ATM Testing - October 13, 2025
As 2025 continues to wind down, many ATM operators still find themselves mired in the trenches of their PCI DSS 4.0.1 compliance initiatives. Full enforcement of the updated standard, including its "future-dated" requirements that have been mandatory since March 31, 2025, has transformed what was once only a looming deadline into a persistent operational nightmare for many organizations.
More than 9 months after the January 1, 2025, target implementation date for TR-31 support mandated by PCI DSS, full compliance remains elusive for many organizations. Industry estimates indicate that 60-70% of ATMs have been at least partially upgraded, but end-to-end certification—factoring in multi-vendor testing and Windows migrations—hovers at 40-50%, especially for mixed environments.
The risk of non-compliance is real and significant: transaction declines by processors, fines up to $100,000 per month, and ATMs taken offline all negatively impact revenue and erode consumer trust.
This blog examines where the industry stands today, recaps the foundational mandates, and spotlights how early, automated testing tools like Paragon's platforms are proving indispensable in dealing with this drawn-out process.
The Impact of PCI DSS 4.0 on the ATM Channel
Originally released in March 2022 (and refined to version 4.0.1 in 2024), PCI DSS 4.0 introduced more than 60 new requirements - covering areas like zero-trust principles, multi-factor authentication (MFA) for Cardholder Data Environment (CDE) access, automated logging, and targeted risk analyses, all aimed at supporting the main PCI DSS mission of “enhancing payment account data security and facilitating the broad adoption of consistent data security measures globally”.
Specifically related to the ATM channel, the PCI DSS spotlight is on PIN security:
- All upgradable ATMs must now support PCI PTS 5.x+ Encrypting PIN Pads (EPPs), and all non-upgradable units must be replaced.
- TR-31 key blocks that effectively support the interchange of symmetric keys in a secure manner are now mandated.
- For Remote Key Loading (RKL) the TR-34 protocol for transporting the encrypted key blocks is now also a mandated requirement.
While supporting these new requirements has caused complicated and potentially expensive implications for fleet owners, they are part of the long-term goal to better protect consumers, financial services companies, and the entire global payment industry.
Pain Points and Progress
The long and winding road toward compliance may seem unending for many fleet owners and operators. Current ATM vendor roadmaps and audits reveal a landscape where approximately 70% of deployed ATM hardware is upgraded, but both software integration and testing are lagging far behind, pushing as many as 25-30% of operators into overtime.
Not totally unexpected, supply chain delays of 6 to 9 months for EPPs and other ATM hardware components, as well as certification backlogs, have further highlighted the difficulty in achieving PCI DSS 4.0 compliance. Multi-vendor fleets, that now account for approximately 60% of global deployments, are reportedly facing interoperability issues, with failure rates for TR-34 certificate validation hitting approximately 30%. Bottlenecks like these underscores the need for modernization: manual testing in multi-vendor ATM environments can increase costs by as much as 40%.
Additionally, completion of the PCI DSS 4.0 compliance initiative now overlaps with Windows 10 EOL/Windows 11 migration activities, further complicating the already complicated equation. Teams that are struggling to deal with budget cuts, headcount reductions, ATM related fraud, and the continual demand to do more with less will find it increasingly difficult to meet project delivery dates and compliance deadlines.
Better Testing Tools Help Accelerate Compliance
Despite all of the operational challenges facing fleet owners and operators today, the ATM remains an important delivery channel for engaging with customers, who still expect (demand) immediate access to their money and financial services 24x7x365. So, on top of everything else, we need to ensure that ATMs are ready, responsive, and resilient - operating flawlessly every time a cardholder wants to transact. Comprehensive ATM testing is an essential part of ensuring we meet this requirement.
Continuous Evolution and Compliance
PCI DSS 4.0 and Windows 11 may be the latest challenges for the ATM industry to address, but they certainly won’t be the last. It is important to position your organization with the right tools and resources to deal with any challenge, any change, any compliance crisis that arises quickly, efficiently, and cost-effectively.
If your operations still rely too heavily on legacy technology tools and manual ATM testing processes, it is time to consider the many advantages that ATM virtualization and automation can provide. Faster test execution, expanded coverage, improved quality, increased control and collaboration, as well as remote access to the ATM test environment, will help your developers, testers, and QA resources be successful today and into the future.
By investing in testing tools that support virtualization and automation, ATM operators can confidently test and deploy any changes needed to keep their fleet reliable, secure, and compliant – all while helping their organization to consistently deliver a superior consumer experience at the lowest cost.
Ready to discuss how ATM virtualization and automation can help you deal with the accelerating pace of industry change?
Contact the Paragon team today.
A Guide to ATM Testing
In this guide, we explore a number of issues and challenges associated with the continued reliance on manual ATM testing and provide information and advice on how to use virtualization technology to automate and streamline the ATM testing process.
