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Upcoming PCI TR 31 EPP Compliance Mandates

Updated: Nov 2, 2023

In 2019, the Payment Card Industry (PCI) Security Standards Council introduced new mandatory security requirements that impact both ATMs and processors. These regulations target the Electronic Pin Pad (EPP) within ATM hardware, responsible for cardholders entering their PIN numbers. A phased implementation strategy was initially planned to enhance the secure transfer of encryption keys from an ATM's host processor to the device. However, the COVID-19 pandemic led to postponements of compliance deadlines. The following dates now represent the revised deadlines: PCI EPP Compliance Dates:

  • December 31, 2022: Replacement of ATMs and upgrading EPPs for ATMs with PCI PTS v1 or older (considered less secure technology)

  • January 01, 2025: Mandate for EPP hardware, firmware, and software to adopt TR31 Phase 3 "Key Blocks"

Is your ATM in Compliance? Chances are, it's not. Minimum requirements include software updates, as manufacturers and processors certify software. Any ATM manufactured prior to March 2021 will likely require an EPP upgrade. Each ATM's upgrade pathway will vary, but generally, a technician's visit will be necessary. Tasks could involve loading new software, possibly installing a new EPP, related accessories, and reprogramming the ATM to the new protocol. Next Steps This upgrade is obligatory. Failure to comply means that your ATMs will cease processing transactions after January 2025. Given the extensive scope of this mandate (essentially impacting every ATM in the country, necessitating at least a software upgrade), we strongly advise against delays. Promptly upgrade your ATMs. PCI already extended their deadline once due to COVID-19. Historically, early upgrades are more cost-effective. Waiting until the last minute could lead to missing the deadline and facing higher upgrade costs due to potential manufacturer price increases closer to the deadline. Additional Information and Our Approach We've been aware of this requirement for years and ceased selling and deploying ATMs without the appropriate EPP style last year. Currently, we're contacting major affiliates/customers to relay this information, enrolling them for upgrades or selling kits. Preparing for Compliance Reach out to your ISO to determine which machines require software updates versus software and keyboard upgrades, or even complete replacements. For large Independent ATM Deployers (IADs), while the cost might appear significant, early action remains the more economical choice. If feasible, consider upgrading sooner, prepare by increasing surcharges if possible, and start setting aside funds. You have several months; don't leave preparations until the eleventh hour. Financing options are available for significant operators processing with us. Starting afresh? If you're considering purchasing used machines, conduct thorough research. Understand the cost of upgrading and whether an upgrade is feasible for that model. In the upcoming months, there'll be a surge in used equipment as people replace outdated hardware. Many of these might not be upgradable, we have Hyosung EPP Upgrade kits and Genmega EPP Upgrade kits available. Investing a few hundred dollars to utilize a machine for a brief period might not be a wise business decision. Questions are always encouraged. Contact us at 877-RUN-DASH during sales hours (Monday to Friday, 8:30 AM – 4:30 PM Central Time), or reach out 24/7 via email at

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