As the fate of debit card interchange costs are decided in the Federal Reserve’s appeal to the 8th U.S. Circuit Court of Appeals, many merchants are quietly embracing credit card surcharges as a way to offset interchange costs on credit card transactions. Credit card surcharges are an incremental fee that a merchant charges a customer that pays the merchant with a credit card. The surcharges are designed to offset the merchant’s credit card interchange costs, i.e., the fees that a payment network charges a merchant for the privilege of accepting credit card transactions. Surcharging software can be extremely effective if the surcharging program is designed properly and the agreement between the merchant and the provider properly allocates compliance responsibilities, protects the merchant with strong indemnifications and requires the provider to maintain a robust regulatory change management program. Payment-card accepting merchants of all types, large and small, are rapidly implementing credit card surcharges, including for large-ticket business-to-business and commercial transactions where end users routinely settle six-figure invoices with a payment card. A surcharge program can help a merchant recoup credit card interchange costs from the end user, but the absence of a federal surcharging standard has led to complex compliance requirements. Credit card surcharges are governed by a balkanized regime of disparate state laws in combination with stringent payment card network rules. The payment card networks’ operating regulations act as minimum compliance standards for all surcharging transactions, and even apply in states that have no surcharging limitations. And when a state has a surcharging law that is more restrictive than the payment card networks’ rules, then the merchant must follow those stricter state laws. Merchants operating across large geographic footprints are frequently managing myriad state surcharging laws in addition to payment card network operating regulations for each brand.