Effective August 1, 2025, EN 18031-3:2023 becomes a mandatory EU harmonized standard—all wireless devices processing monetary or virtual currency value (e.g., POS machines, cryptocurrency hardware wallets) must obtain certification to enter the EU and European Economic Area (EEA) markets.

I. Essence of EN 18031-3 Certification Standard

EN 18031-3:2023 is the dedicated technical specification for "anti-fraud protection" under Article 3(3)(f) of the EU Radio Equipment Directive (RED 2014/53/EU). Its mandatory force derives from Delegated Regulation (EU) 2022/30, becoming a "hard threshold" for financial wireless devices entering the EU from August 1, 2025.

Its core definition is clear: targeting "monetary value fraud exploiting radio equipment vulnerabilities," not general cybersecurity risks. This distinguishes it fundamentally from EN 18031-1 (basic cybersecurity):

·EN 18031-1 focuses on "preventing device attacks" (e.g., DDoS protection, default password bans);

·EN 18031-3 focuses on "preventing transaction tampering and fund theft" (e.g., payment instruction verification, private key protection).

Simply put, EN 18031-1 is the "security door for device protection," while EN 18031-3 is the "safe for financial transactions." In 2025, EU regulation will adopt a dual mechanism of "proactive inspections + market reporting"—non-compliant products face not only bans but also inclusion in the EU "security gate" blacklist, impacting other product access.

  II. Products Subject to EN 18031-3 Certification

Two core criteria determine EN 18031-3 applicability: possession of wireless communication functionality (Wi-Fi/Bluetooth/4G/5G, etc.) and processing/impact on monetary or virtual currency value (storage, transmission, transactions). Based on the latest notified body guidelines, specific applicable devices and exemptions are as follows:

1. Mandatory Certification Device List:

·Traditional Financial Terminals: Wireless-enabled POS machines (handheld/smart/mobile-connected), ATMs, self-checkout systems, bank self-service transfer terminals;

·Cryptocurrency-Related Devices: Wireless-sync cryptocurrency hardware wallets/cold wallets, specialized virtual currency transaction POS terminals;

·Payment-Enabled Wearables: NFC-equipped smart watches, bands, and other wearables;

·Other Monetary Value Devices: Wireless transit card recharge terminals, game/virtual currency recharge devices.

2. Explicitly Exempt Devices:

·Pure mechanical POS machines (no electronic connectivity), account inquiry terminals (no transaction execution);

·Pure points redemption terminals without monetary value transfer (no wireless functionality).

3. Special Requirements for Associated Regions:

In addition to the 27 EU member states, Iceland, Norway, and Liechtenstein (EEA countries) have synchronized implementation. Due to the customs union agreement, Turkey requires not only product compliance but also Turkish safety labels on packaging and designation of local authorized representatives for compliance matters.

  III. Core Mandatory Requirements for EN 18031-3 Certification

EN 18031-3:2023 requirements undergo "firmware testing + physical inspection + documentation review"—four core items are critical for notified body audits, resulting in immediate rejection if unmet:

1. Secure Boot & Firmware Protection

Devices must enable secure boot, only allowing execution of digitally signed legitimate firmware to prevent tampering. Firmware updates require "digital signature + access control + timestamp" triple protection. High-risk vulnerabilities demand 48-hour response and 7-day patch deployment, with a minimum 2-year security support commitment.

2. Physical Tamper Resistance & Data Isolation

Critical components (e.g., Secure Elements (SE), encryption chips) require anti-tamper design (e.g., conductive glue, microswitches). Unauthorized disassembly must trigger irreversible sensitive data destruction (private keys, transaction records). Sensitive data must be isolated from regular data with AES-256 encryption to prevent physical or logical leakage.

3. Transaction Integrity & Identity Authentication

All transaction instructions (amount, account, timestamp) require digital signatures for integrity. Transmission must use TLS 1.2 or higher. Multi-factor authentication (e.g., password + biometrics + dynamic token) is mandatory for transactions—high-value transactions require additional hardware key verification, with single-password authorization prohibited.

4. Log Retention & Traceability

Transaction logs must be encrypted, tamper-proof, and include key fields (transaction party identities, terminal location, authentication method). Retention period is at least 5 years, with formatting compliant with the EU Anti-Money Laundering Directive (6AMLD) for regulatory traceability.

  IV. 2025 Practical Pitfalls & Compliance Strategy

1. Common Pitfalls (Based on Notified Body Audit Cases):

·Misaligned Compliance Pathway: Assuming financial devices qualify for "self-declaration"—in reality, third-party notified body certification is mandatory; self-declaration only applies to low-risk non-financial devices.

·Missing Documentation: Lack of third-party component compliance statements or vulnerability scan reports leading to audit delays.

·Neglected Continuous Compliance: Certificates are valid for 5 years but require annual surveillance audits; failure to deploy timely security patches results in invalidation.

·Non-Compliant Log Formatting: Missing key fields or insufficient retention periods requiring documentation and firmware rectification.

2. Three-Step Compliance Strategy:

·Step 1 (1-2 Months): Compliance Assessment & Gap Analysis. Identify shortcomings in hardware tamper resistance, firmware protection, and log retention against standards and associated regulations, prioritizing rectification.

·Step 2 (3-4 Months): Technical Rectification & Documentation Preparation. Complete hardware modifications and software optimization focusing on core requirements; compile key materials (security design documents, SBOM lists, compliance statements).

·Step 3 (2-3 Months): Certification Application & Testing Rectification. Select notified bodies with RED and EN 18031 dual qualifications (e.g., TÜV Rheinland, SGS); rapidly address test feedback. Reserve factory audit time for high-risk devices.

3. Certification Cost & Timeline Reference:

·Costs: Basic financial devices (e.g., standard POS machines): €15,000-€30,000; complex devices (e.g., cryptocurrency hardware wallets): €50,000+. Factory audit fees: €5,000-€10,000 per audit.

·Timeline: Standard 6-8 months (testing, rectification, factory audit); low-risk devices: 3-4 months. Launch applications 6 months in advance to avoid 2025 transition period backlogs.

The mandatory implementation of EN 18031-3:2023 essentially uses technical standards to screen enterprises with strong security capabilities. For enterprises, compliance is not a "cost burden" but a "core competitiveness" for overseas expansion—early alignment and rectification ensure a firm foothold in the EU market. For professional certification consulting, contact BLUEASIA at +86 13534225140.