3223 Comair

Introduction

• What it is: This MCC covers airlines providing commercial passenger and freight transportation services.
• Risk level: Medium — Flight operations can be subject to geopolitical and economic factors.
• Acceptance difficulty: High — Frequent chargebacks and cancellations make acceptance challenging.
• Typical business models: passenger airlines; cargo services; charter flight operators; aviation services.
• For merchants: Expect moderate MDR; potential for fund reserves; thorough approval scrutiny.
• What PSPs expect: Comprehensive business documentation; proof of operational safety; clear cancellation policies disclosed.

Payment Insights & Benchmarks

Merchants in this MCC should plan for unique challenges related to payment processing, often influenced by industry-specific dynamics such as travel and related services. Understanding these factors will help merchants manage expectations and optimize their payment strategies.

Payment methods

Credit and debit cards: widely used but may face higher rejection rates due to fraud prevention measures.

• E-wallets: offer convenience and faster transactions, particularly for online bookings.
• Bank transfers: common for larger purchases, may involve longer processing times.
• Vouchers or gift cards: useful for customer loyalty programs, but can complicate reconciliation.

Authentication & security

Strong customer authentication (SCA) requirements are frequently applied to reduce fraud risk.

• 3DS (Three-Domain Secure) is commonly implemented, which can impact checkout speed but enhance security.
• Continuous fraud monitoring is essential, focusing on ticket volume, frequency of bookings, and transaction patterns.

Benchmarks (indicative, not guaranteed)

MDR: generally higher than average due to increased fraud risks in travel-related transactions.

• Rolling reserves: may be implemented, often at levels around 10-20%.
• Settlement times: typically longer (5-10 days) due to processing complexities.
• Chargeback ratios: often higher owing to the nature of services and customer disputes.
• Approval rates: generally lower for cards, especially in cross-border transactions, whereas local payment methods might perform better.

Key metrics to monitor

Transaction success rates segmented by payment method.

• Chargeback rates and reasons to differentiate between fraud and service issues.
• Average transaction value and frequency of large bookings to assess risk.
• Customer engagement metrics, including repeat transaction rates and channel efficiency.

Risk & Compliance

Merchants categorized under this MCC face heightened scrutiny due to the unique risks associated with travel and transportation services. PSPs and acquirers are particularly vigilant about fraud, chargebacks, and compliance with AML/KYC regulations in this industry.

Chargebacks & fraud

Common chargeback reasons include friendly fraud, where customers claim they did not authorize a transaction, and disputes related to service not rendered (e.g., canceled flights).

• Fraud patterns may include the use of stolen payment methods for purchasing tickets or services.
• Mitigation tools such as chargeback alerts, AI-driven fraud detection systems, and device fingerprinting can help reduce exposure to fraudulent activities.

AML/KYC expectations

Strong customer identity verification practices are essential, with comprehensive checks on government-issued IDs and verification against watch lists.

• Monitoring for high-risk transactions, including large bookings or payment over time with multiple identities, is crucial for compliance.
• Manual review triggers often include high-dollar transactions, bookings with multiple passengers under different names, or repetitive changes to reservations.

Operational red flags

Lack of transparency regarding ownership structure or obscured beneficial owners in the service provider may raise concerns.

• Unverified travel packages or service offerings, particularly from new or unfamiliar operators, can attract scrutiny.
• Inadequate communication of cancellation, refund, and change policies may signal poor operational practices.
• A high volume of refunds and chargebacks could indicate customer dissatisfaction or potential operational issues.

Onboarding Checklist

Merchants under this MCC should prepare a complete onboarding package before approaching PSPs or acquirers. A well-structured submission improves approval chances and shortens review times.

Legal & corporate documents

company registration and incorporation documents

• disclosure of beneficial owners (UBO) and corporate structure
• valid licenses for the relevant business activities
• policies: Terms of Service, Privacy, AML/KYC, Refund Policy

Financials & risk management

recent financial statements and cashflow forecasts

• liquidity or reserve model for payouts
• description of antifraud setup and monitoring tools

Product & marketing

demo access or screenshots of the live platform

• marketing plan and traffic source overview (affiliates, SEO, PPC)
• geographic targeting information
• KYC flow details, including IDV providers and thresholds

Technical integration & security

payment architecture overview with supported methods/providers

• description of SCA/3DS flows, retry logic, and tokenization
• PCI DSS compliance status and data storage policy

Operations

customer support coverage (languages, 24/7 if available)

• SLA for dispute handling and chargeback response
• deposit, bet, and payout limits; self-exclusion mechanisms
• internal process for chargeback investigation and documentation

Regulation & Licensing

Licensing and certification are crucial for merchants in the MCC 3223 (COMAIR), as payment service providers (PSPs) require evidence of compliance before offering service. The recognition of these licenses is heavily influenced by the merchant's jurisdiction and the specific markets they are targeting.

Operator licenses

Federal Aviation Administration (FAA) — a key regulatory body in the United States overseeing commercial aviation standards and safety.

• European Union Aviation Safety Agency (EASA) — responsible for aviation safety regulations within the EU, ensuring compliance from operators.
• National Civil Aviation Agency (ANAC) in Brazil — governs aviation operations and licensing for airlines in Brazil.
• Other countries may maintain their own regulatory authorities, requiring local licenses for commercial aviation operations.

Geo-restrictions

Certain countries may have aviation bans affecting foreign carriers, limiting operational capabilities.

• Regulatory compliance requirements vary, with some regions having strict permits only applicable within their borders.
• Specific markets may impose additional restrictions or require compliance with regional aviation safety standards.

Certifications & audits

Certification of Airworthiness for aircraft, ensuring safety and operational standards.

• FAA Part 145 certification for repair stations involved in aircraft maintenance.
• Compliance audits related to safety and operational procedures by independent authorities.
• Regular safety audits and inspections are conducted by national and regional regulatory agencies.

Official Definitions & Network Comparisons

This section shows how major card networks define this MCC and highlights practical differences that affect merchant onboarding.

Explanation:

Though the definitions indicate a focus on airline ticketing, networks may vary in their emphasis on compliance and documentation requirements. Key phrases like “related services” versus “specializing in” can indicate different interpretations of what constitutes acceptable merchant activities. Common denial reasons include failure to provide adequate licensing, ticket verification issues, and operations in high-risk regions.

Alternative MCC Codes

Merchants often confuse this MCC with other categories. The table below shows which codes are related, why they are confused, and what risks misclassification brings.

Rule of thumb for merchants:

Ensure that your services are directly related to air travel or airline operations to qualify for MCC 3223. Misclassification can lead to serious compliance issues, including account penalties and financial disputes. Always verify the core services provided to maintain accurate MCC classification.

Best Practices for Merchants

Merchants under the Comair MCC (3223) need to navigate a competitive landscape while managing payment operations effectively. By adhering to the best practices outlined below, merchants can enhance acceptance rates, minimize risks, and foster productive relationships with payment service providers (PSPs).

Classification & transparency

always use the correct MCC; incorrect classification may lead to higher fees or account termination

• provide clear information on your business model, including flight details, booking conditions, and cancellation policies on your website
• ensure transparent billing descriptors that align with customer expectations

Fraud & chargeback reduction

implement 3DS or step-up authentication for transactions perceived as high risk (e.g., large bookings or unusual patterns)

• utilize clear billing descriptors and send confirmation emails or SMS to customers immediately after booking
• maintain detailed records of ticket sales and boarding events to support dispute representments effectively

Payment acceptance optimization

support a variety of payment methods, including credit/debit cards, digital wallets, and local payment options to cater to customer preferences

• consider routing transactions based on customer location or issuing bank to improve approval rates
• perform A/B testing with different PSPs to evaluate performance and optimize transaction costs

Operational discipline

monitor and analyze key performance indicators (KPIs) like authorization rate, chargeback ratio, and customer satisfaction regularly

• conduct compliance audits to ensure adherence to internal policies and payment regulations
• establish a dedicated team or individual to manage disputes and ensure timely responses to inquiries

Payouts & liquidity

maintain adequate cash flow buffers to accommodate rolling reserves and manage unexpected settlement delays

• automate anti-money laundering (AML) checks on withdrawals to ensure compliance and minimize risk
• continuously monitor payout frequency and amounts, looking for unusual patterns that could indicate fraud

Business Scope & Examples

This MCC encompasses businesses primarily involved in air transportation services. Merchants classified under this category typically provide services related to the transportation of passengers or cargo by aircraft, focusing on scheduled air travel and charters. The scope includes both commercial airlines and specialized air transport services.

Models

scheduled commercial airlines

• charter flight services
• air taxi and helicopter services
• freight and cargo airlines
• air ambulance services

Borderline cases

Tour operators — companies that package travel arrangements, may include flights but are primarily service providers.

• Travel agencies — businesses that organize trips and sell air travel as part of a broader portfolio; typically classified elsewhere.

Signals for correct classification

business operates flights as a primary service for transporting passengers or cargo

• offers a fleet of aircraft for commercial use
• transactions primarily relate to booking or facilitating air travel services