Visa 10.4 (other fraud, card-absent environment) is the most expensive line item in most merchants' chargeback ledger. Disputes filed under 10.4 carry higher disputed amounts than other codes because the cardholder claims the transaction was unauthorised; they tend to be filed late in the issuer's 120-day window, by which point evidence has aged; and the merchant's naive win rate without a structured CE 3.0 defence typically sits below 10%.
10.4 is also the only Visa reason code where Compelling Evidence 3.0 applies. The framework, in force since April 2023 and expanded with auto-qualification pathways in October 2025 and Order Insight integration in April 2026, lets a merchant overturn a 10.4 dispute by showing the cardholder has a prior pattern of undisputed transactions with the same merchant. The qualifier is strict: two prior undisputed transactions on the same payment credentials within 120 to 365 days of the disputed one, sharing at least two of four identifiers (IP address, device ID, customer account, shipping address) with the disputed transaction.
The strictness is what makes CE 3.0 valuable to merchants it fits and useless to the rest. A subscription business with returning customers, a marketplace with repeat buyers, or a DTC brand whose customers reorder will qualify on most of their 10.4 cases. A first-purchase-heavy merchant will qualify on almost none. Both should know which group they sit in before treating CE 3.0 as a defence strategy.