Moving to EMV compliant terminals is not a plug-and-play endeavor. You can’t simply plug them in, turn them on and expect everything to work. Changes are needed to the software for supporting point-of-sale systems (cash registers). You will likely need to provision keys to devices; if you manage keys internally you will also need to make sure everything is safely stored in an HSM. There are often required changes to back-office software to sync up with the POS changes. IT staff typically need to be trained on the new equipment. Merchants who use payment processors or gateways that manage their terminals for them face less disruption, but it’s still a lot of work and rollouts can take months.
Much of the merchant pushback we heard was due to the cost, time, and complexity of this conversion. Merchants see basically the old payment system they have today, with one significant advantage: that cards can be validated at swipe. But merchants have not been liable for counterfeit cards, so have had little motivation to embrace this cumbersome change.
PINs vs. Signatures
Another issue we heard was the lack of requirement for “Chip and PIN”, meaning that in conjunction to the chipped card, users must punch in their PIN after swiping their card. This verifies that the user using the card owns it. But US banks generally do not use PINs, even for chipped cards like the ones I carry. Instead in the US signatures are typically required for purchases over a certain dollar amount, which has proven to be a poor security control. PINs could be required in the future, but the issuers have not published any such plans.
Point to Point Encryption
The EMV terminal specification does not mandate the use of point-to-point encryption (P2PE). That means that, as before, PAN data is transferred in the clear, along with any other data being passed. For years the security community has been asking merchants to encrypt the data from card swipe terminals to ensure it is not sniffed from the merchant network or elsewhere as the PAN is passed upstream for payment processing. Failure to activate this basic technology, which is built into the terminals, outrages security practitioners and creates a strong impression that merchants are cavalier with sensitive data; recent breaches have not improved this perception. But of course it is a bit more complicated. Many merchants need data from terminals for fraud and risk analytics. Others use the data to seed back-office customer analytics for competitive advantage. Still others do not want to be tied to a specific payment provider, such as by provisioning gateways or provider payment keys. Or the answer may be all of the above, but we do not anticipate general adoption of P2PE any time soon.
Why Move?
The key question behind this series is: why should merchants move to EMV terminals?
During our conversations each firm mentioned a set of goals they’d like to see, and a beef with some other party in the payment ecosystem. The card brands strongly desire any changes that will make it easier for customers to use their credit cards and grease the skids of commerce, and are annoyed at merchants standing in the way of technical progress. The merchants are generally pissed at the fees they pay per transaction, especially for the level of service they receive, and want the whole security and compliance mess to go away because it’s not part of their core business. These two factors are why most merchants wanted a direct Merchant-Customer Exchange (MCX) based system that did away with credit cards and allowed merchant to have direct connections with customer bank accounts. The acquirers were angry that they have been forced to shoulder a lot of the fraud burden, and want to maintain their relationships with consumers rather than abdicating it to merchants. And so on.
Security was never a key issue in any of these discussions. And nobody is talking about point-to-point encryption as part of the EMV transition, so it will not really protect the PAN. Additionally, the EMV transition will not help with one of the fastest growing types of fraud: Card Not Present transactions. And remember that PINs are not required – merely recommended, sometimes. For all these reasons it does not appear that security is driving the EMV shift.
This section will be a bit of a spoiler for our conclusion, but I think you’ll see from the upcoming posts where this is all heading. There are several important points to stress here. First, EMV terminal adoption is not mandatory. Merchants are not being forced to update. But the days of “nobody wanting EMV” are past us – especially if you take a broad view of what the EMV specifications allow. Citing the lack of EMV cards issued to customers is a red herring. The vast majority of card holders have smart phones today, which can be fully capable “smart cards”, and many customers will happily use them to replace plastic cards. We see it overseas, especially in Africa, where some countries process around 50% of payments via mobile devices. Starbucks has shown definitively that consumers will use mobile phones for payment, and also do other things like order via an app. Customers don’t want better cards – they want better experiences, and the card brands seem to get this.
Security will be better, and that is one reason to move. The liability waiver is an added benefit as well. But both are secondary. The payment technology change may look simple, but the real transition underway is from magnetic plastic cards to smartphones, and it’s akin to moving from horses to automobiles. I could say this is all about mobile payments, but that would be gross oversimplification. It is more about what mobile devices – powerful pocket computers – can and will do to improve the entire sales experience. New technology enables complex affinity and pricing plans, facilitates the consumer experience, provides geolocation, and offers an opportunity to bring the underlying system into the modern age (with modern security). If you are a merchant looking to justify an EMV investment, look no further than Starbucks and how they leverage apps for competitive advantage. Their story is about millions of users and the stickiness of their mobile app.
My next post will cover the liability shift, and I will follow up observations on how tokenization will disrupt the underlying security of payment systems.
Comments