If you operate ATMs, you’ve probably heard about the January 1, 2025, deadline for PCI TR31 Phase 3 compliance. Whether you’ve missed this deadline or are still working toward it, understanding what’s at stake is crucial for your business.

What is PCI and Why It Matters

PCI compliance isn’t just another regulation – it’s a set of security standards designed to protect financial transactions. The latest requirement, TR31 Phase 3 encryption, focuses on securing communication between ATMs and processors. This new standard affects how your ATMs handle sensitive information; from the moment a customer enters their PIN to when the transaction is processed.

What Happens If You Missed the Deadline?

Here’s the good news: your ATMs won’t suddenly stop working if you missed the January deadline. Many processors have stated they won’t immediately shut down non-compliant machines. However, this doesn’t mean you can ignore the requirement indefinitely.

Protecting Consumer Data – The primary goal of TR31 Phase 3 encryption is to protect an ATM user’s financial information. With financial fraud becoming more sophisticated, this upgrade helps ensure that data transmitted through your ATMs remains secure and protected from potential threats.

Security Vulnerabilities – Non-compliant ATMs are more vulnerable to security breaches. Without the latest encryption standards, your machines are at higher risk for data theft and fraudulent transactions. This isn’t just a technical issue – it’s about maintaining the trust your customers place in your services.

Liability Shift – Perhaps the most significant consequence of non-compliance is the potential shift in liability. If a security breach occurs on a non-compliant machine, your insurance may not cover the loss, and you could be financially responsible for:

• Any fraudulent transactions
• Legal costs associated with the breach
• Damages to affected ATM users
• Potential fines and penalties

What the Experts Are Saying

Industry Leadership Perspective

Bruce Renard, Executive Director for The National ATM Council, Inc. (NAC), has been clear about the importance of PCI compliance: “ATM operators need to understand PCI compliance is still a requirement of the VISA and Mastercard Network Rules, which must be met for ATMs to be lawfully connected to the financial networks. Although ATM processors are currently handling transactions in both old and new PCI encryption formats, this transitional treatment could change on a moment’s notice and will likely come to an end later this year per the ATM Nation grapevine.”

“Most importantly, present non-compliance puts ATM operators and their merchants at current risk, very much like EMV, where a decision not to upgrade can become very costly if fraud does occur,” says Renard. “Potential fines for non-compliance by the global networks/sponsor banks are also still a very real threat, in the case for instance of a ‘anonymous whistleblower’ complaint spurred by a competitor.”

“Bottom line, if you haven’t already done so, it’s in your best interest to put a PCI compliance plan in place now, in a written format that you save electronically, start implementing promptly, and complete ASAP this year,” Renard states.

Manufacturer Readiness

Major ATM manufacturers are prepared to help ATM operators meet these requirements:

• Hyosung has detailed documentation available for upgrading their machines
• Genmega provides step-by-step guidance for compliance updates
• Triton offers comprehensive resources for implementing the necessary changes
• ATMTrader provides essential PCI compliance components and upgrade kits to ensure your ATMs meet the latest security standards.

Processor Requirements

While processors aren’t currently enforcing strict compliance, industry experts agree this won’t last forever. Processors will eventually require all ATMs to meet these standards, making it a matter of “when” rather than “if” you’ll need to upgrade.

The Importance of Having a Plan

Even if you’re not ready to upgrade immediately, having a detailed plan is crucial so that you know what needs to be done and ready to take action. A good plan should include:

• Assessment of your current ATM fleet
• Timeline for necessary upgrades
• Budget considerations
• Coordination with manufacturers and processors

Make sure to keep an eye on shipping timelines, costs, and requirements to make the most educated and timely decisions about when to move forward. And that interaction with your processor will be key to knowing when “eventually” becomes “now.”

Making Your Decision: Upgrade Now or Wait?

When considering your upgrade timeline, several factors come into play:

• Age and condition of your current ATMs
• Available budget for upgrades
• Risk tolerance for potential liability
• Customer security concerns

As a top industry partner, NationalLink can help you navigate these decisions and develop a practical plan for achieving compliance. Our team understands the challenges ATM operators face and can provide guidance on the most cost-effective path to meeting these requirements.

Whether you choose to upgrade now or develop a phased approach, the important thing is to start making a move. Contact NationalLink today to discuss your options and start building your compliance strategy today!