EN 18031-3 certification involves 5 core phases: Compliance Assessment → Documentation Preparation → Scenario-Based Testing → Audit & Certification → Ongoing Compliance, with a total timeframe of 6-12 months. As the anti-fraud provisions under EU Mandate (EU) 2022/30 take mandatory effect on August 1, 2025, this certification becomes a non-negotiable requirement for financial wireless devices entering the EU market. Surging demand has led to a shortage of Notified Body audit resources, extending lead times by 30%-50% compared to previous years. Timeframes vary significantly by product risk: 6-8 months for basic POS terminals, 10-12 months for high-risk devices like cryptocurrency wallets.

Businesses exporting EU financial wireless devices know EN 18031-3 certification is never just “going through the motions”—it’s a dual battle against time and compliance. With the 2025 mandatory deadline approaching, 80% of businesses face delays due to poor early preparation or misjudged lead times; some even miss inventory clearance deadlines and face product bans.

I.Preliminary Compliance Assessment: 1-2 Months

The “foundation phase” of certification—simple in appearance but prone to pitfalls. Many businesses have to start over later due to incorrect early risk assessment.

Core Actions:

·Clarify product scope: Confirm if your device falls under EN 18031-3 (wireless devices handling financial/digital asset transactions, e.g., POS terminals, crypto wallets, cross-border payment terminals) to avoid misaligning with EN 18031-1/2.

·Accurate risk classification: Use the EU official risk assessment tool to define risk levels (basic/advanced/high-risk). High-risk devices need additional compliance for private key protection and transaction hijacking prevention.

·Pre-select bodies & confirm scheduling: Screen Notified Bodies with RED Directive qualifications and expertise in financial devices. In 2025, top bodies have lead times 2-3 months out—confirm testing scope and audit windows early to avoid passive waiting.

Timeframe & Pitfalls:

·Standard 1-2 months; add 1 extra week if products integrate multi-scenario functions (e.g., payment + data transmission) to confirm compliance priorities.

·Pitfall: Never skip risk assessment for documentation. A business once misclassified a cross-border payment terminal as basic risk, leading to missed test items and 1.5 extra months for supplementary testing.

  II.Technical Documentation Preparation: 2-3 Months

The easiest phase to get stuck—only 40% of documentation passes first audit, with average 2-4 weeks for supplements, directly delaying the entire process.

Core Actions:

·Basic technical documents: Product schematic diagrams, PCB layouts, BOM lists (encryption chips must note EAL5+ certification numbers), English user manuals—all compliant with GDPR data protection requirements.

·Financial security-specific documents: EN 18031-3 core, including threat modeling reports (covering fraud scenarios like transaction tampering and payment hijacking), risk assessment reports, encryption mechanism descriptions (complying with RSA-2048 or ECC-256), and anti-fraud design documents.

·Supply chain compliance documents: Obtain compliance declarations from core component suppliers (especially encryption chips, payment SDKs, wireless modules). In 2025, bodies mandate component-level security audit reports—missing documents lead to immediate rejection.

·Prototype preparation: Prepare 4-6 prototypes (standard factory units + test units with open debug interfaces); high-risk devices need 2 extra units for anti-tamper and sensitive data self-destruction testing.

Timeframe & Pitfalls:

·Standard 2-3 months; SMEs with poor documentation management may take 3.5 months.

·Pitfall: Documents must be in English or EU official languages—Chinese documents need professional translation. A business once faced 3 extra weeks for retranslation due to non-standard translations; ensure prototypes are stable to avoid test interruptions from malfunctions.

  III.Scenario-Based Testing: 3-6 Months

The longest certification phase. Unlike general cybersecurity certification, EN 18031-3 test cases are built around real financial fraud scenarios, with higher complexity and 40% failure rate—rectification and retesting add significant time.

Core Actions:

·Pre-testing: Entrust qualified labs for preliminary testing, focusing on encryption protocol validity, anti-tamper design, transaction log integrity, and abnormal transaction identification. Costing 20%-30% of official testing fees, it identifies 80% of issues upfront.

·Official testing: Conducted in Notified Body-accredited labs. Basic items include real-time transaction data verification, firmware anti-rollback design, and multi-factor authentication validation; high-risk devices require additional testing for secure private key storage, anti-hijacking, and physical tamper-triggered data self-destruction.

·Rectification & retesting: For failures (e.g., outdated encryption protocols, faulty anti-tamper sensors), rectify hardware/software and apply for retesting. In 2025, retest lead times add 1-2 extra weeks.

Timeframe & Pitfalls:

·3-4 months for basic devices (e.g., simple POS), 5-6 months for high-risk devices (e.g., crypto wallets); rectification/retesting adds 1-2 months.

·Pitfall: Lab resources are tight in 2025—book official testing 2 months in advance. Never skip pre-testing: a business failed “transaction tampering simulation” without pre-testing, spending 2.5 extra months on rectification/retesting and missing production schedules.

  IV.Audit & Certification Issuance: 1-3 Months

Testing pass doesn’t guarantee success—audits may delay due to inconsistent documents or test data. In 2025, surging applications have extended audit timelines from 1 to 1-3 months.

Core Actions:

·Document audit: Bodies verify consistency of test reports, technical documents, and supply chain declarations, focusing on full fraud scenario coverage and logical clarity.

·On-site audit (high-risk only): Bodies audit factory QMS (ISO 9001 or equivalent) and mass production consistency (e.g., encryption chip traceability, firmware update management). 2025 on-site audit lead times add 2 extra weeks.

·Certification application: Post-audit, bodies issue CE-RED certificates with explicit EN 18031-3 compliance statements; businesses sign a Declaration of Conformity (DoC) to prepare for CE marking.

Timeframe & Pitfalls:

·Standard 1-3 months; 2-3 months for high-risk devices with on-site audits; 1-2 extra weeks for document supplements.

·Pitfall: Test reports must clearly state compliance for each fraud scenario—vague descriptions trigger supplementary requests. Prepare mass production records before on-site audits; a business faced 1-month delays due to missing encryption chip traceability documents.

  V.Ongoing Compliance Maintenance: Long-Term, Critical for Validity

EN 18031-3 certification isn’t “one-and-done”—EU regulators require proactive, ongoing risk management. Post-certification maintenance directly impacts validity and is core to annual surveillance audits.

Core Actions:

·Vulnerability response mechanism: Conduct firmware vulnerability scans quarterly; push patches for vulnerabilities within 90 days, retaining full update logs and user notifications.

·Annual surveillance audit: 1 audit per year post-certification, submitting vulnerability fixes, production consistency reports, and abnormal transaction cases (1-2 weeks). Failure suspends certification validity.

·Dynamic compliance adaptation: Track EN 18031-3 and (EU) 2022/30 updates; complete reassessment within 12 months for new requirements.

Timeframe & Pitfalls:

·1-2 weeks annually for surveillance audits; ongoing daily vulnerability management.

·Pitfall: Never miss vulnerability fix deadlines. In 2025, businesses failing to fix high-risk transaction vulnerabilities within 90 days had certificates revoked, requiring 6 extra months for recertification.

  2025 Certification Timeframe Reference (Real Cases)

·Basic wireless POS (card payment only): 6-8 months (1-month assessment + 2-month docs + 3-4-month testing + 1-month audit)

·NFC payment band (biometric payment): 8-10 months (1.5-month assessment + 2.5-month docs + 4-month testing + 1-1.5-month audit)

·Cryptocurrency hardware wallet (high-risk): 10-12 months (2-month assessment + 3-month docs + 5-6-month testing + 1.5-2-month audit)

·Cross-border payment terminal (multi-currency): 9-11 months (1.5-month assessment + 3-month docs + 4-5-month testing + 1.5-month audit)

3 Practical Time-Saving Tips for 2025 (Cut 2-3 Months)

·Submit documents as a complete package, not piecemeal: Organize full packages (basic + security + supply chain docs) with clear directories to avoid repeated audits. A business cut audit time from 3 weeks to 10 days via full submission.

·Choose dual-accredited labs: Prioritize labs with both CNAS and EU accreditation—pre-test reports are directly accepted by Notified Bodies, skipping retests and cutting 1-2 months.

·Apply off-peak to avoid rush seasons: March-May and September-November are peak seasons with 20%-30% premiums and tight scheduling. Apply January-February or June-August for 30% shorter lead times and faster audits.

EN 18031-3 certification time management hinges on early planning and avoiding hidden delays. In 2025’s post-mandate market, “rush certification” only causes more delays—invest in early preparation: solid compliance assessment, complete documentation, and locked-in body scheduling.For professional certification consulting, contact BLUEASIA at +86 13534225140.