PCI PTS Compliance: A Necessary Step, But Not the Full Story

Read time:05:00

Release date:11.28.2025

The PCI PIN Transaction Security (PTS) standard defines strict requirements for devices that handle and protect PINs and sensitive transaction data - such as encrypting PIN pads (EPPs), POS terminals, and hardware security modules. Certification under PCI PTS ensures that approved components meet the minimum criteria for secure design, encryption, and tamper resistance.

Although PCI PTS approval validates the security of the certified PIN-entry component, it does not cover the security of the entire payment solution. Even if an ATM or self-service POS terminal includes a PCI PTS approved PIN pad, the rest of the system - including terminal software, operating system, communication channels, encryption processes, backend interfaces, and any temporary or permanent data storage - must still comply with the relevant PCI PIN, PCI DSS, and scheme-specific requirements. These areas, which fall outside the scope of PTS approval, are where real-world vulnerabilities most often emerge.  

While certification validates the resilience of the PIN-entry component, it does not evaluate how securely the device behaves once integrated into a full solution - nor how it performs in the field against real attackers. 

When Certified Devices Still Get Compromised  

History shows that compliance does not guarantee immunity. Over the past decade, several high-profile attacks have demonstrated that PCI-approved components can be exploited once deployed in complex, real-world environments 

These kinds of incidents occur not because the certified hardware is weak, but because attackers try to exploit everything around it - software, integrations, networks, backend systems, and operational mistakes. 

These examples highlight an important outcome: compliance ensures a baseline, but security depends on how the device and the complete ecosystem perform under real-world attack conditions.  

Emerging ATM Threats in 2025: Beyond Certification 

According to recent industry analysis, ATM networks are now facing three major security challenges that complicate the landscape - and which PTS approval alone does not fully address:

  1. Quantum Computing Threats  about blogs/combating 3 atm security threats in 2025/
    • Quantum computers could one day break today’s standard encryption, putting ATM communications at risk.
    • Financial institutions should start planning now by adopting post-quantum cryptography to stay ahead.  
  1. Stricter TR-31 Key Management Regulations about blogs/combating 3 atm security threats in 2025/

    • New TR-31 standards mandate stronger encryption key-block management within ATM networks. 
    • Remote Key Loading (RKL) and compliant hardware/software upgrades may be required to meet TR-31. 
    • Institutions need to assess their key management systems and possibly adopt modern solutions (e.g., the TSS A98 system) to comply. 
    • Many ATM networks still use legacy hardware or software that lack modern security controls.
    • Upgrades (software, hardware, key management) are necessary to reduce risk - but they are costly and complex.  

 The Risks for Payment Device Manufacturers 

Manufacturers often assume that once a device receives PCI PTS approval, its security posture is fixed. In reality, multiple risks remain: 

  • Implementation bugs missed during certification
  • Misinterpretation of which components or communication channels must be certified
  • Weaknesses in firmware signing or software update mechanisms
  • Insecure third-party components outside PTS scope 

While these devices are designed to be highly secure and are not easily compromised, a determined and skilled malicious attacker may still discover a weakness. When that happens, the impact is immediate: even a single vulnerability can translate into significant risk in the field, potentially triggering product recalls, re-certification efforts, and reputational damage - issues that are both costly and time-consuming for manufacturers. 

Regular offensive penetration testing ensures that devices remain robust well beyond their initial certification. 

The Risks for Payment Solution Providers 

Payment solution providers - those integrating devices into complete payment systems - face additional risks. While using PCI PTS approved hardware is mandatory, the integration, configuration, and deployment process introduces new attack surfaces.

These risks include:

  • Insecure interfaces or communication paths
  • Outdated middleware
  • Misconfigured or exposed remote-management services

Without testing early - even during the design phase - providers risk system outages, data exposure, and deteriorating trust from acquiring banks. 

These consequences are often far more damaging than a failed compliance audit. 

The Risks for Financial Institutions 

Banks, acquirers and merchants rely on PCI PTS approved devices to ensure secure transactions but once deployed across thousands of locations, operational security becomes the primary challenge.

Attackers frequently target: 

  • POS hardware weaknesses and weak design
  • ATM and POS software vulnerabilities
  • Weak encryption implementations
  • Network connectivity
  • Software update channels
  • Remote administration tools

Beyond jackpotting, the 2025 threat landscape includes malware targeting ATM software, exploitation of legacy infrastructure, and potential future risks to encryption from quantum computing. 

Compromise in any of these areas can lead to fraudulent transactions, direct financial loss, and erosion of customer trust. 

Real-world penetration testing helps ensure that deployed systems behave securely under actual field conditions - not just in certification labs. 

The Risks for Merchants and End-Users 

Retailers and service operators rely on certified terminals but often overlook operational factors:

  • Physical tampering
  • Insecure network segmentation
  • Weak passwords or administrative controls

These gaps can enable skimming, data theft, and chargebacks, ultimately affecting revenue and customer confidence.

Even the most secure hardware cannot compensate for an insecure environment. 

Beyond Compliance: Why Real-World Security Testing Matters 

To maintain long-term resilience, stakeholders across the payment ecosystem - manufacturers, solution providers and financial institutions - must treat PCI PTS and PCI DSS as the foundation, not the finish line.

Even at an early phase or later, once the components are already certified real-world penetration testing and vulnerability research may expose flaws that certification testing can’t - validating security under realistic attack conditions simulating real attack scenarios with a motivated hacker mindset 

This is where PCA Cyber Security adds value. With deep expertise in the offensive security of embedded systems and payment technologies, our team acts as an extension of your security organization.

We understand how highly motivated attackers work, so we simulate the latest attack techniques targeting: 

  • payment terminals, 
  • PIN pads,  
  • ATMs,  
  • backend systems,
  • transaction processing flow.

By thinking like adversaries, we help you uncover and fix weaknesses before attackers exploit them. 

A compliant product is not necessarily a secure product.  

Partnering with PCA Cyber Security means investing in long-term, real-world resilience, not just regulatory compliance. 

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