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Choose a government payment processor only after confirming which procurement route applies, what the agency must accept, and how payments must move into its accounting and operational systems. Federal agencies generally have a Treasury program requirement to resolve first; state and local agencies must check their own jurisdiction’s rules and contracts. Once eligibility is clear, compare proposals against the agency’s payment channels, security duties, settlement needs, full costs, and service requirements—not a headline transaction rate.
Start with the agency’s authority and procurement route
The first question is not which processor has the lowest advertised price. It is which providers the agency is allowed or required to use. That answer depends on whether the agency is federal, state, or local, and on the applicable program, contract, and procurement rules.
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Federal agencies: check the Card Acquiring Service requirement
The U.S. Department of the Treasury says most federal agencies that accept credit or debit cards must use its Card Acquiring Service (CAS), unless an exception applies. Treasury’s FAQ identifies the U.S. Postal Service, Army/Air Force Exchange Service, Navy Exchange, and Smithsonian among exceptions to the usual participation rule. Because applicability depends on the entity and current program requirements, confirm the agency’s status with Treasury and agency counsel before soliciting or selecting a separate provider. See Treasury’s CAS FAQs and CAS rules and security requirements.
Treasury’s FAQ, last updated November 10, 2021, says more than 60 federal agencies use CAS. Treat that as a dated program figure, not a current count or a measure of the entire government payment-processing market. The CAS footprint is substantial: Treasury’s overview, last updated February 25, 2026, describes approximately 10,000 locations and more than 19,000 point-of-sale endpoints. Those numbers describe CAS, not the capacity or market share of any commercial processor. See the CAS overview.
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State and local agencies: verify local rules rather than assuming a federal rule applies
The federal CAS participation requirement should not be treated as a rule for states, counties, cities, school districts, or other local entities. A state or local agency should identify its own procurement rules, statewide processing contracts or programs, approval requirements for payment providers, and rules governing fees charged to payers. There is no single state-and-local framework established here; the agency must verify the requirements that apply in its jurisdiction.
Also separate public-facing payment acceptance from purchase-card rules. Federal Acquisition Regulation 13.301 addresses use of the governmentwide commercial purchase card for otherwise lawful government purchases and calls for agency procedures consistent with the Treasury Financial Manual and current GSA credit card contract. It does not, by itself, select a processor for collecting payments from the public. See FAR Subpart 13.3.
Set a pass/fail gate before comparing proposals
Write down the legal authority, eligible contract vehicle, program participation requirement, and required approvals before issuing a request or evaluating bids. Mark a proposal ineligible if its provider, contract path, or proposed service cannot meet those conditions. A lower fee cannot make an unavailable or unauthorized option acceptable.
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A useful solicitation describes the full payment workload rather than saying only that the agency needs “online card processing.” Acceptance channels, payment methods, transaction patterns, and downstream workflows determine what a processor must support and what the agency must integrate.
Inventory channels, payment methods, and transaction patterns
Record which of the following the agency uses or expects to add:
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- Online payments, including any connection to an agency website or line-of-business application.
- In-person payments, including whether staff need terminals and whether the checkout process must integrate with agency systems.
- Telephone, mail, recurring, and staff-assisted transactions.
- Credit cards, debit cards, ACH, and any required EBT or stored-value acceptance.
For each channel and method, estimate transaction volume and seasonality, average and maximum ticket, peak-period demand, refunds, reversals, disputes, and timing needs for deposits. Document which payment types are mandatory and which are optional. ACH is a separate payment rail, not simply a card-processing feature: Treasury’s payment-mechanism guidance describes ACH and Same Day ACH options for federal entities where same-day settlement benefits the entity and government. Applicability and operating rules should be checked for the agency and use case. See Treasury Financial Experience’s payment-mechanism guidance.
Understand authorization, clearing, and settlement
Card transactions involve a sequence of parties and steps. At authorization, a payment request travels from the acceptance point through the acquirer or processor and card network to the card issuer, which responds to the request. Clearing and settlement follow: transactions are reconciled and funds move through the relevant accounts. A proposal should explain who performs each operational step, which party supplies transaction-level information, and what the agency must do to investigate exceptions.
CAS provides a specific federal-program reference point, not a general industry service guarantee. Treasury says prior-day CAS transactions settle to Treasury’s Federal Reserve account before 2:00 p.m. Eastern Time, with next-day funds availability. An agency comparing other arrangements should obtain the bidder’s exact settlement timetable, cutoffs, deposit destination, and treatment of weekends or holidays rather than assume CAS timing applies. The details are in the CAS overview.
Identify transaction limits and exceptions in the applicable program
Treasury’s CAS materials state a maximum credit-card transaction of $24,999.99 for agencies using CAS rules. Treasury’s FAQ separately gives a $9,999.99 limit for government cards. These are program-specific figures, not universal limits for every government agency or payment arrangement. Confirm the current applicable rule, payment type, and program before designing a workflow for larger transactions. See the CAS security and rules page and CAS FAQs.
Translate security obligations into verifiable requirements
Security is an operating responsibility, not a feature that can be delegated away by choosing an outside processor. In the federal context, Treasury states: “All federal agencies that process, store, or transmit credit and debit card transactions must comply fully with the Payment Card Industry Data Security Standard (PCI DSS).” The statement applies to federal agencies; agencies elsewhere must determine their own legal, contractual, and payment-card obligations. Treasury’s CAS rules and security requirements describe PCI DSS, EMV, encryption, and tokenization in the CAS security posture.
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Require a clear data-flow and responsibility description
Ask each bidder to show how payment information moves from entry through authorization, settlement, reporting, refunds, and support. Require the proposal to identify:
- Which party captures, processes, stores, or transmits cardholder data, and which data, if any, reaches agency systems.
- How encryption and tokenization are used, where tokens can be used, and how access to payment information is controlled.
- Which party supplies PCI DSS validation evidence, what that evidence covers, and which agency systems or activities remain in scope.
- How architecture changes, new channels, integrations, or operational changes could affect the agency’s security scope.
- Incident-notification contacts, escalation steps, cooperation duties, and the bidder’s response process.
Do not assume that outsourcing card handling or using tokenization automatically removes agency duties. Treasury’s FAQ distinguishes validation evidence from ongoing controls; the agency should understand both and document its own responsibilities as well as the processor’s.
Prohibit retention of sensitive authentication data after authorization
Treasury says not to store full magnetic-stripe track content, card verification codes such as CVV or CVC, or PINs and encrypted PIN blocks after authorization. Make the bidder explain how its systems and any agency-managed components prevent prohibited retention. The same requirement should be reflected in implementation plans, staff procedures, and data-retention practices, not left as a general promise that the service is secure. See Treasury’s security requirements.
Compare total cost, not just the transaction rate
No market-wide government processing price or universal “typical rate” is established here. Costs depend on the agency’s transaction mix, channels, contract, and services. Ask every bidder for a complete price schedule and model it against the same agency-specific assumptions.
Request comparable prices for every payment type and channel
For each proposal, request fees and conditions for:
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- Percentage-based and per-transaction charges, broken out by payment method and channel.
- Gateway, terminal, or other equipment charges, including any recurring charges.
- Monthly account fees, minimums, reporting charges, implementation, and support.
- Refunds, reversals, chargebacks, disputes, and any related administrative services.
- Contract termination, data export, and transition or migration assistance.
Use the agency’s expected transaction counts, ticket sizes, payment-method shares, and channel mix to calculate scenario costs. Include peak periods, refunds, disputes, and fixed charges. Ask bidders to disclose assumptions and explain charges that vary with transaction characteristics. This makes a low quoted percentage comparable with a proposal that includes more services or has different fixed costs.
Do not mistake debit interchange rules for a cap on processor costs
Federal Reserve Regulation II addresses specified debit interchange fee standards and routing. The Federal Reserve’s small-entity compliance guide says that fees for checks, credit cards, and ACH are not covered by section 920 or Regulation II. Government-administered payment-program transactions can also qualify for an exemption. Regulation II does not set every processor, gateway, terminal, support, or contract charge, and it is not a general cap on an agency’s processing costs. For scope, consult the Federal Reserve’s Regulation II information.
Whether an agency may impose a convenience fee, surcharge, or other charge on a payer is a separate legal and program question. Do not treat a processor’s technical ability to add a charge as proof that the agency is permitted to do so. Obtain jurisdiction-specific legal and procurement review before including such a charge in the payment design.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Specify settlement, reconciliation, and daily operations
Payment acceptance is only useful if finance and operating teams can account for receipts, resolve exceptions, and serve constituents. Convert daily work into requirements bidders can answer rather than relying on broad assurances about “reporting” or “integration.”
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Describe the destination account for deposits, the required settlement schedule, and the accounting close process. Specify the level of detail needed to match deposits to transactions, including transaction identifiers, dates, amounts, payment methods, refunds, reversals, and fees. State how agency accounting codes or other required classifications must be carried into reports or connected systems.
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Identify who will investigate unmatched items, delayed or failed deposits, and differences between processor reports and agency records. Ask for sample reports and test data in the solicitation or evaluation process. Treasury’s CAS overview explains the acquirer/processor reconciliation and settlement flow, but the accounting codes, reporting format, and integration needs of an individual agency must be defined by that agency. See the CAS overview.
Cover customer service, controls, and continuity
Set requirements for refunds, reversals, disputes, constituent receipts, audit trails, role-based access, support hours, incident escalation, uptime, disaster recovery, and data portability at contract end. Specify accessibility expectations for online payment pages and assisted workflows, as well as alternatives for people with limited digital access. For in-person service, address terminal replacement, connectivity interruptions, and how staff should handle a payment that appears incomplete.
Require a realistic implementation plan: dependencies, agency resources, testing responsibilities, training, cutover steps, and the path back to the existing process if launch criteria are not met. The agency should identify connections to its finance and line-of-business systems before award, so integration effort and operational ownership are visible in both evaluation and contract terms.
Use a structured proposal scorecard
After mandatory eligibility and security checks, compare proposals on consistent criteria. Assign weights that reflect the agency’s priorities, and require evidence or a specific contractual commitment for each scored answer.
| Evaluation area | Questions to ask | Evidence to request |
|---|---|---|
| Eligibility and contract route | Is this provider and contract vehicle permitted? Are required program approvals, term, renewal, and exit rights acceptable? | Applicable contract documents, program confirmation, and proposed term and exit provisions. |
| Payment coverage | Which payment methods, card types, channels, transaction limits, and workflows are supported? | Channel and method coverage, transaction limits, and workflow descriptions. |
| Security and compliance | Who handles card data? What remains in agency scope? How are encryption, tokenization, access, validation, and incident response addressed? | Data-flow description, PCI DSS evidence and responsibility allocation, security controls, and incident procedures. |
| Economics | What is the total cost under the agency’s actual payment mix, including setup, equipment, refunds, disputes, support, and exit? | Complete fee schedule and a cost model using the agency’s common assumptions. |
| Settlement and accounting | When are funds available, where are they deposited, and how can finance reconcile them? | Settlement terms, sample transaction-level reports, and reconciliation process. |
| Integration and operations | How will the service connect to finance and line-of-business systems, and what staffing, training, and support will it require? | Integration plan, implementation schedule, support commitments, continuity and recovery provisions. |
| Constituent experience and resilience | Can people pay through the required channels, receive clear receipts, and use a workable alternative when a channel fails? | Demonstrations of required workflows, accessibility information, and documented fallback procedures. |
Keep mandatory pass/fail requirements separate from scored preferences. A proposal that fails an eligibility, security, payment-coverage, or essential accounting requirement should not recover its standing through a favorable price score. For the remaining eligible proposals, score only against criteria announced in advance and supported by comparable evidence.
Quick Recap
Run the selection in a defensible sequence
- Confirm jurisdiction and authority. Determine whether the agency is federal, state, or local; identify the applicable payment program, procurement rules, contracts, and approvals.
- Set mandatory requirements. Record required methods and channels, applicable transaction limits, security obligations, settlement needs, integrations, and customer-facing workflows.
- Build the transaction profile. Provide bidders with consistent estimates for volume, ticket sizes, channel and method mix, peak periods, refunds, reversals, disputes, and deposits.
- Issue a comparable request. Ask each bidder the same questions and require a full fee schedule, data-flow and responsibility description, sample reports, implementation plan, and service commitments.
- Apply pass/fail gates. Exclude options that lack an allowed contract route or cannot meet mandatory security and operating requirements.
- Score eligible proposals and validate claims. Use the published scorecard, test demonstrations against actual agency workflows, and resolve gaps in writing.
- Put commitments in the contract. Confirm fees, settlement timing, support, security responsibilities, reporting, incident escalation, implementation milestones, data portability, and termination rights in binding terms.
- Plan launch and ongoing oversight. Assign agency owners for reconciliation, access reviews, incident coordination, staff procedures, and periodic checks that the service still meets program and operational requirements.
Common selection mistakes to avoid
- Applying a federal rule to a state or local entity. Confirm the governing jurisdiction and contracts instead of presuming CAS requirements apply universally.
- Choosing on a headline rate. Compare total cost with the agency’s own volume and mix, including channel, fixed, refund, dispute, equipment, and exit costs.
- Treating outsourcing as a security exemption. Document what the agency still does and what systems remain in scope, even when the processor handles card data.
- Confusing purchase-card use with public payment acceptance. Keep procurement-card policy separate from the process for collecting fees or payments from constituents.
- Assuming a processor’s surcharge feature makes a surcharge lawful. Have counsel verify the jurisdiction’s rules and the relevant program terms.
- Leaving reconciliation until after award. Require sample reports and define deposit matching, accounting data, and exception ownership before selecting a proposal.
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