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Ensignbus £10 contactless limit and Apple Pay / Google Pay ban

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DelayRepay

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I think there are some important points to be raised here:

Firstly, how many average customers even know that there is a Transit Mode, or if they do, how it works? I'd be fairly confident in assuming most people just know that they won't be asked for their pin, because there aren't pin pads. I find people who are still confused when they get asked to enter their pin on the random "is it still you" checks. As a result of which, is this issuing of season tickets using contactless simply to save drivers getting into "why can I pay for £100 quid's worth of groceries with contactless but not £80 quid for a bus pass" arguments?

Secondly, has the Transit mode framework been updated since the substantial rise in contactless limits over the last few years? the division of risk seems fairly fair when the limit was £30, but if the downloadable document mentioned upthread is anything to go by, it hasn't been updated since the rise first to £45, then £100.
I don't think customers know, or need to know the mechanics of Transit mode.

I don't think the £10 cap needs to be updated. The fact that contactless limits have increased since is not relevant, because those limits apply to purchases, not transit mode transactions.

Transit Mode is designed for low value transactions (hence the bank accepting liability up to £10). It's not intended to be used to purchase goods, which is effectively what a season ticket is. The bus company are using it in a way that it's not intended to be used, which why they are suffering fraud. Purchases are subject to a different liability framework, but have to be processed through an on-line terminal which can seek authorisation. If the £10 limit was updated, then that would mean the banks being liable for the bus company's failings - doesn't seem fair to me.

However, I still find it odd that there's such a large black market for fraudulently obtained season tickets in Essex. I wonder if all of these season tickets are actually being sold on and used.
 
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Cloud Strife

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However, I still find it odd that there's such a large black market for fraudulently obtained season tickets in Essex.

This is Essex we're speaking about! I used to live next to a particularly interesting council estate pub, and the landlord had a lovely pirate DVD business on the side.
 
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omnicity4659

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With Ensignbus banning Monzo and Revolut cards, even after the £10 limit, then that narrows it down to the fraudulent use of Virtual Cards.

You don't have to have money on any card to be able to pay for a bus ticket from a Ticketer machine due to the delay in processing, but with a conventional card it will still deduct money and put you into your overdraft. However, with a virtual card, you can simply delete it after "payment" and there would be no impact on yourself.

I can't imagine that the number of people doing this would be significant, unless Ensignbus happen to have loads of customers who pay for a Monzo Plus subscription... Judging by the numbers who have taken up Monzo Plus nationally, and Ensignbus' limited network of services, this is probably caused by one or two people.

The solution would be to work with Ticketer to implement instant authorisation of payments. Having worked with the likes of SumUp readers in the past which are just as remote, but authorise payment instantly, I can't see why Ticketer have done it differently.
 
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Bletchleyite

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Nothing takes payment instantly, but it would certainly be possible to do an authorisation for these high value tickets. It is a misuse of transit mode to work in this way anyway, transit mode is intended for low value tickets hence the £10.

Another option would be to cease sale of season tickets on board, or look to replace them with capping.
 

omnicity4659

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Nothing takes payment instantly, but it would certainly be possible to do an authorisation for these high value tickets. It is a misuse of transit mode to work in this way anyway, transit mode is intended for low value tickets hence the £10.

Another option would be to cease sale of season tickets on board, or look to replace them with capping.
That's what I meant, apologies.

But yeah, it should be the case that on buses where the fare isn't variable based on tapping and capping, that any amount should be authorised immediately. I believe Ticketer does this anyway for higher value tickets.

It seems like the £10 limit on Ensignbus was a kneejerk reaction to something they didn't yet understand.
 

Cesarcollie

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That's what I meant, apologies.

But yeah, it should be the case that on buses where the fare isn't variable based on tapping and capping, that any amount should be authorised immediately. I believe Ticketer does this anyway for higher value tickets.

It seems like the £10 limit on Ensignbus was a kneejerk reaction to something they didn't yet understand.

No bus ticket machine works any differently as far as I know. Combination of signal and speed. Ticketer certainly doesn’t for any value of ticket.
 

crablab

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Is blocking specific banks not definitely a breach of merchant agreement?
Yes. For Mastercard, it is a requirement that Acquirers accept all valid Mastercards irrespective of product or issuer.

So it must be something to do with chargebacks happening that wouldn't be able to happen with an actual card.
If the transaction is not identified properly as a transit transaction, then the Acquirer would be liable for a 4808 if the issuer is unable to honour the Presentment (because there is subsequently no money left in the account - card - and the account has been closed).

It is also possible that 4808s are being raised where there is a valid Second Presentment condition (ie. they were properly identified), but the Acquirer and the merchant aren't correctly defending the chargeback. It is very common for Acquirers to send entirely inappropriate evidence that they've obtained from the merchant, despite having a valid Second Presentment, which then means the Acquirer loses.

and if there is a flaw in Google/Apple Pay specifically I think that very much should be public so they are forced to spend some of their massive profits fixing it quickly.
It's not really a flaw. More an unintended consequence of the way these work, it's very well known about and certain larger transit operators take significant steps to defend against it (notably by following scheme rules with regard to transaction processing)
 

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Starmill

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notably by following scheme rules with regard to transaction processing
Who would ever have thought that it might be quite important to actually follow the card scheme rules, eh!? :lol:

Certainly a lesson in there for some.
 

Cesarcollie

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Who would ever have thought that it might be quite important to actually follow the card scheme rules, eh!? :lol:

Certainly a lesson in there for some.

The cause of the original problem however was nothing to do with following the scheme rules. It was a problem caused by certain types of bank account and their interplay with EMV ‘transit’ mode, where monies are not debited instantaneously as they are (for example) in a shop.
 

Starmill

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The cause of the original problem however was nothing to do with following the scheme rules. It was a problem caused by certain types of bank account and their interplay with EMV ‘transit’ mode, where monies are not debited instantaneously as they are (for example) in a shop.
If the company had been following the rules correctly they wouldn't have been using 'transit mode' in the way they were, and as a result wouldn't have got into the mess they did.
 

Cesarcollie

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If the company had been following the rules correctly they wouldn't have been using 'transit mode' in the way they were, and as a result wouldn't have got into the mess they did.

I‘m not sure what you mean. Transit mode is what is is. Liability for declined transactions over £10 lies with the operator. It was this liability coupled with a certain client base using a certain selection of banks that caused the problem. It would be unwise of me to say more.
 

Starmill

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I‘m not sure what you mean. Transit mode is what is is. Liability for declined transactions over £10 lies with the operator. It was this liability coupled with a certain client base using a certain selection of banks that caused the problem. It would be unwise of me to say more.
I'm afraid that unless you're being deliberately misleading I don't understand where the confusion is arising from?

The company tried to sell products through transit mode which it should not have done. The sale of a season ticket costing over £10 should never have been done in this way.

They messed up, and as a result, when they were exposed to fraud, the Bank refused to accept liability, and it fell on them. As police and and CPS resources aren't adequate to allow them to persue the actual criminals, there was little defence against this risk in place for the company. It's a business risk which obviously should have been identified earlier, but wasn't.

Frustrated at this failing, and the losses which it resulted in, the company issued lots of bellicose rhetoric, which will have been taken careful note of by their genuine customers, and totally ignored by the criminals who'd taken their money. They then made changes which overtly broke the rules of the card scheme they'd freely contracted to follow.

Some people have tried to give defences of the company by suggesting it is the rules that are at fault, but several patient explanations of why this is wrong have already been made. This episode does tell us a little about the company's corporate attitudes however.

Transit mode contains a well documented and understood point of weakness. The card scheme rules protect the bank from liability arising from this weakness for transactions over £10. The company can hardly expect to be offered all of the benefits of transit mode and then have the bank accept unlimited liability for its weaknesses? Every bus company in the country faces the same conditions.

In addition, virtual cards are neither new nor rare, and their use is something which the rules take full account of.
 
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crablab

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It was a problem caused by certain types of bank account and their interplay with EMV ‘transit’ mode, where monies are not debited instantaneously as they are (for example) in a shop.
I‘m not sure what you mean. Transit mode is what is is. Liability for declined transactions over £10 lies with the operator. It was this liability coupled with a certain client base using a certain selection of banks that caused the problem. It would be unwise of me to say more.

I think the confusion may stem from a misunderstanding about how transaction processing works for dual-message system cards. It's important to note that mass transit transactions are different from a 'shop', and that's why separate processing rules are in place.

DMS cards never debit money 'instantaneously'. When you (the customer) transact with a shop, they obtain a technical authorisation with your issuer to debit your account (PAN) for up to an amount. The issuer is then guaranteeing that the acquirer (representing the merchant) will get their money at a future point in time. It is possible to adjust the authorisation amount by sending an auth advice after the initial auth, but that's a bit beyond scope here. At this point the card machine prints and reciept and you walk out of the shop with your item, but no money has changed hands.

The second part of a DMS transaction is clearing. The acquirer will submit the authorised transactions it wishes to clear to the network in a batch file - this is known as presentment. The network will then sort out who owes who what (multiple issuers, refunds etc.) and send the clearing files to the issuer, debiting their account (this is net-settlement). The issuer then sends a big CHAPS payment (or even a BoE transfer) to the network, which dishes it out to the acquirers.

There are rules about how the acquirer must present - for example, you must present within a certain timeframe (ie. the time for which you have obtained authorisation) and you must have an authorisation correctly identified and linked in the presentment.

It is of course possible to just submit presentments without authorisations - this sometimes happens for technical reasons, or if the Acquirer messes up and doesn't submit to clearing in time. Those are known as unauthorised presentments and the issuer is entirely within their rights (under scheme rules) to submit authorisation chargebacks (4808), and they will.

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So how does what people are calling 'transit mode' work? Well, the difference is that for 'transit mode' the final amount is not known.

It is helpful to think about how TfL do this, as they have implemented it very well.

When you 'tap in', TfL will authorise a small amount (10p) on the card correctly identified as a 'transit mode' transaction. This tells them that the PAN is active, the cryptogram the card generated was valid etc. They need to do this otherwise they will have no authorisation to present against, which would be against scheme rules.

When you ride around TfL you'll accrue a number of fares (and maybe hit a cap), but TfL won't submit any more auths (mostly, see below). At the end of the day, TfL calculates the total amount you owe them and takes into account any caps you've hit.

They can then submit a presentment to clearing for the total amount you owe and crucially, because they correctly identified the transaction as a mass-transit auth, they are allowed to present above the amount they authorised (ie. without authorisation) by the scheme rules. This is important because it means that even if you don't have enough money in your account with the issuer, TfL will still get their money and be protected from chargeback - the issuer takes liability.

There are various caveats to this, including the liability shift ceiling (ie. the maximum amount).

---

So, what can go wrong in 'transit mode'?

Well, if you don't identify the transaction properly as a mass-transit transaction then the rules I've described above simply don't apply.

Likewise, if the acquirer/merchant tries to present for an amount higher than the liability shift ceiling then the liability shifts back to them. TfL will re-auth your card if they think you're about to go over the ceiling, and split your fares across the auths - that's within the rules. They have some business logic about how they do this which I don't know and will be quite sensitive.

---

I don't really know what has happened in this specific situation we're discussing in the thread, mostly because I haven't read in detail about what has happened and can't see the transaction data. However, if you are selling a fixed price product (ie. a day/season ticket) then that should be authorised correctly for the full amount - not as a mass-transit transaction - and especially not if it exceeds the ceiling. If it declines, don't issue the goods as you won't be able to collect any money!

I believe the Ticketer approach is to submit separate auths for each transaction you make (ie. for each single, for example) and not batch transactions for clearing. That's a much simpler approach and is entirely within the rules AIUI. (TfL has a much cleverer system because the delay in obtaining auth for each 'tap in' at a gateline would cause serious backlogs at stations, and their gatelines need to be able to operate 'offline' at peak times).
 
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158756

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I'm still confused by this thread. Have Ensign been operating their ticket machines differently from everyone else, or is this a risk any bus company is taking by accepting card payments over £10?
 

Bletchleyite

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I'm still confused by this thread. Have Ensign been operating their ticket machines differently from everyone else, or is this a risk any bus company is taking by accepting card payments over £10?

That one.

Transit mode is not intended for the sale of season tickets. It is intended primarily for tap-in tap-out transactions like TfL's, though can also be used for traditional ticket purchase of a single or return.

It's also not really intended for high value fares like coach tickets, which these days are mostly booked online.
 

Dai Corner

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That one.

Transit mode is not intended for the sale of season tickets. It is intended primarily for tap-in tap-out transactions like TfL's, though can also be used for traditional ticket purchase of a single or return.

It's also not really intended for high value fares like coach tickets, which these days are mostly booked online.
Do/can the ticket machines differentiate between the two and use 'normal' mode instead of transit mode when appropriate?
 

Bletchleyite

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Do/can the ticket machines differentiate between the two and use 'normal' mode instead of transit mode when appropriate?

No, they don't, which is the root of the issue.

I don't know if Ticketer *can* do that or not. If it can't it's their issue. If it can it's the bus operator's issue for misconfiguring it.

There are challenges if online authorisation is required, though, as some bus routes run through areas of poor signal. I must admit I'm fairly surprised that the Ticketer machines don't come with a Chip and PIN reader for this purpose - they are small and cheap now, and if a PIN is used the rules are a bit different. It is a bit slower, I'll admit, but ideally operators need to be moving as many high value season sales online as possible anyway, so you're only needing to do a small number on-bus.
 

crablab

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I'm fairly surprised that the Ticketer machines don't come with a Chip and PIN reader for this purpose - they are small and cheap now, and if a PIN is used the rules are a bit different
There would be no difference for this purpose. A chip can authorise offline via the contactless interface, depending on issuer configuration.

Liability shift and floor limit don't change, except in the case of magstripe.

(Well, assuming you don't exceed the contactless ceiling, but the chip certainly shouldn't authorise above that anyway and if you have a Transaction Certificate you're in the clear anyway)

No, they don't, which is the root of the issue.

I don't know if Ticketer *can* do that or not. If it can't it's their issue. If it can it's the bus operator's issue for misconfiguring it.
Exactly. As I explained above, the Transaction Processing Rules are not being followed correctly.
I would suggest this is probably an issue between the acquirer (which will differ between customers) and Ticketeer, but I couldn't back that up.
 

Ken H

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@crablab How does that work if that takes someone over their credit limit. Is it somehow Ok for transit mode to push people over credit limit but not a shop?
I thought a transaction that took a card holder over credit limit would be declined.

And how does transit mode work when there is no connection from the bus ticketing gear to the card network (no mobile signal) Who takes the risk then, because there is absolutely no authorisation, even for 10p?
 

Dai Corner

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I note that my local bus company, Newport Transport, who also use Ticketer, allow on-bus transactions up to £100. They don't have chip & pin as far as I know.
 

Bletchleyite

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It makes no difference to the situation originally described, except that you cannot (shouldn't) code transactions with PIN entry as mass-transit.

True, it doesn't make a difference for the specific situation here, but it would prevent stolen or found cards being used to buy seasons.

Really the fix is to authorise transactions above £10 and secondarily to push, as far as possible, such sales online, by offering good quality apps, the sale of printable barcode tickets on the operator website etc, and ideally a small discount for choosing these options to drive passenger choice so the bus isn't delayed by carrying out those authorisations for any more than a tiny number of people. (See also Germany, where drivers do generally sell tickets and give change, but as hardly anyone buys from the driver this doesn't slow operation like it does in the UK).
 

Starmill

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There are operators who don't sell any tickets for longer than seven days, or sometimes longer than one day, onboard the bus, for precisely this reason. They make longer tickets available in-app, from staffed sales points or ticket vending machines in town centres or bus stations, or for postal issue. It is difficult to see the problems with this. In England, but also probably in most places, totally offline people are probably entitled to free bus travel anyway.
 

Bletchleyite

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There are operators who don't sell any tickets for longer than seven days, or sometimes longer than one day, onboard the bus, for precisely this reason. They make longer tickets available in-app, from staffed sales points or ticket vending machines in town centres or bus stations, or for postal issue. It is difficult to see the problems with this.

Yes, this is a good plan. Though some weeklies do cost more, and indeed on longer routes some returns and increasing numbers of day tickets do. (I think it'll need to go from £10 to £15 fairly soon, indeed).

Does Ticketer offer a "skinned" online sales feature and app to make it easier for small operators to do this? If not perhaps it'd be a good business opportunity for them.

Even better still would be for Ticketer to do a deal with Paypoint and Payzone so seasons for all operators who use them could be sold from newsagents, that then covers cash sales too, reducing the amount of cash on board and thus improving driver safety.
 

crablab

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True, it doesn't make a difference for the specific situation here, but it would prevent stolen or found cards being used to buy seasons.
Why would the bus company spend the money on installing chip and PIN devices (and the operational overheard) to reduce issuer liability exposure?
Remember that properly processed contactless transactions have liability shift equivalent to chip and PIN.

The only thing that chip and PIN might help with is reducing declines offline I guess (and online SCA declines, but that's a separate issue that starts to lead into areas that aren't appropriate to discuss here I'm afraid).

Really the fix is to authorise transactions above £10 and secondarily to push, as far as possible, such sales online, by offering good quality apps, the sale of printable barcode tickets on the operator website etc, and ideally a small discount for choosing these options
Yes.
 

Hophead

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Surely (and I'm risking a 'surely'), the simple answer is a weekly cap? Ideally, a reducing daily cap until the weekly limit is reached. This is the approach taken by Brighton & Hove and Metrobus.
 

Starmill

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Surely (and I'm risking a 'surely'), the simple answer is a weekly cap? Ideally, a reducing daily cap until the weekly limit is reached. This is the approach taken by Brighton & Hove and Metrobus.
It's a good solution, but unfortunately, no operator can be forced to adopt it if they don't want to.
 
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