Card Machine Security & PCI DSS: How to Protect In-Person Payments
Published - 05 February 2024
Revised - 27 August 2026


Libby James is the founder and Managing Director of Merchant Advice Service. Since 2016, she has worked directly with businesses and payment providers across merchant accounts, card processing, payment gateways and complex provider requirements.
Libby specialises in high-risk, declined and harder-to-place merchants, as well as businesses requiring specialist payment methods, integrations or international support. She writes and reviews Merchant Advice Service content, drawing on practical experience gained from real merchant enquiries and provider relationships.
Card-machine security is not just about encrypting a transaction.
For businesses accepting face-to-face card payments, security also means knowing:
This becomes particularly important for retailers, restaurants, hotels and multi-site businesses operating dozens or hundreds of payment terminals.
Under PCI DSS, specific requirements apply to point-of-interaction devices used for card-present transactions.
Card-machine security therefore starts with a simple principle: know which devices should be there, check that they are still the same devices, and make sure staff know what to do if something looks wrong.
Card-machine security covers the measures used to protect payment terminals, the information they process and the wider environment in which they operate.
This includes:
The terminal itself is only one part of the payment environment.
An integrated retail setup might involve:
EPOS → terminal → payment application → terminal-management system → processor/acquirer → settlement and reporting.
Security therefore needs to consider how those components interact.
PCI DSS Requirement 9.5 specifically addresses point-of-interaction devices used in card-present transactions.
PCI SSC identifies three core controls:
This applies to deployed point-of-interaction devices that capture payment-card data through direct physical interaction with the card or payment form factor — for example where a card is:
Read PCI SSC's guidance on Requirement 9.5.
You cannot reliably identify a substituted card machine if nobody knows which card machine is supposed to be there.
No — PCI DSS Requirement 9.5 does not itself require every payment terminal to be physically fixed to a surface using a cable, bracket or tether.
PCI SSC expressly clarifies this point.
The requirement focuses instead on:
A business may still decide that physically securing a terminal is appropriate for its environment.
For example, it could help reduce:
But a cable should not be mistaken for the whole security control.
Not automatically.
A countertop terminal may be easier to control physically because it normally remains in one location.
A portable terminal may move between:
That can create different operational controls, but it does not mean the device is inherently less secure.
Security depends on the complete implementation, including:
The purpose of a terminal inventory is to help the business identify its authorised payment devices.
Depending on the environment, useful information can include:
A multi-site business should maintain this centrally rather than relying entirely on individual locations to remember which devices they have.
PCI DSS requires applicable devices to be inspected periodically, but it does not prescribe one universal inspection frequency suitable for every merchant.
The appropriate frequency should take account of the merchant's environment and risk.
Factors may include:
A terminal at a permanently staffed reception desk and one left in a publicly accessible unattended environment may justify different controls.
The objective is to identify changes that may indicate the terminal has been tampered with or replaced.
Checks can include:
The business should follow the inspection guidance supplied by its payment provider and terminal manufacturer.
Staff should not dismantle a payment terminal themselves to determine whether it has been tampered with.
If something appears suspicious, stop using the device and follow the agreed escalation procedure.
Unauthorised substitution occurs when a legitimate payment terminal is replaced with another device without the merchant's permission.
This is one reason maintaining an accurate device inventory is important.
For example, staff should question:
Yes.
Staff should not automatically allow someone access to payment devices simply because they say they are from the terminal provider.
A merchant's procedure might include:
This is particularly important in businesses where many staff members work shifts and may not know whether an engineer visit was arranged by head office.
A new terminal should enter the payment environment through a controlled process.
That might include:
For a multi-site rollout, this should form part of the formal deployment process rather than being left to each individual location.
Old payment terminals should not simply be put in a cupboard indefinitely or discarded with ordinary office equipment.
Establish:
Keep records of returned equipment, particularly where multiple terminals are being replaced.
PCI SSC maintains the PIN Transaction Security Point of Interaction — PTS POI — Standard.
The standard contains security requirements for devices used to protect:
at the point of interaction.
The current PCI SSC document library lists PCI PTS POI Modular Security Requirements v7.0.
Read PCI SSC's PTS Point of Interaction information.
PCI DSS itself does not universally require the use of PTS-approved devices.
PCI SSC notes that payment brands may have their own requirements concerning PTS-approved hardware.
Businesses should therefore confirm acceptable terminal requirements with:
This distinction matters because:
PCI DSS compliance and terminal-device approval are related but separate concepts.
Point-to-Point Encryption — P2PE — protects account data by encrypting it from the point of interaction through to a secure decryption environment.
PCI SSC maintains a dedicated P2PE standard and listings of validated P2PE solutions.
Where a merchant correctly implements a PCI-listed P2PE solution, the number of PCI DSS requirements applicable to the merchant's cardholder-data environment can be significantly reduced.
However, PCI SSC is clear that P2PE does not completely remove PCI DSS applicability.
Read PCI SSC's guidance on P2PE and PCI DSS scope.
Encryption is valuable, but “our terminals are encrypted” is not the same as saying the merchant is using a PCI-listed P2PE solution.
PCI SSC publishes listings for validated payment-security solutions.
Merchants considering P2PE should confirm:
Simply seeing the term “P2PE” in sales material is not enough.
Not automatically.
PCI SSC clarified again in March 2026 that encryption alone is not sufficient to make cardholder data automatically out of scope for PCI DSS.
The scope impact depends on the architecture, access to decryption capability and whether a recognised validated solution such as PCI-listed P2PE is being used correctly.
Read PCI SSC's current guidance on encrypted cardholder data and scope.
Potentially.
An integrated terminal communicates with systems such as:
The merchant needs to understand:
See our Integrated Card Machines & EPOS Compatibility guide.
A Terminal Management System — often abbreviated to TMS — can be used by payment providers or other authorised parties to manage payment terminals remotely.
Depending on the implementation, it may support activities such as:
Remote management can be operationally valuable, especially for large terminal estates.
But access to payment infrastructure must itself be secured.
PCI SSC's guidance for payment-terminal environments highlights controls around supported applications, security updates and multi-factor authentication for applicable remote access into the cardholder-data environment, including payment terminals and terminal-management systems where relevant.
Responsibility depends on the provider and architecture.
Updates may be managed by:
The important thing is that ownership is clear.
Businesses should understand:
Potentially.
A terminal may need replacing where:
The fact that a terminal still powers on does not necessarily mean it should remain in service.
UK 3G mobile networks have now been switched off, and UK mobile operators are also phasing out 2G.
Older payment terminals dependent on legacy connectivity may therefore require replacement or reconfiguration.
This is primarily a connectivity issue, but keeping obsolete unsupported hardware in service can also create operational and security-management problems.
See our Portable Card Machines guide for the current connectivity position.
They can require different physical controls because they move around the business.
For example, a hospitality business may need to know:
Portable-terminal security should therefore be built into operational processes rather than treated as an IT-only issue.
The merchant should follow its payment-provider and incident-response procedures immediately.
Depending on the setup, this may include:
Do not simply replace the hardware without investigating what happened to the original device.
They should not continue using it simply because payments still appear to work.
An internal procedure should tell staff to:
A terminal processing payments successfully is not proof that the device is legitimate.
PCI DSS expects personnel in relevant point-of-interaction environments to be aware of attempted tampering and device substitution.
Training can cover:
This is particularly important for businesses employing temporary, seasonal or high-turnover staff.
Yes, as part of a controlled change process.
After legitimate maintenance or replacement, consider:
Unattended payment environments can include:
These can create different physical-security considerations because a member of staff may not be continuously present.
The PCI PTS POI Standard includes security requirements relevant to categories including unattended payment terminals.
Merchants should work with their acquirer, payment provider and technology supplier to establish the correct controls for their particular environment.
For a multi-location merchant, terminal security needs central governance.
A useful framework can include:
A 100-site retailer should not have 100 different approaches to handling payment terminals.
Once a merchant has a large terminal estate, payment-device security becomes an asset-management discipline as well as a PCI requirement.
Potentially.
Simply changing provider does not automatically alter PCI DSS scope.
But the migration may also change:
Those changes can affect the merchant's PCI DSS environment and validation requirements.
See our Changing Card Processor & PCI DSS guide.
Businesses accepting card-present payments should be able to answer:
We would separate terminal security into six areas.
Does the business know exactly which terminals are authorised and where they are?
Can tampering, substitution, loss or unauthorised access be detected and escalated?
Are terminals, applications and integrations supported and appropriately secured?
How is payment data protected, and is a validated P2PE solution involved?
Who can install, configure, remotely manage and replace payment devices?
How are terminals ordered, deployed, inspected, upgraded, replaced and decommissioned?
The strongest card-machine security controls cover the entire life of the device — from the moment it arrives to the moment it leaves the business.
Merchant Advice Service helps businesses compare payment providers and payment architectures, including the practical implications of changing terminal estates.
When reviewing a card-machine setup, we may consider:
Formal PCI DSS validation and security advice should be obtained from the merchant's acquirer, payment provider, Qualified Security Assessor or other appropriately qualified PCI professional where required.
Businesses can explore payment providers through The Payments Directory® or read How Merchant Advice Service Works.
The current PCI SSC document library lists PCI DSS v4.0.1 as the current PCI Data Security Standard.
PCI SSC confirms that Requirement 9.5 covers device inventories, periodic inspections and staff training for applicable card-present POI devices. It also confirms that PCI DSS does not specifically require every terminal to be physically tethered to a surface.
PCI SSC — POI Tampering and Substitution Guidance
The PTS POI Standard establishes security requirements for devices protecting PINs and sensitive payment-card data at the point of interaction.
PCI SSC confirms that use of a PCI-listed P2PE solution can significantly reduce applicable PCI DSS requirements but does not completely remove PCI DSS applicability.
PCI SSC — Effect of P2PE on PCI DSS Validation
PCI SSC's March 2026 guidance confirms that encryption alone does not automatically render cardholder data out of PCI DSS scope.
PCI SSC — Encrypted Cardholder Data and PCI DSS Scope
Merchant Advice Service is an independent payments information, comparison and provider-matching service.
MAS may receive commission or a referral fee from some payment providers where a business chooses to proceed following an introduction. This does not determine the factual information or security principles included in this guide.
PCI DSS requirements vary according to the merchant's payment environment, systems, payment channels and validation requirements.
PCI DSS Requirement 9.5 applies to relevant deployed POI devices used for card-present transactions. PCI SSC states that these requirements do not apply in the same way to certain components, including commercial off-the-shelf smartphones and tablets, although similar controls may remain sensible operational practices.
PCI DSS does not universally require every merchant to use a PTS-approved terminal. Separate payment-brand, acquirer or provider requirements may apply.
A PCI-listed P2PE solution can reduce PCI DSS scope but does not completely remove PCI DSS applicability. Encryption alone should not be assumed to make cardholder data out of scope.
Formal PCI DSS validation, security architecture and incident-response requirements should be confirmed with the merchant's acquirer, payment provider, QSA or appropriately qualified PCI professional.
Security standards, device approvals, terminal software and provider requirements can change.
Merchant Advice Service does not provide PCI certification or guarantee that a particular payment environment is PCI DSS compliant.
PCI and security information last checked: 27 August 2026
This guide provides general payments information and should not be treated as legal, regulatory, cybersecurity or formal PCI compliance advice.
Written or reviewed by Libby James, founder of Merchant Advice Service and specialist in merchant payments and complex provider requirements.