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 March 31, 2026

Chris Suh
Chief Financial Officer
Visa Inc.
P.O. Box 8999
San Francisco, California 94128

 Re: Visa Inc.
 Form 10-K for Fiscal Year Ended September 30, 2025
 File No. 001-33977
Dear Chris Suh:

 We have reviewed your filing and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended September 30, 2025
Item 7. Management s Discussion and Analysis of Financial Condition and
Results of
Operations
Non-GAAP financial results, page 41

1. To avoid giving undue prominence to your non-GAAP results, please revise
to present
 and discuss your non-GAAP results after your discussion and analysis of
GAAP results.
 Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Corporation Finance
Interpretations
 102.10(a).
Results of Operations
Net revenue, page 45

2. Increases in each component of net revenue appear to be primarily volume
related. This
 factor appears to recur annually as the primary factor impacting your
net revenue. Please
 discuss to the extent identifiable factors, such as macro-economic
conditions and others,
 are the cause for the increased volume. To the extent there are known
trends in the
 factors that materially impact future results, discuss such. Refer to
the introductory
 paragraph of Item 303(b) and 303(b)(2)(ii) of Regulation S-K and Section
III.B.3 and 4
 of SEC Release No. 33-8350.
 March 31, 2026
Page 2

3. Increases to your value-added services appear to represent about 50% of
the respective
 period over period increases to your net revenue. Please revise to
provide discussion of
 the factors underlying the increases. Further, your disclosure
attributes the growth to
 your "Issuing Solutions, Advisory and Other Services and Acceptance
Solutions"
 portfolios. However, you do not appear to quantify within the filing the
revenues
 attributed to these portfolios, and your disclosure does not include
quantification of the
 period over period increases to the respective portfolios to fully
understand the impact of
 the growth from each. Refer to the applicable guidance noted above as
well as
 Item 303(b)(2)(i) of Regulation S-K and section III.D of SEC Release No.
33-6835
 (501.04 of our Codification of Financial Reporting Policies).
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

 Please contact Abe Friedman at 202-551-8298 or Doug Jones at
202-551-3309 if you
have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
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