Blog February 27th 2023

CMSPI Data Shows PINless Enablement On The Rise

In a win estimated to be worth $3bn for merchants¹, the Federal Reserve’s October 2022 clarification mandates that issuers make at least two competing debit networks available for all payment channels by July 1, 2023.

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Christian Johnson

Senior Manager, Global Advocacy Manager

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In this blog post, we pick through some of the trends in PINless enablement we’ve seen since October, with an eye to industry readiness for the July 1, 2023, effective date. CMSPI analysis indicates that not only are small- to medium-sized issuers already mostly complying with the mandate, but some large issuers have, just since October, also enabled access to competing networks across all channels.

Large Issuers are Moving Towards Compliance

CMSPI regularly tracks U.S. debit PINless enablement to ensure our clients can hit the moving target to optimize debit routing strategies. Why is it a moving target? Because issuer enablement and network badging selection is always changing. Since the October 3rd Federal Reserve clarification that all debit transactions must provide merchants with network routing choice on all types of debit transactions, CMSPI data indicates a climb in overall dual network enablement, especially from large issuers.

Figure 1. PINless Enablement on Regulated Debit Issuer Payment Volume, September vs. November 20222

As shown in Figure 1, regulated debit issuers, those with over $10 billion in assets, have increased PINless enablement³ by ten percentage points on average in just the period September 2022 to November 2022. It’s important to note that overall average enablement can be significantly influenced by the decisioning of just a few issuers on their highest-volume cards. For example, in the period October 2022-January 2023, a total of nearly 30 BINs associated with 15 regulated issuers went from having no competing network in a CNP environment to having a competing PINless-enabled card network co-badged on the card. Interestingly, three BINs account for nearly two-thirds of the very steep increase in PINless enablement observed in the period September-November 2022.

Small- to Medium-sized Issuers Were Almost Already There

For issuers with less than $10 billion in assets, PINless enablement has steadily held around 80%. For these small issuers, it seems that the enablement of competing networks for all channels of transaction for debit cards has already been mostly integrated into their card issuing business (Figure 2).

Figure 2. PINless Enablement by Unregulated Debit Issuers4

In fact, from October 2022-January 2023, there’s even been a slight uptick in PINless enablement among unregulated debit card issuers. CMSPI data suggests that 90 BINs associated with nearly 50 unregulated issuers did not have PINless functionality fully enabled in October 2022, but, by January 2023, those cards were compliant with the Fed’s clarification.

Industry Readiness by July 2023

The data above is striking, as it’s clear that not only are large issuers enabling PINless functionality within a few months of the clarification, but small- and medium-sized issuers are already mostly in compliance with the dual-badging mandate. In addition, the data presents limited evidence to indicate that the issuing industry cannot be ready by July 2023. Merchants need to begin shaping their PINless debit strategies today, as each month presents new opportunities to drive competition and achieve cost savings.

To learn more about the PINless debit routing opportunity and the prescient threats, read ‘The Attack on Merchant Debit Savings Report‘.



  1. CMSPI estimates and analysis
  2. CMSPI estimates and analysis
  3. PINless enablement is measured as share of transactions that are eligible for routing to competing debit networks across all payment channels.
  4. CMSPI estimates and analysis

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