Who's Actually Responsible for Chargebacks Under Google Play's 2026 Policy?

Google Play is ending its practice of absorbing chargeback costs for orders placed after August 3, 2026, putting the disputed purchase amount and card-network fees onto developers instead. Google's own Review Refund API, launched July 2026, lets developers submit delivery and consumption data to help Google contest disputes, but it does not change who pays if a dispute is lost.

What's actually changing on Google Play

Starting with orders placed after August 3, 2026, Google Play developers become responsible for the purchase price, minus Google's service fee, plus any chargeback fee the card network or bank applies. Previously, Google covered these costs in full and simply notified the developer after the fact. Google frames the change as aligning Play with "industry standards," and in direct-to-consumer commerce, seller-pays-chargebacks is indeed standard, unless using a Merchant of Record. 

Liam Wiltshire, VP and GM at Tebex, pushed back on that framing publicly in an interview with GamesBeat, arguing this model is unfair and doesn’t reflect an industry standard of seller risk especially for in-app purchases, where developers had no control over how Google built or ran its billing system. The scale of this exposure is what makes it so dangerous - suddenly, studios are entirely uncovered against card-network dispute fees on every single microtransaction, regardless of its original value.

< Link to YouTube video> 

Where the Review Refund API stops and Merchant of Record starts

Google's Review Refund API works only within Google Play billing. Developers feed it delivery status, consumption data, and order state, and Google decides whether to contest a dispute using that evidence. It is a data-submission tool, not a liability shift. The developer still pays if the case is lost, and building the pipeline to generate that evidence is engineering work most studios don't have spare capacity for.

This is structurally different from how card networks already handle disputes outside app stores. Visa's Compelling Evidence 3.0 (CE 3.0) framework lets a merchant fight a friendly-fraud claim by showing two prior undisputed transactions from the same cardholder, shifting liability back to the issuer if the criteria are met. It's a card-network-wide standard, not one platform's proprietary tool, and Merchant of Record providers already build dispute infrastructure around it. 

That's the real lever for studios: moving sales into a web store where a Merchant of Record, not Google, is the legal seller, with dispute defense running on an established standard rather than a brand-new API with no track record.

Who bears the risk, by category

Once sales move outside Play billing, the exposure a studio faces comes down to which of four models its provider follows. The distinction isn't whether a provider is a merchant of record. Google (For Google Play Developers), Xsolla, Appcharge, FastSpring, and Tebex are all MoR in some form. What varies is what each does with chargeback liability once it's holding it.

Category	Approach to chargebacks	Why it matters
Google Play	MoR for tax and remittance, but its 2026 policy explicitly carves chargeback liability back to the developer; the Review Refund API supplies evidence, but Google still decides the outcome	The MoR label doesn't carry the usual risk transfer; the studio pays regardless of who's the legal seller
MoR, liability passed back (Xsolla, Appcharge, FastSpring)	Legally the seller and will defend a dispute, but typically passes the fee, and often the purchase amount, back to the studio	The platform holds the liability on paper, but the studio pays the fee regardless of outcome, meaning a lost dispute or even a won one still lands on the studio's books.
MoR, full chargeback insurance (Tebex)	Legally the seller and covers the fee, defense costs, and the refund itself if a dispute is lost, so the studio never pays	The platform keeps the liability regardless of outcome, rather than passing a lost dispute back down, backed by specialized tools and team expertise.
Standard PSPs (PayPal, Stripe, etc.)	Not a merchant of record; the business itself is the seller of record and carries the full cost and fees directly	No chargeback insurance by default; the studio is fully exposed on every dispute, win or lose

Tebex reports a chargeback rate under half the 0.6-0.7% industry benchmark, leveraging 14-plus years of specialized fraud tools and team expertise in gaming commerce. 

What this means for studios right now

Reading Google's policy change as a data problem - just plug in the Review Refund API and move on - misses the structural issue underneath it.

Speaking to GamesBeat about the stakes for smaller teams, Wiltshire said one bad month of chargebacks from factors outside a studio's control could be the difference between a sustainable game and one "completely destroying your game."

The API can improve a studio's odds inside Google's own system, but it doesn't change who writes the check when a dispute is lost. The only way to actually transfer that liability is to route transactions through a provider that becomes the merchant of record and contractually absorbs the outcome, which is what Tebex offers for web-store sales, not Play Store purchases.

For a studio evaluating options now, the useful question isn't "does this provider help me fight chargebacks?" It's "when I lose a dispute, whose revenue actually takes the hit?" Under Tebex's model, that answer is Tebex's, not the studio's.

FAQs

Q: Does Tebex protect studios from Google Play's new in-app chargeback policy? 

A: Not directly. Google's policy applies specifically to purchases made through Google Play billing, and no third-party Merchant of Record can intervene in that system. Tebex's chargeback protection applies to transactions processed through a Tebex-powered web store, which is why studios are increasingly looking at moving sales outside Play billing rather than trying to out-manage Play's dispute process.

Q: What does Tebex actually cover when a chargeback happens? 

A: Tebex covers the chargeback fee, the administrative cost of defending the dispute, and the refund to the customer if the defense fails. The studio does not pay any of these costs on transactions Tebex processes as the merchant of record.

Q: How is Tebex's approach different from Google's Review Refund API? 

A: The Review Refund API is a data-submission tool that helps Google decide disputes inside its own billing system; it does not change who pays if a case is lost. Tebex removes that financial exposure entirely for the transactions it processes, since Tebex is the legal seller and absorbs the outcome.

Q: What is Visa's Compelling Evidence 3.0 (CE 3.0), and how does it relate to this policy change? 

A: CE 3.0 is a Visa framework that lets a merchant defeat a friendly-fraud dispute by showing prior undisputed transactions from the same cardholder, shifting liability to the issuer when the criteria are met. It is a card-network-wide standard that Merchant of Record providers like Tebex already build dispute defense around.

Q: Should a studio move all its sales to a web store because of this policy? 

A: That depends on the studio's platform mix and player behavior, but the financial exposure is real enough that most studios should at least model it. Moving even a portion of transactions to a Merchant of Record like Tebex shifts chargeback liability off the studio for that portion of revenue, which reduces the impact of Google's 2026 change regardless of how the rest of the business is structured.