Congress quietly narrows credit card competition to protect big networks
S. 3623 — Credit Card Competition Act of 2026 · Filed by Roger Marshall (R-KS) · 5 cosponsors · Introduced Jan 13, 2026 · Referred to committee
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What it does
This bill requires large credit card issuers (those with over $100 billion in assets) and payment networks to stop forcing merchants and cardholders to use only one or two specific payment networks. Instead, merchants must be allowed to route credit card transactions through any available network, and card issuers cannot penalize merchants for choosing cheaper or faster networks. The bill exempts networks deemed national security risks and three-party systems (like American Express), and gives the Federal Reserve one year to write the rules.
Why we flagged it
The bill's core function is to mandate competition in credit card routing by prohibiting exclusive network agreements and routing restrictions. It is fundamentally a deregulation measure that removes contractual barriers between networks and merchants, framed as pro-competition but with significant carve-outs.
What the text implies
- The $100 billion asset threshold exempts most regional and mid-size card issuers, potentially creating a two-tier system where only the largest players face routing competition, limiting the bill's competitive reach.
- The national security carve-out allows the Federal Reserve to exempt foreign payment networks from routing requirements without transparent criteria, potentially protecting domestic networks from international competition.
The full analysis lists 5 implications of this text.
Who stands to gain
Merchants and payment processors (lower routing fees); Smaller payment networks (access to larger issuer networks); Fintech payment platforms (routing flexibility)