EMV Level 3 certification is a complex endeavor for any payment processor, but in the United States, it comes with its own special set of challenges.
Here are some of the top challenges U.S. processors encounter when certifying payment terminals and why they make the process so demanding:
U.S. processors deal with many card networks (Visa, Mastercard, Discover, Amex, regional debit networks, etc.), each with slightly different test requirements.
This leads to “multi-network” certifications that are complex and lengthy. Ensuring one terminal meets the nuances of all networks is like hitting a moving target.
A pass on one network’s tests doesn’t guarantee a pass on another, so you end up running a huge battery of test cases.
The software in terminals isn’t static. There are firmware updates, security patches, and feature upgrades. Unfortunately, even minor updates can trigger the need for recertification in the U.S.
That means processors often find themselves in an ongoing cycle of testing. A small software fix to improve user experience might put you back in the certification lab for weeks, delaying improvements from reaching merchants.
Terminals in the U.S. must satisfy EMVCo specifications and additional standards like PCI PIN Transaction Security (PCI-PTS). Meeting both sets of requirements raises the bar for testing.
It’s not just about processing a chip card correctly; it’s also about demonstrating the device’s physical and software security (PIN encryption, tamper resistance, etc.). This dual necessity means more tests and sometimes conflicting priorities to juggle.
Gone are the days of just chip and swipe.
Today’s terminals must handle contactless cards and smartphone wallets (tap-to-pay via Apple Pay, Google Pay, etc.). Each of these introduces new layers of testing complexity.
For instance, a contactless transaction might involve different processing paths or fallbacks (like CDCVM – Consumer Device Cardholder Verification via a phone).
U.S. processors, catching up on contactless adoption, often have to certify these capabilities on terminals that originally were built just for contact EMV. It’s a learning curve with lots of trial and error.
Certification isn’t quick or cheap. In the U.S., a single terminal model’s EMV L3 certification can take 3 to 6 months and cost anywhere from $50,000 to $200,000 in total.
Why so long?
Because of all the factors above, including numerous test cases, recertifying after fixes, and limited lab availability, It all adds up.
And the cost isn’t just fees to labs or tools; it’s also the staffing cost of engineers and analysts working for months on test cycles. For smaller processors or those with many terminal models, this is a heavy burden.
Uniquely, the U.S. still uses chip-and-signature widely (customers sign receipts), whereas most of the world moved to PIN codes for credit cards.
So, terminals (and processors) in the U.S. must handle both methods.
This dual requirement effectively doubles some of the testing. For instance, you must test transaction flows where a PIN is entered and again where a signature is used to ensure there are no glitches in either path.
It’s a U.S.-specific complexity that global processors don’t face to the same degree.
The U.S. payments market has a lot of players, but not all of them are on the latest tech.
Some legacy terminals and systems are still in play, and they can struggle with modern EMV requirements.
Processors might have to accommodate older hardware that wasn’t originally designed with EMV in mind, using software workarounds.
Testing these can be tricky. Things that newer terminals handle easily might not work on older ones, leading to special-case test scenarios or even waivers (documented exceptions) for certain tests.
Certification testing often involves external certified labs or approval by the networks.
In the U.S., there are limited accredited labs, and during peak periods, they become bottlenecks.
Think about a deadline like a new Visa mandate coming into effect.
Suddenly, dozens of processors and terminal vendors rush to certify changes, and the labs get overbooked.
Processors face delays simply waiting in line for someone to evaluate their test results.
It’s like a traffic jam on the road to certification.
Payments is a regulated space. The U.S. has its own regulatory considerations (for instance, requirements from regulators for certain security features or differences in how debit routing must work by law).
These regional regulatory issues can impose additional certification checks or constraints.
For example, ensuring a terminal supports the mandated Common AID for U.S. debit networks is an extra step that might not exist elsewhere. Processors have to be mindful of these and include them in the testing scope, further broadening the effort.
Dealing with all these challenges means U.S. payment processors have to be extra diligent and organized in their certification projects.
It’s not surprising that many processors have entire teams dedicated to certification alone.
The stakes are high. A delayed or failed certification can hold up hardware rollouts and impact merchants’ ability to take payments.
Processors are actively seeking ways to ease this burden, from better project management to new automated tools.
However, recognizing the top challenges is the first step. If you’re a stakeholder in this space, knowing what you’re up against helps in planning better and perhaps advocating for industry-wide improvements (like more shared standards or more certification resources).
EMV certification is non-negotiable. The challenges might be tough, but they’re surmountable with the right approach. Processors that excel at navigating them turn a compliance exercise into a competitive advantage.
