PCI Compliance for ISOs: A Guide for 2025
As published in updated documentation in 2022, the PCI Security Standards Council has released new PCI DSS standards for ISO PIN encryption. The requirements and deadlines for ATMs are as follows:
- Phase 1 - Implementation Key Blocks for internal connections and key storage within Service Provider Environments - this would include all applications and databases connected to hardware security modules (HSM) - Effective 1 June 2019
- Phase 2 - Implement Key Blocks for external connections to Associations and Networks - Effective 1 January 2023
- Phase 3 - Implement Key Block to extend to all merchant hosts, point-of-sale (POS) devices and ATMs. (aka EPP hardware, firmware, and software using TR31 "Key Blocks") - Effective 1 January 2025
More information can be found in the PCI document library located at https://www.pcisecuritystandards.org/document_library/.
How will your machines be affected? Contact Cash Depot to find out more.
Why Implement?
- Non-compliant ATMs are considered a risk of fraud, brand damage, and loss of revenue
- Implementation could mitigate possible penalties and/or fraud liability. The ISO will ultimately hold the liability for their own ATMs for fraud and data breach; ATM Networks (e.g. Visa, Mastercard) could assess penalties on ISOS and require non-compliant ATMs to be shut down.
- Failure to implement TR-31 could leave an ATM vulnerable to more attacks and could ultimately result in payment and customer data compromises
- PCI and Networks' (card brands) requirements are intended to improve and enhance security and will change the way encryption keys are protected and managed
Compliance by Manufacturer
In an effort to provide comprehensive information for our partners, Cash Depot has gathered information from top manufacturers as a reference guide.
Hyosung Innovue
Non-Upgradable ATMs
Keyboard | ATM Model | Upgrade Path |
3000K |
1500 basic, 1800 basic, 1800CE, 2100T, NH1000, NH2100, NH2200, Nano Cash, 5000CE, 5050CE, 5300CE |
Replace ATM |
5000K |
1500 basic, 1800 basic, 1800CE, 2100T, NH1000, NH2100, NH2200, Nano Cash, 5000CE, 5050CE, 5300CE |
Replace ATM |
6000K/R |
1500 basic, 1800 basic, 1800CE, 2100T, NH1000, NH2100, NH2200, Nano Cash, 5000CE, 5050CE, 5300CE |
Replace ATM |
8000R |
1500 basic, 1800 basic, 1800CE, 2100T, NH1000, NH2100, NH2200, Nano Cash, 5000CE, 5050CE, 5300CE |
Replace ATM |
EPP-X1 |
1500 basic, 1800 basic, 1800CE, 2100T, NH1000, NH2100, NH2200, Nano Cash, 5000CE, 5050CE, 5300CE |
Replace ATM |
Upgradable ATMs
Keyboard | ATM Model | Upgrade Path |
3000K |
1500SE, 1800SE, 2700 (T), Halo, Halo 2, Force, 4000W, MX5000(SE), 5200SE, 5300SE, 5400SE |
Replace Keyboard & Update Software |
5000K |
1500SE, 1800SE, 2700 (T), Halo, Halo 2, Force, 4000W, MX5000(SE), 5200SE, 5300SE, 5400SE |
Replace Keyboard & Update Software |
8000R |
1500SE, 1800SE, 2700 (T), Halo, Halo 2, Force, 4000W, MX5000(SE), 5200SE, 5300SE, 5400SE |
Update Software |
EPP-X1 |
1500SE, 1800SE, 2700 (T), Halo, Halo 2, Force, 4000W, MX5000(SE), 5200SE, 5300SE, 5400SE |
Update Software |
Identification Instructions - Look at the backside of the keyboard to determine keyboard type and follow path in previous chart. For more information, visit https://hyosungamericas.com/storage/app/media/Legal%20Document%20PDFs/Hyosung-PCI-Compliance-Update-PCI-PTS-v5-.pdf
Genmega
Per Genmega:
- B3 and B5 keypads CAN support TR-31 but will require a software update when the time is right
- B1 and B2 keypads will NOT support TR-31. The keypad and bracket must be replaced and a software update may be required to support B5
- C4000 with ACU1 Board will NOT support TR-31. The motherboard must be replaced along with the keypad and mounting hardware
Keyboard | Upgrade Path | |
Pre-2006 | B1 EPP Embedded | Replace ATM |
2006-2008 | B1 EPP C4000 |
Replace Keyboard, Change Out Board, Updated Software |
2008-2014 | B1 & B2 EPP |
Replace Keyboard & Update Software |
2014-Current | B3 & B5 EPP |
Update Software |
Click here for supporting documentation.
Triton
After their initial presentation on Triton models at the National ATM Council show, NAC2021, feedback from Triton customers pushed the manufacturer to create an upgrade path for the popular 9100 model. The company encourages businesses interested in the 9100 upgrade to fill out the form located here - https://triton.com/9100-tr-31-t10-keypad-upgrade/ The original control panel in the 9100 will not support the T-10 EPP and production for the 9100 upgrade kit will be limited.
For RL/FT series, Traverse, and ARGO series ATMs, there is only an EPP change and software update. As with previous mandates, especially EMV, there could get additional software updates prior to the January 1, 2025 cut-in date. These upgrades are going to consist of migrating from a T5, T7, or T9 EPP to the new T10.
The upgrade kits are slightly different in that a migration from a T7 to a T10 will require an extra cable. This LINK will help customers in the field distinguish which keypad they have.
Model | Keypad Model | PCI Version | Replace ATM? | Software Update | Keypad Replacement |
9600 | T6 | 1.x | Yes | NONE | NONE |
9700 | T6 | 1.x | Yes | NONE | NONE |
8100 | T6 | 1.x | Yes | NONE | NONE |
9100 | T6 | 1.x | Yes/No (form) | w/T10 | T10 |
RL100 | T7 | 1.x | No | w/T10 | T10 |
T5 |
1.x w TKM |
No | w/T10 | T10 | |
T9 |
3.1 |
No | w/T10 | T10 | |
RL200 | T7 |
1.x |
No | w/T10 | T10 |
T5 |
1.x w TKM |
No | w/T10 | T10 | |
T9 |
3.1 |
No | w/T10 | T10 | |
RT2000 | T7 |
1.x |
No | w/T10 | T10 |
10.4" Screens Only | T5 |
1.x w TKM |
No | w/T10 | T10 |
T9 |
3.1 |
No | w/T10 | T10 | |
FT5000 | T7 |
1.x |
No | w/T10 | T10 |
T5 |
1.x w TKM |
No | w/T10 | T10 | |
T9 |
3.1 |
No | w/T10 | T10 | |
ARGO 7.0 | T9 |
3.1 |
No | w/T10 | T10 |
T10 |
5.x |
No | TBD | None | |
ARGO 15.0 | T9 |
3.1 |
No | w/T10 | T10 |
T10 |
5.x |
No | TBD | None | |
ARGO FT | T9 |
3.1 |
No | w/T10 | T10 |
T10 |
5.x |
No | TBD | None |
How will your machines be affected? Contact Cash Depot to find out more.