$2,521~5 peopleDental, ~5 people: Your time $1,575Dental, ~5 people: Security tools $480Dental, ~5 people: Cyber insurance $2,150$4,205~20 peopleDental, ~20 people: Your time $2,700Dental, ~20 people: Security tools $1,920Dental, ~20 people: Cyber insurance $5,900$10,520CPA, taxSoloCPA, tax, Solo: Your time $975CPA, tax, Solo: Security tools $96CPA, tax, Solo: Cyber insurance $1,150$2,221~5 peopleCPA, tax, ~5 people: Your time $1,275CPA, tax, ~5 people: Security tools $480CPA, tax, ~5 people: Cyber insurance $2,150$3,905~20 peopleCPA, tax, ~20 people: Your time $2,400CPA, tax, ~20 people: Security tools $1,920CPA, tax, ~20 people: Cyber insurance $5,900$10,220PlumberSoloPlumber, Solo: Your time $525Plumber, Solo: Security tools $96Plumber, Solo: Cyber insurance $1,150$1,771~5 peoplePlumber, ~5 people: Your time $825Plumber, ~5 people: Security tools $480Plumber, ~5 people: Cyber insurance $2,150$3,455~20 peoplePlumber, ~20 people: Your time $1,950Plumber, ~20 people: Security tools $1,920Plumber, ~20 people: Cyber insurance $5,900$9,770
    Your timeSecurity toolsCyber insurance

    Bars read left to right: your time, tools, insurance. Hours × $75, plus $8 a person a month for MFA tools, plus cyber insurance at $900 + $250 a person. Dental adds 10 HIPAA hours; tax adds 6 plan hours.

    FirmSolo~5~20
    Dental$2,521$4,205$10,520
    CPA, tax$2,221$3,905$10,220
    Plumber (and most other trades)$1,771$3,455$9,770
    First year adds $1,200 for dental or tax (16 set-up hours). A 20-person tax firm holding data on 5,000+ people adds about $9,000 of testing: about $19,220 in all. Per person at ~5: $691; dental $841.
    13 · In Canada

    Canada: same card rules, different privacy law

    PCI DSS and Visa’s program apply in Canada as in the US. Privacy and breach duties come from federal and Quebec law.

    OPCPIPEDA

    Report real risk of significant harm

    • Report to the Privacy Commissioner and tell affected people as soon as feasible (Office of the Privacy Commissioner).
    • Keep a record of every breach for two years, harmful or not.
    • Knowingly failing is an offense.
    Law-firm reportQuebec Law 25

    Up to C$25M or 4%

    • Name a person in charge; report incidents with a risk of serious injury; keep a register (Blakes).
    • Penalties up to C$10M or 2%; fines up to C$25M or 4% of worldwide turnover (McCarthy Tétrault, 3 Feb 2026).
    • The 4% bites only above C$625 million turnover.
    ProposedBill C-36

    Would amend PIPEDA

    • Introduced 15 Jun 2026 (ISED, 15 Jun 2026).
    • Penalties up to C$10M or 3%; fines up to C$25M or 5%.
    • Status since introduction is unconfirmed.
    14 · What to do

    Six steps, in order

    1. File your SAQ. Ask your processor which one applies, and avoid storing card numbers anywhere.
    2. Turn on MFA for email, banking, your processor and your practice software.
    3. Write a one-page breach plan: who decides, who to call, and the 30-day clocks (FTC, five states).
    4. Tax preparers: finish your written security plan from IRS Pub 5708. Dental: update your HIPAA risk analysis.
    5. Answer processor requests the same day, and warn them before an unusually large month.
    6. List your AI tools. If one screens applicants or customers, plan notices for Colorado and records for California.
    15 · Gaps

    What this research did not cover

    These are open, not answered.

    • IRS Publication 4557 text, and the IRS steps for reporting data theft.
    • Visa and Mastercard time limits for filing a chargeback; Mastercard’s own current program page (a processor’s documentation was used). Mastercard is replacing these programs with a new audit program from April 2027, with a lower ECM ratio line (industry summary: Chargeback Gurus).
    • Processor dispute-rate limits and official complaint counts about frozen accounts.
    • Other states’ small-business privacy exemptions.
    • Cyber premiums by firm size from an official dataset.
    • Alberta and BC private-sector privacy laws; Canadian card-network differences.
    • State rules for lawyers (trust accounts) and licensing boards; not in scope here.
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