Why Not to Delay Your AFD EMV Implementation

If you are old enough, you might remember when there were no cards. Merchants transacted through cash, and service stations were no different.

In order to save money and avoid risk, many countries, especially those “in development” continue to transact via cash only. In many countries that have decided to pursue card acceptance, even adopting EMV for an additional security measure, decouple the card reader from the fuel dispenser, instead opting for a regular terminal with a Wi-Fi connection to the store network. In these countries, consumers still have to tip the attendant in cash.

The Liability Shift

In July 2017, the US Payments Forum published a document titled “Understanding the U.S. EMV Liability Shifts” [1], in which they explained the nature of fraud risks and how the liability for this risk should be shifted, as it was for POS in stores in October 2015, at Automated Teller Machines (ATM) and AFDs.

The fraud types observed in the document are:

  • Counterfeit: Use of magnetic stripe cloned cards at terminals which do not support EMV chip cards.
  • Lost-or-Stolen: Use of authentic cards without requiring a PIN if the card was PIN-preferring.
  • Technical fallback: Force the use of magnetic stripe by failing the EMV chip reading on purpose.
  • Cross-border transactions: Misuse of non-US-issued cards in US territory OR US-issued cards outside the US territory.
  • Mobile and Contactless transactions: Use of MSD (Magnetic Stripe Data) Contactless on terminals which do not support, at least, contact EMV chip.

Originally, the Liability Shift for AFDs would start taking effect in 2016 for Mastercard, and 2017 (October) for the other networks in the United States. Due to challenges in solution readiness, the liability shift was delayed three more years, establishing October 1, 2020 as the AFD Liability Shift.

Pandemic Times

Even prior to the March 11 announcement from the World Health Organization (W.H.O.) that the Coronavirus (COVID-19) should be classified as a pandemic, the October 2020 liability shift date presented a scheduling challenge for merchants with AFD terminals. Only a few merchants had already implemented EMV solutions at their pumps, others were in the middle of certification processes, and others were still planning how to implement EMV card acceptance.

The need to maintain a safe distance between individuals to preserve health and avoid the quick spread of COVID-19 among people forced schools, restaurants and churches to close. Companies not providing essential goods and services instituted work-from-home policies for all employees.

After evaluating all the challenges that the pandemic imposed, Visa decided to delay the AFD Liability Shift date:

“The COVID-19 pandemic has impacted the world in ways nobody could have predicted. Because of the unprecedented circumstances created by COVID-19, Visa will further delay implementation dates and impact of certain previously announced U.S. interchange and fee changes to April 2021.”[2]

It did not take too long for the other payment brands to do the same.

American Express announced the delay on May 5[3], Discover on May 13[4] and Mastercard on May 18[5], with all brands postponing their shift date to April 16, 2021.

Should I slow down my implementation speed?

Though the card brands have delayed the liability shift date, W. Capra advises merchants to maintain momentum and refrain from delaying EMV AFD implementations for the following reasons:

  1. There is no certainty on when the pandemic is ending. Even when the contact restrictions become less rigid, there is no guarantee that the virus will not produce a second (possibly stronger) wave.
  2. Do not waste your current momentum that was built working towards the original October deadline. While EMV AFD implementations undoubtedly pose significant challenges, we recommend you use your experience navigating these challenges to capitalize on this implementation opportunity.
  3. There might be a bottleneck of qualified resources to aid in certification, implementation planning and execution in the short term. Procrastination will further exacerbate this potential resource bottleneck.
  4. Certification and implementation take time. Development does not mark the end of implementation. EMV Certification, Operation Pilot and Production Implementation must be included in any comprehensive project plan.
  5. When EMV is implemented, fraudsters will migrate to those who are not yet EMV-enabled; do not become part of the statistics.


Assume your deadline is still October 2020. If you hit this deadline, you will be safer six months before the AFD Liability Shift takes place, and if you hit an unforeseen delay, you will still have six months to recover versus scrambling at the last minute.

Now, more than ever, BE SAFE.

If you are interested on learning more about AFD EMV Certification and Implementation, do not hesitate and contact Victor Madera ([email protected]).

If you want to know more about the COVID-19 and its impact in your community, visit W. Capra’s investigation report at https://wcapra.com/covid-19-trends-by-state-may-20-update-2/

[1] https://www.uspaymentsforum.org/wp-content/uploads/2017/07/EMV-Fraud-Liability-Shift-WP-FINAL-July-2017.pdf

[2] https://usa.visa.com/support/merchant/library/visa-merchant-business-news-digest.html

[3] https://www.digitaltransactions.net/amex-extends-fuel-pump-emv-liability-shift-date-and-other-digital-transactions-news-briefs-from-5-5-20/

[4] https://csnews.com/american-express-discover-join-visa-delaying-emv-compliance

[5] https://www.businesswire.com/news/home/20200518005718/en/Mastercard-Announces-Consumer-Protection-Measures-Pump

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