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There is no universal winner. For government collections, cards usually buy immediate authorization and broad payer convenience but create visible processing costs. ACH can be economical and is the federal government’s preferred method for many disbursements, yet its timing, return risk, integration work, and total cost depend on the specific bank, processor, payment type, and operating rules. The right choice starts by identifying whether money is moving to government or from government.
Start with the direction of payment
“Government payments” covers two different operating problems. A tax, license fee, court fine, permit charge, or other amount paid by a resident or business is a collection. A benefit, salary, grant, vendor invoice, refund, or other amount sent by an agency is a disbursement. Card acceptance and ACH origination have different economics and rules in those two directions.
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Collections: money paid to an agency
When an agency accepts a card, the payer receives an authorization response in seconds, while the agency incurs network, issuer, processor, and acquiring costs. The agency may receive funds on a schedule set by its acquiring arrangement rather than at the instant of authorization. ACH collections can avoid card-network interchange, but the sources available for this comparison do not establish one government-wide ACH price or one settlement interval. An agency must obtain its own pricing and model returns, fraud controls, account validation, reconciliation, and staff time.
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Disbursements: money sent by an agency
For federal payments, Treasury identifies direct deposit through ACH as its preferred disbursement mechanism for individuals and businesses. That policy addresses payments from government; it does not prove that ACH is the best channel for collecting taxes, fees, fines, or other amounts owed to government. Cards may be useful for a specific outbound payment program, but the agency must evaluate card acceptance by recipients, authorization and settlement arrangements, legal authority, and contract terms rather than applying the federal direct-deposit policy to every use case.
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What the federal card-cost benchmark actually shows
The most concrete comparable cost figure is federal and applies to card activity, not to every public agency. In Payment Cards: Costs and Benefits for Federal Entities (GAO-25-107298), the U.S. Government Accountability Office reported that more than 85 federal entities received $43.604 billion through payment cards in fiscal year 2023 and paid $784 million in fees. GAO characterized that as approximately 1.8% of revenue and an average of $1.06 per transaction.
| GAO FY 2023 measure | Reported value | How to interpret it |
|---|---|---|
| Federal entities covered | More than 85 | The population in GAO’s review, not every federal, state, or local agency. |
| Card revenue received | $43.604 billion | Aggregate revenue received through payment cards. |
| Fees paid | $784 million | Aggregate card fees for the covered activity. |
| Fees as a share of revenue | About 1.8% | An aggregate ratio, not a quoted rate for an individual agency. |
| Average fee per transaction | $1.06 | An average across the covered transactions. |
| Card types included | Credit, debit, and prepaid | These figures are not a credit-card-only benchmark. |
The totals cannot be used to predict a particular agency’s price. Transaction value, card type, volume, industry category, channel, processor contract, and whether an agency settles through Treasury all affect the result. They also cannot be compared with a single ACH number from the same evidence, because no comparable aggregate ACH collection-cost benchmark is established.
Why card acceptance costs more than one line item
A typical Mastercard or Visa transaction has several components. Interchange goes to the card issuer. Network fees go to the card network. Processing and acquiring fees pay for routing, authorization, settlement, risk services, reporting, and related functions. Pricing can be a percentage of the transaction, a per-item charge, or a combination, with contract-specific minimums and adjustments.
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1Fix the driver behind crashes, sound loss and screen glitches2Clear out junk files and repair common Windows errors3Scan for outdated or missing drivers - takes under a minuteGAO found that interchange represented nearly 90% of the fees paid by the selected entities it examined in fiscal year 2023. That finding describes those entities and their transaction mix; it is not a universal percentage. A small-value payment can produce a meaningful per-transaction cost even when the percentage is modest, while a high-value payment can produce a large absolute fee under percentage pricing.
Ways agencies have reduced card fees
GAO reported that some federal entities lowered fees by meeting volume thresholds or limiting the card types and transaction amounts they accepted. Those tactics may reduce cost but can also remove a payment option for people who lack a preferred card, divide a payment into multiple transactions, or add eligibility rules that complicate customer service. Card-network rules can be difficult to navigate, so an agency should have its processor explain qualification, data, dispute, and routing requirements in writing.
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Do not treat purchase-card rebates as a collection offset
GSA SmartPay generated $488 million in spending-based refunds in fiscal year 2023 on $37 billion in net eligible funds spent. Those are purchase-card program figures. They are not a general rebate against fees an agency pays to accept taxes, fees, fines, or other public collections, and they should not be netted against the $784 million card-collection benchmark.
What ACH costs—and what is not established
ACH does not mean “free.” An agency may pay its bank or processor for origination, account validation, file or API access, returns, fraud screening, exception handling, reconciliation, and support. It may also incur internal costs for integration, treasury operations, customer service, and uncollected or returned payments. The complete amount depends on the institution, volumes, payment types, controls, and contract.
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Treasury identifies 31 CFR Part 210 and the Federal Reserve ACH Operating Circular as governing sources, with Appendix D governing ACH for federal agencies. Those authorities describe operating and legal arrangements; the cited Treasury material does not promise a single settlement time or a government-wide ACH price. An agency should request a detailed schedule showing origination, return, correction, fraud, and reconciliation charges before claiming ACH is cheaper.
| Cost question | Cards | ACH |
|---|---|---|
| Issuer or network charge | Interchange and network fees are built into the card transaction economics. | No card interchange; bank and processor charges still apply. |
| Per-payment pricing | Often percentage-based, per-item, or blended. | May be per-entry, bundled, or tiered under the agency’s agreement. |
| Returns and disputes | Chargebacks and card disputes require evidence and case handling. | Returns, reversals, unauthorized entries, and corrections require monitoring. |
| Reconciliation work | Requires matching authorizations, settlements, refunds, and disputes. | Requires matching files or API entries, settlement batches, returns, and exceptions. |
| Comparable public benchmark | GAO provides the bounded FY 2023 federal aggregate described above. | No comparable aggregate cost figure is supplied here. |
Speed: separate authorization, settlement, and availability
“Instant” can describe only one stage. A card authorization is a response to a payment request. Clearing and settlement happen afterward, and the agency’s usable balance depends on its acquiring arrangement. ACH has its own origination windows, clearing rules, settlement cycles, and return processes.
Federal Treasury Card Acquiring Service
Treasury says transactions processed through its Card Acquiring Service (CAS) are accepted throughout the day and have next-day funds availability. Prior-day transactions settle to Treasury’s Federal Reserve account before 2:00 p.m. Eastern Time. This is a CAS operating example, not a promise for every state, local, or federal processor. A merchant-style “approved” message should therefore not be represented as same-day government funds in every implementation.
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ACH timing
Treasury’s ACH guidance points agencies to 31 CFR Part 210, the Federal Reserve ACH Operating Circular, and Appendix D. Because the cited page does not establish one duration for all ACH payments, an agency should publish the cutoffs and expected availability for its own channel, including weekends, holidays, returns, and correction procedures.
Same Day ACH for eligible federal disbursements
Treasury guidance says eligible federal disbursements can settle on the day they are originated through Same Day ACH. The described program has a $1 million ceiling per payment, application-dependent submission cutoffs, and a $0.052 fee per payment paid by the Fiscal Service. Same Day ACH is not a blanket acceleration tool: Treasury says not to use it to move forward regularly scheduled benefits, salary, or similar recurring payments. Eligibility, cutoff, amount, and payment-purpose checks belong in the agency’s workflow before a file is released.
| Stage | Card example | ACH example |
|---|---|---|
| Authorization or origination response | Card network and issuer return an approval or decline during the transaction. | Originator submits an entry or file; acceptance does not mean final, irrevocable funds. |
| Clearing and settlement | CAS prior-day transactions settle before 2:00 p.m. ET under Treasury’s stated schedule. | Timing follows ACH operating rules, schedules, and the agency’s bank or processor arrangement. |
| Funds availability | CAS states next-day availability. | Same Day ACH may provide same-day settlement for eligible federal disbursements subject to limits and cutoffs. |
| Exceptions | Declines, refunds, and chargebacks can alter the final amount. | Returns, unauthorized entries, corrections, and account changes can alter the final amount. |
Convenience, access, and payer choice
Why agencies accept cards
GAO reported that federal officials identified reduced administrative burden from handling cash and checks, customer satisfaction, and spending tracking as benefits of payment cards. Cards can let a payer complete a transaction without entering bank-routing details, and a familiar authorization flow can reduce abandonment for one-time payments. Those benefits have to be weighed against fees, disputes, network rules, and the agency’s obligation to offer an accessible payment path.
Where ACH can be stronger
ACH is well suited to recurring or scheduled transfers when the payer or recipient has a verified bank account and the agency can manage authorization, prenotification or validation, returns, and changes. For federal disbursements, Treasury’s direct-deposit preference reflects that operational fit. It does not eliminate the need for an alternative channel when a person lacks a bank account, cannot use a particular account, or needs a different payment experience.
Transaction size and eligibility
Cards may be constrained by network rules, agency limits, processor risk controls, and the cost of percentage pricing on large payments. ACH programs may have account, file, cutoff, or per-payment limits; the Same Day ACH federal disbursement guidance specifically sets a $1 million ceiling. Agencies should document the maximum and minimum amount, allowed payment purpose, return window, and exception path for each channel instead of advertising a generic “no limit” claim.
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Reconciliation and operational workload
The cheapest fee schedule can lose its advantage if staff cannot reconcile it reliably. For cards, the accounting design should connect the payer-facing receipt, authorization identifier, settlement batch, refunds, and chargebacks to the receivable or case record. For ACH, it should connect the authorization or account record, originating file or API message, settlement entry, return code, correction, and ledger posting.
- Define the settlement event: decide whether reporting recognizes authorization, clearing, settlement, or funds availability.
- Capture durable identifiers: retain transaction, batch, trace, and case references needed to investigate a missing or reversed payment.
- Design exception queues: route card disputes and ACH returns to owners with service levels and escalation rules.
- Reconcile gross and net amounts: separate taxes or fees collected from processor charges, refunds, and adjustments.
- Test close timing: run end-of-day, weekend, holiday, and month-end scenarios before launch.
Can government charge a card fee?
There is no universal answer. GAO cites specific authority for the Internal Revenue Service to pass through card fees and a statutory user fee at the Defense Commissary Agency. GAO also reports that Treasury officials were not aware of surcharge or convenience-fee authority for other entities participating in the Card Acquiring Service. A state or local program may operate under different statutes, regulations, contracts, and payment-purpose rules.
“What is a convenience fee or pay-to-pay fee?” is also a consumer-law question with a narrow federal source. The Consumer Financial Protection Bureau’s opinion concerns debt collectors: the Fair Debt Collection Practices Act and Regulation F prohibit charging a payment-channel fee unless the underlying agreement expressly authorizes it or law affirmatively permits it. That opinion should not be turned into a rule for every government agency, tax program, or public payment.
Before adding a fee, an agency should identify the exact entity, jurisdiction, payment type, governing statute or regulation, contract language, disclosure requirement, and whether the charge is a surcharge, convenience fee, or another authorized user fee. Legal counsel and the agency’s finance and procurement offices should confirm the result.
A practical decision framework
| Question | Card-oriented answer | ACH-oriented answer |
|---|---|---|
| Is this a collection or disbursement? | Often useful for payer-initiated collections where broad choice matters. | Especially aligned with scheduled federal disbursements and direct deposit. |
| How important is a rapid payer response? | Authorization is typically returned during checkout. | Origination acceptance is not the same as final funds; timing follows ACH schedules. |
| How important is predictable agency cost? | Obtain the full interchange, network, processor, and acquiring schedule. | Obtain bank and processor pricing plus return, fraud, integration, and staff costs. |
| Who should bear a fee? | Only if the precise legal authority and disclosure permit it. | Any account or transaction fee still requires applicable authority and contract review. |
| What happens when payment fails? | Decline, refund, or chargeback workflows are required. | Return, reversal, correction, and account-change workflows are required. |
| What access problem must be solved? | Supports people who prefer cards or cannot provide bank details. | Supports account holders and recurring transfers but may exclude people without usable bank access. |
Implementation checklist for an agency
- Classify the payment direction and purpose. Record whether the agency is collecting or disbursing, and whether it is a one-time, recurring, emergency, benefit, salary, tax, fine, or commercial payment.
- Map the complete money flow. Draw authorization or origination, clearing, settlement, funds availability, ledger posting, refund or return, and final exception closure.
- Request comparable bids. For cards, obtain interchange treatment, network and processor fees, acquiring fees, assessments, minimums, disputes, refunds, and settlement timing. For ACH, obtain origination, return, correction, fraud, validation, integration, and reconciliation charges.
- Model payer and agency costs separately. Show the amount the payer sees, the amount the agency receives, and every fee or adjustment. Do not assume a fee can be passed through.
- Set eligibility controls. Document card types, amount limits, account requirements, Same Day ACH eligibility, cutoff times, and recurring-payment restrictions.
- Build reconciliation before launch. Test identifiers, batch reports, refunds, chargebacks, ACH returns, corrections, and month-end close.
- Validate legal authority. Confirm federal, state, local, program-specific, and contractual authority for the payment method and any convenience or pass-through fee.
- Publish honest timing. Distinguish authorization, settlement, and funds availability, and state the applicable business-day, holiday, and cutoff assumptions.
- Review performance periodically. Recheck processor terms, network rules, ACH operating guidance, limits, fees, and newer cost data because each can change.
Common mistakes and how to avoid them
Calling ACH free
Use a full-cost model. Include bank charges, returns, fraud controls, account validation, integration, reconciliation, customer support, and uncollected payments. If a line item is unknown, label it as unknown rather than assigning it a zero value.
Treating authorization as cash
A card approval can later be refunded or charged back, and an ACH entry can be returned or corrected. Financial reporting should use the agency’s defined settlement and availability events.
Applying federal numbers to a local program
The $43.604 billion, $784 million, 1.8%, and $1.06 figures describe GAO’s FY 2023 federal card activity. They are useful scale indicators, not a quote for a county, school district, state tax department, or individual federal agency.
Using Same Day ACH for every urgent payment
Check payment purpose, the $1 million per-payment ceiling, application cutoff, and the recurring-payment restriction in Treasury’s guidance. Same-day settlement does not erase account, return, or reconciliation risk.
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Identify affirmative statutory or contractual authority first. The legal treatment of a debt collector’s pay-to-pay fee is not a blanket rule for government programs.
Bottom line
For government collections, cards provide familiar payer access and rapid authorization but carry layered costs that can be material: GAO’s FY 2023 federal sample paid $784 million on $43.604 billion in card revenue, including credit, debit, and prepaid activity. For federal disbursements, ACH aligns with Treasury’s direct-deposit preference and can use Same Day ACH for eligible transactions under stated limits and cutoffs. Neither method has a universal price or speed. Choose after separating collections from disbursements, pricing the complete operating workflow, testing reconciliation and exceptions, and confirming the agency’s legal authority.
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