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The screen says "includes a 5.5% markup". What is that a markup over, and where is it even required?

Last verified 22 August 2026 · by the NoDCC editorial desk

Short answer. The percentage is measured over the European Central Bank's euro reference rate, and the duty to show it now lives in Article 4 of Regulation (EU) 2021/1230. It was introduced by Regulation (EU) 2019/518, which is no longer in force. The scope is the part that catches people out: the duty reaches only payments denominated in euro or another EU member state currency, so a euro cardholder paying in dollars, pounds, francs, lira or baht is outside it. Disclosure is also not a price cap, and one 2026 test of Prague ATMs, one withdrawal per operator, measured mark-ups from 6.51% to 19.00%.

What is the percentage measured against?

Over the European Central Bank's euro foreign exchange reference rate. Article 4 of Regulation (EU) 2021/1230 requires the party providing the conversion to express the total currency conversion charges as a percentage mark-up over the latest available euro foreign exchange reference rates issued by the ECB, and to disclose that mark-up before the payment transaction is initiated.

That cuts two ways, and both are worth knowing before you read the next screen.

It is not a mark-up over the rate your own card would have given you. Where Visa performs the conversion it uses a rate it selects from the range of rates available in wholesale currency markets, which may vary from the rate Visa itself receives, and your issuer may then add an optional issuer fee or its own mark-up outside VisaNet. The ECB reference rate is a fixed public yardstick, not a forecast of your alternative.

It is usually not a separate fee bolted onto a clean rate either. Visa's own merchant integration documentation describes the DCC exchange rate as a wholesale rate with the DCC mark-up already built into it, which is why the number can be large with nothing on the screen labelled as a fee. Some operators do charge a commission as well: Visa's receipt rules name commission, fees, markup or margin on the exchange rate as four shapes the charge can take, and BEUC documented a live ATM screen disclosing a 9.9% margin over the wholesale rate while showing a commission of zero.

The percentage is telling you how far the rate on offer sits from the reference rate.

What 15% looks like in cash

On 1 April 2026 the ECB reference rate was 24.514 Czech koruna to the euro. A 1,000 CZK withdrawal at that rate is 40.79 EUR. One Prague ATM operator's euro rate that month sat 15.00% above the reference rate, which puts the same 1,000 koruna at 46.91 EUR.

That is a gap of 6.12 EUR against the reference rate. It is not automatically 6.12 EUR saved by pressing the other button: decline and your own issuer converts instead, at the rate its scheme gives it, plus any foreign transaction fee or mark-up your bank adds. The reference rate is the yardstick, not a quote for the alternative.

One thing the percentage is not measuring: the machine's own access fee. A fee for using the ATM and a bad conversion rate are two different charges, and the Czech test above measured fees and rates separately for exactly that reason. The ATM fee guide takes them apart.

Who has to show it, and since when?

The duty was introduced by Regulation (EU) 2019/518. That instrument is no longer in force: EUR-Lex records its end of validity as 18 August 2021 and its repeal by Regulation (EU) 2021/1230. The substance was carried into that codification unchanged, where the old Article 3a became Article 4.

Regulation (EU) 2021/1230 is in force, with a consolidated version dated 8 April 2024 following an amendment that touched Articles 3 and 6 and left Articles 4 and 5 alone. So the citation is Article 4 of Regulation (EU) 2021/1230. Citing 2019/518 as live law, which is still common, is out of date.

Then the dates. There are three, they are routinely conflated, and only two of them concern DCC at all.

FromWhat startedWhat it is not
15 December 2019General application of the 2019 amendments, including the equal-charges rule for cross-border payments in euro.Nothing to do with DCC display.
19 April 2020The mark-up disclosure, the two amounts, the public platform, and the duty to display the mark-up clearly at the ATM or point of sale.Not the messaging duty.
19 April 2021Your own bank's duty to send you an electronic message with the mark-up after a cross-currency withdrawal or payment, then once a month per currency.Not the screen duty.

The duty binds payment service providers and parties providing currency conversion services at an ATM or at the point of sale, which reaches the ATM operator itself and not only your bank. The party at the machine or terminal must also inform you of the possibility of paying in the currency used by the payee, with the conversion performed afterwards by your own provider. All of that information has to be provided free of charge and in a neutral and comprehensible manner.

Two carve-outs, and both sit on the messaging duty only. You can opt out of receiving the post-transaction electronic messages. And you and your provider may agree that paragraph 5 and paragraph 6, meaning the message itself and the channel it arrives on, do not apply in whole or in part where you are not a consumer.

That is the whole of the non-consumer carve-out. The screen duty in Article 4(1) to (4) carries no such exception, so a corporate or business card is covered at the machine exactly like a personal one.

Does the rule apply where I am going?

For most long-haul travel, no. This is the part almost everyone gets wrong, including people quoting the regulation at a terminal.

Articles 4 and 5 apply to national and cross-border payments that are denominated in euro or in a national currency of a member state other than the euro, and that involve a currency conversion service.

Two things pin that down before you try to use it. Denominated means the currency the payee is charging in, not the currency the DCC screen is offering you: Article 4(5) describes the payment order as denominated in a Union currency different from the currency of the payer's account, which is the local leg of the transaction. And Article 1(2) applies the Regulation in accordance with Directive (EU) 2015/2366, whose own scope rules turn on where the payment service providers are located. We have not verified those PSD2 provisions, so read the currency test below as assuming a Union-issued card and a Union-based ATM operator or merchant.

On that test the protection covers currency pairs inside the Union. A euro-account cardholder paying in Swedish krona or Polish złoty is inside it. A złoty-account cardholder paying euros in Paris is inside it. Domestic payments count as well as cross-border ones.

A transaction denominated in a non-Union currency is outside Articles 4 and 5 entirely. Dollars, pounds, francs, lira, yen, baht and dirhams are all outside. The classic tourist DCC moment, a euro cardholder in New York, London, Istanbul, Zurich or Bangkok being offered "pay in EUR", is not covered by this regulation at all.

Outside the Union currencies, no EU rule requires that screen to show you a percentage over the ECB rate. What the currency limit takes away is the ECB-percentage form. Underneath it sits PSD2's plainer duty on the party offering the conversion to disclose all charges and the exchange rate before you initiate, and how far that reaches when one side of the transaction is outside the Union is set by PSD2's own scope rules, which we have not verified. Card scheme rules apply on top, and they ask for different things again. Declining is still the move that works without any of it.

Online, and the UK

The operative article says "at an ATM or at the point of sale". In 2019/518 the online case appeared only in recital 8, which contemplated the information being given "on-screen in the case of online purchases", and recitals are interpretive rather than binding. We have not checked whether the 2021 codification's own recitals carry that sentence forward. Either way, do not assume the percentage rule squarely binds a foreign webshop.

The UK is not running this regulation. Regulation 57 of the Payment Services Regulations 2017 requires the party offering a currency conversion service, at an automatic teller machine, at the point of sale, or by the payee, to disclose all charges as well as the exchange rate to be used before the transaction is initiated. That third limb, "by the payee", is what reaches an online checkout, where there is no ATM and no physical terminal; the EU operative article names only an ATM or the point of sale. It is a charges-and-rate duty rather than a percentage-over-ECB duty. And it is a UK statutory instrument: it tells you what a UK-regulated provider owes you, and this page makes no claim that it binds a foreign ATM operator or an overseas merchant.

Regulation 57 is the UK transposition of Article 59(2) of PSD2, the article Regulation 2021/1230 hooks its own mark-up duty onto by name. A third-party reproduction of Article 59(2) shows the same "by the payee" limb in the EU text, but we could not load the article from EUR-Lex itself, so treat that as corroborated rather than read.

One precision point, if you end up arguing with a bank: the European Banking Authority has answered that the percentage mark-up over the ECB reference rate is not itself treated as a charge for the pre-contractual information requirements in Article 45(1)(c) and (d) of PSD2, because the mark-up duty sits in the cross-border payments regulation instead. That answer does not address ATM screens or online checkouts.

Why do some screens show no percentage at all?

Usually because nothing requires one there.

Outside the Union-currency scope, what binds the machine is card scheme rules, and they ask for different things. Mastercard requires that before authorisation you are clearly informed that you have the right to choose the currency, and shown the amount in local currency, the amount in your billing currency, the conversion rate to be applied, and any other fee that applies if you take the conversion. On the June 2026 edition of the Transaction Processing Rules we read, the receipt list stops at the two amounts, the currency codes and the conversion rate used: the mark-up itself belongs to the disclosure you get before you choose, not to the printed receipt.

Visa is stricter on paper. A Visa DCC receipt must carry the currency conversion commission, fees, markup or margin on the exchange rate over a wholesale rate or government-mandated rate, plus a statement, easily visible to the cardholder, that a choice of currencies was offered. Visa's consumer page lists the amount in both currencies with both currency symbols, the exchange rate used for the conversion, and any additional fees or markup assessed.

So a machine that shows a rate and two amounts and no percentage may be entirely within the rules that bind it. The absence of a number is not proof of a breach, and its presence is not proof of a fair price.

The two amounts are enough on their own. Compare the home-currency total the screen is offering against the same amount at the ECB reference rate, and the mark-up falls out whether or not it was named. That is what the exact mode of the NoDCC calculator is for: type the converted total exactly as the machine shows it, and it returns the mark-up hiding inside.

Does disclosure mean the price is fair?

No, and the freshest field test says so bluntly.

In April 2026 the Czech consumer-finance title Měšec.cz toured Prague ATMs with two foreign debit cards, one German and billed in euro, one Polish and billed in złoty, withdrawing 1,000 CZK from each major network and comparing the DCC rate offered against the ECB reference rate on the transaction date. On the euro card, ten operators ran from 6.51% at Air Bank to 19.00% at ATM Point, with Euronet at 15.00%. The złoty card produced a comparable spread, starting at 6.45%. Euronet, one of the higher operators in that table, later reproduced the euro-card figures on its own corporate site.

Read it for what it is: one city, one visit, one withdrawal per operator, published by specialist consumer media rather than by a regulator. It is still six years after the display duty took effect, inside a member state where the duty applies.

Older European measurements, for scale. BEUC in 2017 reported a Stiftung Warentest test in which DCC increased the price paid at ATMs by between 2.6% and 12%, and in-store card payments by 2% to 5%. Stiftung Warentest's own 2019 test sent 30 testers to 23 non-euro countries for 330 withdrawals and 132 card payments, found DCC offered in 15 of those 23 countries, and put the usual loss above 5% with a peak of 13.7%.

On Norway, two credible sources disagree, and averaging them would be dishonest. BEUC reports a Norwegian bank study of 1,500 transactions with an average of 7.6% and a maximum of 12.4%, measured against the official Visa rate. The Norwegian Consumer Council describes what is evidently the same work, attributes it to Sparebanken Vest, and gives an average of 6.6%. They do not even describe the sample the same way: BEUC counts 1,500 transactions, the Consumer Council counts 1,500 people. BEUC adds a figure the Consumer Council's write-up does not repeat, that only 4 of the 1,500 cases were cheaper in kroner than in local currency.

Article 4 requires the number to be shown. It does not cap it. When the options were weighed in 2018, a CEPS/ECRI commentary considered transparency, price caps, a chip-level opt-out and an outright ban, and concluded that transparency was the most promising. The European Commission's own impact assessment for what became 2019/518 contains no measured mark-up range at all.

What is changing next?

On 27 November 2025 the European Parliament announced a deal on the payment services package covering, among other things, pre-transaction information on currency conversion charges and on fixed fees for cash withdrawal at automatic telling machines. The same release states that the deal needs to be formally adopted by Parliament and Council before it can come into force.

Law-firm analysis of the provisional agreement expects the Payment Services Regulation to require all charges to be disclosed before initiation, including currency conversion at ATMs and points of sale, with estimated conversion charges presented consistently as a percentage mark-up over the European Central Bank's reference rate, and to bring independent ATM deployers clearly into scope for fee transparency and registration. That is one firm's reading of a provisional text, not the law.

The same analysis, written before publication, expected the text in the Official Journal towards the end of Q2 2026, with the regulation applying 18 months after entry into force. Checked on 22 August 2026: that window has passed and we have not confirmed publication either way.

Read all of it as the direction of travel, not as protection you have today.

What to do about it

<ol><li><strong>Decline.</strong> On Visa and Mastercard this is a rule rather than a courtesy: under Mastercard's rules, if you do not choose to have the transaction completed in your billing currency it must be completed and processed in the local currency, and Visa's rules bar a merchant, ATM acquirer or branch from imposing any additional requirement on you for having it processed in local currency. None of the law above has to reach your transaction for that to work. Declining is not free, because your own card then converts at its own rate and any foreign transaction fee it charges; it is just cheaper in nearly every measurement anyone has published.</li><li><strong>Read the two amounts, not the reassuring sentence.</strong> The home-currency total and the local-currency total are the only inputs you need.</li><li><strong>Put them in the <a href="/">calculator</a>.</strong> Exact mode takes the converted total the machine shows and returns the mark-up inside it, against the ECB reference rate.</li><li><strong>If you pressed the wrong button, photograph the receipt.</strong> The <a href="/mastering-atm-fees-and-dcc-refusal/">screen-by-screen refusal playbook</a> has the void, reversal and dispute ladder.</li><li><strong>Check the destination before you fly.</strong> The <a href="/countries/">country pages</a> cover where DCC actually shows up, and the <a href="/refusal-card/">refusal card</a> carries the sentence in 40 languages. Short answers to the neighbouring questions are in the <a href="/faq-dcc-explained/">FAQ</a>.</li></ol>

Sources

Every factual claim above is checked against a published source. Links go to the document itself, not to a summary of it.

  1. Regulation (EU) 2021/1230 of the European Parliament and of the Council of 14 July 2021 on cross-border payments in the Union (codification), Articles 1 and 4. The current text: percentage mark-up over the ECB euro reference rate, ATM and point-of-sale display, the scope limit to euro and other Union currencies, and the confinement of the non-consumer carve-out to Article 4(5) and (6). eur-lex.europa.eu ↗
  2. Visa Core Rules and Visa Product and Service Rules, 18 April 2026, s.1.4.3.2 International Transaction and Currency Conversion Fee Disclosure. That the Visa rate is selected from wholesale market rates and may be marked up again by your own issuer, which is why the reference rate is not a quote for declining. usa.visa.com ↗
  3. Visa Currency Conversion, DCC implementation guide (Visa Acceptance Solutions / Cybersource). That the DCC exchange rate is a wholesale rate with the mark-up built in. developer.visaacceptance.com ↗
  4. Visa Core Rules and Visa Product and Service Rules, 18 April 2026, s.5.9.2.3 / Table 5-34. The Visa DCC receipt checklist, including commission, fees, markup or margin over a wholesale rate as four distinct shapes the charge can take. usa.visa.com ↗
  5. Dynamic Currency Conversion: When paying abroad costs you more than it should, BEUC position paper BEUC-X-2017-118, 30 October 2017. The live ATM screen showing a 9.9% margin with zero commission; the 2.6% to 12% ATM range and 2% to 5% in-store range; the Norwegian 7.6% average, 12.4% maximum and 4-of-1,500 figure. beuc.eu ↗
  6. Turista u českého bankomatu: Poplatek, špatný kurz, nebo obojí (TEST), Měšec.cz, 4 May 2026. April 2026 Prague ATM field test: ECB reference rate 24.514 on 1 April 2026, EUR-card mark-ups 6.51% to 19.00%, PLN card starting at 6.45%, and the separation of fees from rates. Single city, single visit, one withdrawal per operator. mesec.cz ↗
  7. Regulation (EU) 2019/518 amending Regulation (EC) No 924/2009, Articles 1 and 2. The originating instrument and the three application dates: 15 December 2019, 19 April 2020, 19 April 2021. Also the message opt-out. eur-lex.europa.eu ↗
  8. EUR-Lex metadata record for Regulation (EU) 2019/518 (CELEX 32019R0518). That 2019/518 is no longer in force, end of validity 18 August 2021, repealed by 2021/1230. eur-lex.europa.eu ↗
  9. EUR-Lex metadata record for Regulation (EU) 2021/1230 (CELEX 32021R1230). That 2021/1230 is in force, consolidated 8 April 2024, with the amendment touching Articles 3 and 6 rather than 4 and 5. eur-lex.europa.eu ↗
  10. Regulation (EC) No 924/2009, consolidated text of 19 April 2020, Article 3a. Who the duty binds, and the operative wording "at an ATM or at the point of sale". eur-lex.europa.eu ↗
  11. Regulation (EU) 2019/518, recital 8 (Official Journal text). The only place that instrument contemplates "on-screen in the case of online purchases", and it is a recital. It also cross-refers to Article 59(2) of Directive (EU) 2015/2366 by name. eur-lex.europa.eu ↗
  12. The Payment Services Regulations 2017 (SI 2017/752), regulation 57, Currency and currency conversion. The UK duty, which reaches conversion offered by the payee as well as at an ATM or point of sale. UK statutory instrument, so a UK-perimeter duty. legislation.gov.uk ↗
  13. Article 59 PSD2, Currency and currency conversion (unofficial reproduction, Lewik). Corroboration only that PSD2 Article 59(2) itself extends to conversion offered by the payee. The register could not load Article 59 from EUR-Lex. lewik.org ↗
  14. EBA Single Rulebook Q&A 2023_6777, answer dated 17 January 2025. That the percentage mark-up is not itself a "charge" for the Article 45(1)(c) and (d) information requirements, and that the answer does not address ATMs or online transactions. eba.europa.eu ↗
  15. Mastercard Transaction Processing Rules, 9 June 2026, s.3.8.1 Cardholder Disclosure Requirements, s.3.8.4 and s.3.13.1 Receipt Requirements. The pre-authorisation disclosure list, the receipt content list, and that a transaction defaults to local currency if you do not choose. One edition cited throughout. mastercard.com ↗
  16. Decoding Dynamic Currency Conversion, Visa Travel (consumer page). Visa's consumer-facing list of what must be shown: both amounts with both currency symbols, the rate used, and any additional fees or markup assessed. visa.com ↗
  17. Bringing clarity to the conversation about ATM currency conversion charges in Czechia, Euronet Worldwide, 29 June 2026. The operator reproducing the same April 2026 euro-card table on its own site. Same underlying test, not independent corroboration of the measurement. euronetatms.com ↗
  18. Geldabheben im Ausland: Wie Sie Kostenfallen vermeiden, Stiftung Warentest / Finanztest 6/2019, 13 May 2019. 30 testers, 23 non-euro countries, 330 withdrawals and 132 card payments, DCC met in 15 countries, losses usually above 5% and peaking at 13.7%. test.de ↗
  19. Utbredt valutafelle lurer nordmenn for én milliard, Forbrukerrådet (Norwegian Consumer Council), 24 May 2017. The 6.6% average, attributed to a Sparebanken Vest study covering 1,500 people. forbrukerradet.no ↗
  20. Dynamic Currency Conversion and Consumer Protection: Finding the right rules, ECRI Commentary No. 22, 19 March 2018. The four policy options weighed, and the conclusion that transparency was the most promising. Carries no measured mark-up figures. ecri.eu ↗
  21. Commission Staff Working Document, Impact Assessment SWD(2018) 84 final, 28 March 2018. Registered as a negative finding: the impact assessment behind 2019/518 contains no measured DCC mark-up range. eur-lex.europa.eu ↗
  22. Payment services deal: More protection from online fraud and hidden fees, European Parliament, 27 November 2025. The PSD3/PSR agreement, its coverage of currency conversion charges and fixed ATM withdrawal fees, and that it still needs formal adoption. europarl.europa.eu ↗
  23. PSD3 and PSR: From provisional agreement to 2026 readiness, Norton Rose Fulbright. Law-firm expectation of what the PSR will require and of the timetable, labelled on the page as analysis rather than law and as a forecast written before publication. nortonrosefulbright.com ↗
  24. Visa Core Rules and Visa Product and Service Rules, 18 April 2026, s.5.8.9.2 DCC Merchant, ATM, and Branch Requirements. That no additional requirement may be imposed for having the transaction processed in local currency. usa.visa.com ↗