In aligning itself to commercial practice and improve its bottomline, DIBP has decided to recover credit card merchant fees from clients by adding a surcharge on credit card payments for all payments to DIBP. The surcharge could boost DIBPs bottomline by $14 million a year.
DIBPs financial statements indicate that despite a revenue of about 1.48 billion in FYE 2012-2013, its expenses, which largely come from border protection spending, led to a deficit of about $94 million for the year.
DIBP has not provided any indication of what the additional charges will be. Commercial operations charges vary widely and may range between 1.5% and 3% (sometimes even more). However, government agencies’ rates are generally half of that range. For instances, currently the Australian Tax Office (ATO) charges credit card merchant fees for payments at the rate of 0.42% for Visa and MasterCard payments and 1.45% for payments by American Express cards. DIBP is expected to announce its rates soon.
RMAs who accept credit card payments for their fees and other payments should be aware that they are allowed to recover ‘reasonable fees’ for credit card usage from their clients pursuant to the Reserve Bank of Australia (RBA) guidelines
The RBA guidelines state the fees you can recover from a client include, “the additional costs, which in addition to the merchant service fees might form part of the reasonable cost of acceptance,"
These costs may include, but are not necessarily limited to:
The examples of costs outlined above (including the merchant service fee) should be calculated net of any rebates from either the acquirer or the issuer. Any costs applying to multiple payment methods should be apportioned, as far as possible, pro-rata based on the transaction volumes attributable to each payment method (e.g. the cost of card terminals should be apportioned between the card schemes that use those terminals) and to the extent the apportioned costs have not already been included in the cost of acceptance for another payment method.”
This smells to me. Legally, we now MUST utilise the immiAccount to submit a variety of visa applications for clients. Legally, to submit the visa application the client MUST pay a prescribed VAC. Practically DIBP is about to establish a system which makes it impossible for clients to submit a visa application at the prescribed rate for a range of visa subclasses!
DIBP may be a government organisation, but it is carrying on a business that generates profits and is therefore subject to fair trading rules, I believe. It will need to tread carefully to avoid claims it has advertised a lower 'price' for a visa than can in fact be achieved by its (valued) customers.
"Surcharge" when there is no other payment method option? This is a compulsory inbuilt to VAC cost, and leading to different VACs for the same type of application, depending on the card used and in fact increasing the VAC for internet applications which it either encourages or has made compulsory. Where does consumer choice and protection fit into this scheme?
Merchant agreements generally prohibit the vendor charging a service fee to use credit card payments. This is done so that customers don't start using cash over credit cards. DIBP might be breaching their merchant agreement by levying a surcharge for using a credit card.