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Visa’s 2025 ATM Rule Changes: What You Need to Know (US Region)

Visa released revised Network Operating Rules (“Rules”) in October 2025 that materially change how the ATM industry must operate in the United States. These requirements are not optional and are in effect. Below is a plain-English overview and an FAQ to help you comply.

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Who this page is for: Independent ATM deployers, operators, agents, and sponsored portfolios connected through Switch Commerce.

The Quick Summary

  • Electronic journals (EJs) are now mandatory and must include additional data elements defined in the Rules.

  • You must verify and document each ATM’s physical address (and keep proof).

  • Acquirers and Visa can audit at any time. Be ready with fleet inventory, EJ records, specs, and site verification.

  • Use the correct MCC and indicators to identify ATM cash disbursement transactions—every time.

  • Only legal transactions may be submitted. Cashless “ATMs” are prohibited.

 

How Switch Commerce helps: We’re updating our Terminal Management System (TMS) to make EJs mandatory, expanding terminal configuration data, coordinating with sponsor banks and manufacturers, and providing guidance so you can implement the Rules efficiently.

QuickSummary

What Changed

WHATCHANGED

Rule 6.2.4.2 – ATM Operator Agreement Requirements (Effective Oct 18, 2025)
 

Your ATM Operator agreement must state that you will:

  • Submit only legal transactions. Do not knowingly submit any transaction that is illegal or should be known to be illegal.

  • Validate each ATM’s location and maintain detailed records, including the date of the last address verification.

  • Provide, upon request:

    • Complete ATM fleet inventory

    • Electronic journal records (EJs)

    • Any other data Visa requests

  • Permit audits and reviews by your ATM Acquirer or Visa (directly or via agent) at any time.

  • Acknowledge Visa’s right to limit or terminate agreements (with you or your agent) if necessary.

  • Require your agents to comply with the Visa Rules.
     

Additional US requirement to include in your agreement:

  • ATMs must disburse cash in the local currency and are only owned, leased, controlled, or sponsored by banks, savings and loan associations, and credit unions (as defined in the Rules).
     


Rule 6.2.4.3 – Acquirer Requirements for ATM Operators (Effective Oct 18, 2025)

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Your ATM Acquirer must:

  • Perform due diligence on each operator, including verifying ATM locations. If suspicious activity is identified, Visa may require a physical site inspection.

  • Ensure operators and agents maintain records and make them available on request, including:

    • Location of all ATMs (including sponsored ATMs) and the date of last address verification

    • ATM specifications: make, model, PCI-compliant keypad, software version

    • EJ records covering: account transfers, balance inquiries, bill sequencing (if available), cash balance and loads, cash deposits and withdrawals, receipt paper replenishment, and any other data Visa requests

  • Ensure correct coding: The operator must use the appropriate MCC and other required indicators to identify ATM Cash Disbursement Transactions.
     


Rule 6.2.5.1 – ATM Acquirer Processing (Effective Oct 18, 2025)
 

  • Acquirers must conduct adequate due diligence of ATM operators—including a site visit or suitable alternative—to ensure only legal transactions are submitted to VisaNet.

What Switch Commerce Is Doing

WHATSWITCHDOING

  • Making EJs mandatory in TMS. We’re changing EJ settings from optional to mandatory so we can begin receiving journals as soon as you enable them at each terminal.

  • Building compliant EJ storage. We reviewed terminal message formats to support Rule-defined EJs. One element, receipt paper replenishment, is not currently passed by any terminal messages we receive. We have engaged terminal manufacturers and are working with sponsor banks on availability and timelines to capture this data element.

  • Expanding terminal configuration and records. We’ll continue updating terminal configuration fields and guidance to help you stay audit-ready.

  • Ongoing guidance. We’re actively engaged with sponsor banks, customers, and partners to share best practices and implementation expectations as they evolve.

What You Need to Do NOW 

CHECKLIST

  1. Enable EJs on every ATM. This is required under the Rules.

  2. Verify and document each ATM’s address. Keep proof (e.g., on-site photos of the terminal inside the location, plus a live transaction to validate the terminal ID at that address).

  3. Update TMS whenever an ATM moves. Event, seasonal, or mobile ATMs must be updated to the current location each time they change.

  4. Maintain complete records for at least 5 years (per current sponsor bank requirements): fleet inventory, address verification dates, ATM specs, and EJ records.

  5. Use the correct MCC/indicators for ATM Cash Disbursement Transactions—no exceptions.

  6. Submit only legal transactions. If a device doesn’t automatically dispense local currency, it’s not an ATM transaction and must not be submitted.

 

Need help? Contact Switch Commerce Partner Support for step-by-step enablement and documentation guidance.

Frequently Asked Questions

FAQ
How do these Rules impact my day-to-day?

 

They require contract updates, site verification, mandatory EJs, and readiness for audits. None of these requirements are optional, and all must be implemented.

 

 

What exactly am I responsible for as an operator?

 

You’re responsible for verifying and validating each ATM site (including make, model, specs, and current address) and for maintaining EJs and related records as defined in the Rules.

 

 

Are the new EJs different from what I use today?

 

Yes. Traditional EJs used for Reg E representments were often optional and narrower in scope. The Rule-defined EJs are mandatory and include additional data elements that were not previously required for representment.

 

 

Can Switch Commerce store Rule-compliant EJs?

 

We’ve designed an EJ storage approach aligned with the Rules. During our review, we found that receipt paper replenishment is not currently included in the terminal messages we receive. We’ve contacted terminal manufacturers to confirm whether this can be provided and requested timelines if changes are needed. We’re working with sponsor banks and manufacturers to resolve this gap so that EJs meet all Rule requirements.

 

 

How long will EJs be stored?

 

Following discussions with sponsor banks, the current requirement is 5 years.

 

 

When should I enable EJs?

 

Immediately. The Rules are in effect now, and EJs are required. We’re updating our TMS to make EJs mandatory, so we can begin receiving journals as soon as you enable them at each terminal.

 

 

What happens if I don’t enable EJs or my ATM can’t send them?

 

Sponsor banks have indicated that failure to enable EJs will create a compliance issue. This may require suspending services at any non-compliant ATM until EJs are enabled. We will notify you of your portfolio’s progress and update terminal configurations to assist. If you need help enabling EJs, contact Partner Support or your ATM manufacturer.

 

 

What proof is required for address verification?

 

Because this is evidence-based, not just a database entry, you should expect to capture on-site photos of the terminal inside the stated location and perform a live transaction to validate the terminal ID at that address. We’ll share more specifics as sponsor bank expectations are finalized.

 

 

How do I handle event, seasonal, or mobile ATMs?

 

Update the address in TMS every time the ATM moves and complete the address validation process for each new location.

 

 

What is an “illegal transaction” under the Rules?

 

The most notable example is a cashless ATM. For the avoidance of doubt, cashless ATMs are not allowed to be processed on Switch Commerce. A valid ATM transaction automatically dispenses local currency from the terminal (e.g., USD in the United States).

If a terminal only prints a receipt or dispenses anything other than local currency, it is not an ATM transaction and must not be submitted. Submitting non-compliant transactions will result in immediate suspension of services for that ATM and may lead to termination under the Rules.

 

 

Where can I read the full Rules?

 

The complete Rules are available on Visa.com. 

Stay Compliant with Switch Commerce

STAYCOMPLIANT

We know new Rules create uncertainty and extra work. Our team is actively coordinating with sponsor banks and terminal manufacturers to streamline implementation and keep you compliant with minimal disruption.

 

Questions or next steps?

  • Partner Support: We’re here to help you enable EJs, verify addresses, and update TMS.

  • Portfolio Reviews: Ask us for a progress snapshot of your fleet’s compliance status.

 

Disclaimer: This page is for informational purposes only and does not constitute legal advice. Always consult the Visa Rules and your sponsor bank for definitive requirements.
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