If your company processed Discover card transactions for merchants between 2007 and 2023, there is an important deadline approaching fast which could directly impact your eligibility for settlement payments.

Payment intermediaries must submit required information by February 25, 2026 to be considered for payment in the Discover Card Merchant Settlement. Missing this step could delay or jeopardize recovery.

We’ll breakdown what’s required, why it matters, and how to stay compliant – without you having to translate legalese.

I’m a Payment Intermediary. What Do I Need to Do?

By February 25, 2025, you must:

1. Review the Discover Merchant IDs (MIDs) associated with your organization
2. Compile the required merchant and pricing data in the administrator’s file format
3. Securely submit that information to the settlement administrator

Not submitting complete and timely data may require follow-up requests and could delay payment processing.

Who is Considered a “Payment Intermediary”?

You may be designated a payment intermediary if your organization:

• Processed Discover credit card transactions on behalf of merchants
• Acted as an acquirer, processor, payment facilitator, or similar entity
• Aggregated multiple merchants under shared Discover MIDs

If you’re unsure whether the designation applies to you, there is a process to either challenge or confirm your status after registration.

Step 1: Review Your Discover Merchant IDs (MIDs)

Discover provided the settlement administrator with a database of all Discover MIDs that had at least one misclassified card transaction between January 1, 2007 and December 21, 2023.

After registering on the settlement website using your Claimant ID and PIN, payment intermediaries can:

• Securely download a list of Discover MIDs associated with their organization
• Review merchant names, addresses, tax IDs, and transaction dates
• Identify which merchants or downstream entities were tied to each MID

Step 2: Compile Required Information

Payment intermediaries must submit data for each end merchant or downstream entity for whom they processed Discover transactions during the class period.

Category One: Merchant Identification Data

This includes:

• Legal name and DBA name
• Tax identification number (TIN)
• Your internal merchant identifier
• Discover MIDs
• Non-Discover MID (if you aggregated merchants)
• Last known mailing address and email address

Each merchant or downstream entity must be uniquely identifiable in the file provided by the administrator.

Category Two: Interchange Fee Allocation Documentation

You need to also provide documentation showing who paid the brunt of Discover interchange fees, including:

• Pricing arrangements between your organization and merchants
• Time periods those arrangements were in effect
• Evidence showing whether interchange fees were passed through or retained

This information helps determine how settlement funds should be allocated between intermediaries and merchants.

Step 3: Submit Your Data Securely

Payment intermediaries may transmit information using one of three methods:

1. Upload directly through the settlement website
2. Request access to the administrator’s secure SFTP system
3. Use your organization’s preferred secure data-transfer method

If needed, the administrator can also provide a mutual non-disclosure agreement prior to transmission.

Can You Be Reimbursed for Data Compilation Costs?

Yes. Reasonable expenses incurred in compiling and submitting required data may be reimbursable, but:

• You must submit a sworn written account
• Documentation must be provided within 30 days of data submission

Reimbursement is not automatic and is subject to administrator review.

What Happens If You Miss the Deadline?

The settlement administrator is required to pursue additional outreach if information is incomplete or late. Late or insufficient submissions can delay processing and payment timing – and in complex cases, may affect eligibility altogether.

February 25, 2026 is a hard deadline. Planning ahead is strongly recommended.

Need Help Navigating The Process?

Payment intermediaries often manage thousands of merchants, legacy pricing models, and fragmented data systems – making this process more complex than it appears on paper.

Many organizations choose to work with experienced settlement specialists, like CCC, who can:

• Reconcile Discovery MIDs and internal merchant IDs
• Normalize historical pricing data
• Prepare compliant file layouts and documentation
• Coordinate secure submissions and administrator follow-ups

If you’d like help assessing your obligations or preparing your submission, now is the time to act – not the last week of February.