In Europe, the answer can be pretty obvious. We’ll cover that later in this answer.
Outside of Europe (and other regulated regions), merchants may choose to take advantage of the benefits of 3-D Secure, including liability protection. This means that when an issuer authenticates a digital transaction, they believe that the transaction is good, and stand behind their authentication to the point that if the transaction turns out to be fraudulent, they will take responsibility for the fraud. Spinning it from the merchant’s perspective, if a merchant sends a transaction for authentication and the issuer authenticates it, the merchant is off the hook if the transaction turns out to be fraud. This is a huge benefit to the merchant, and a huge risk mitigation tool. The issuer has a lot of information about their cardholder, so if they authenticate the transaction, they are pretty confident that it is their cardholder.
In Europe, when SCA is enforced starting December 2020 (for most of the EEA and September 2021 for the UK), if SCA is required, 3DS isn’t used and an exemption isn’t used, the likely result will be a soft decline indicating the transaction needs to be authenticated. If the merchant re-submits the transaction without authenticating it, it then can be hard declined, and the merchant loses the sale.
Our advice is to get EMV 3DS in place now because we anticipate the effects of not having it to get progressively more severe, as regulatory bodies start enforcing the SCA requirements. Planning and implementing in advance gives merchants the opportunity to get it up and running and optimize their 3DS performance, in advance of any deadline pressure. Another benefit to implementing 3DS now is that merchants won’t be scrambling at the last minute before enforcement deadlines. Think about the countries who plan to start enforcing December 31 of this year. The months leading up to that deadline are usually the busiest of the year for many merchants and can involve site freezes for the holiday shopping season. For that reason alone, acting soon makes sense.