Frequently Asked Questions

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How do PCI PTS-approved HSM expiry dates affect a PCI-listed P2PE Solution or Component?

FAQ Response

P2PE Solutions and applicable P2PE Components undergoing an initial assessment (i.e., they are not performing a reassessment on an existing PCI P2PE approval listing) must use non-expired HSMs (i.e., not exceeding the PTS HSM approval expiry date as denoted on the applicable PTS listing(s) or FIPS HSMs whose certificates are not on the NIST historical or revoked list).

PCI-listed P2PE Solutions and Components, as detailed in the P2PE Program Guide, require a full reassessment every 3 years as indicated by the associated “reassessment date” denoted on their PCI P2PE listing. These listed Solutions and Components are allowed to reassess their existing PCI P2PE approval up to but not exceeding 3 years past the expiry of any HSMs already included in their approval. This will be checked as part of the reassessment and submittal process to PCI SSC. As the reassessment (provided it results in an updated P2PE listing) is valid for 3 years, this will allow vendors to continue to use the expired HSMs for up to a total of 6 years after any associated PTS HSM listings have expired depending on their reassessment date.

The Approved PTS Device list with associated expiry dates can be found here:
https://www.pcisecuritystandards.org/assessors_and_solutions/pin_transaction_devices
Please refer to the PCI P2PE Standard and Program Guide in our document library for further details.

For quick reference, the following table provides the current PTS HSM expiry dates and the corresponding reassessment window for P2PE Solutions and applicable P2PE Components using these devices:

 

PCI PTS HSM Version

 

PCI PTS HSM Approval
Expiry Date

P2PE Reassessment End-Date
for Expired HSM Devices*

Expired PCI HSMs
End Of Life**

1.x

EXPIRED APR 2019

29 April 2022

29 April 2025

2.x

30 April 2022

29 April 2025

29 April 2028

3.x

30 April 2026

29 April 2029

29 April 2032

 


* Existing PCI-listed P2PE Solutions and applicable P2PE Components are prohibited from performing a reassessment with any expired HSMs that exceed the reassessment date shown relative to the associated PCI PTS HSM version. E.g., Any PCI-listed P2PE Solution or Component using a v1.x PCI HSM will be prohibited from performing a reassessment after April 29, 2022.
** P2PE Solutions and applicable P2PE Components must have replaced any expired HSMs with current (non-expired) HSMs by this date.
 

November 2019
Article Number 1469