A P2PE application that is used outside a PCI-listed P2PE solution may also be subject to PA-DSS per the PA-DSS Program Guide requirements.
Whether an entity is required to use a PA-DSS validated application is determined by individual payment brand mandates, and not by PCI SSC. For information about payment brand requirements for use of PA-DSS validated applications, please contact the payment brands directly. Payment brand contact details can be found in FAQ How do I contact the payment card brands?.
Article Number 1261