Contactless Only Terminals: When Tap Only Is Allowed
A tap-only counter is allowed under USD 1 million in annual Visa volume if international stays under 10%. Above that, you need another device.
By Jeffrey Anderson
- Visa Core Rules Section 5.6.2.3 (ID# 0026670) permits a contactless-only acceptance device, including a Tap To Phone solution, only under the conditions in Table 5-9, and which one applies turns on your annual Visa volume and your international mix.
- A fully tap-only outlet with no other device is allowed where annual Visa transaction volume does not exceed USD 1 million and international transactions are no more than 10% of total annual Visa volume.
- A queue-busting tap-only lane is conditional on all cards being accepted at other acceptance devices at the same merchant outlet, so it supplements the counter rather than replacing it.
- A Tap To Phone solution must not be deployed as an unattended cardholder-activated terminal, which rules out building a self-service kiosk on a handset.
- This edition publishes VEPS maximum transaction amounts for the AP, Canada, CEMEA, Europe and LAC regions with no US Region table, so the US unattended threshold is set by reference without the figure appearing in the document.
Contactless only terminals are allowed, but not on your own terms. A merchant may deploy a contactless-only acceptance device, including a Tap To Phone solution, only under the conditions in Section 5.6.2.3 of the Visa Core Rules (ID# 0026670). Which condition applies to you depends on two numbers: your annual Visa transaction volume and how much of it is international.
This matters now because tap-only hardware got cheap and Tap To Phone put a terminal on every staff handset. The rule has not loosened to match.
The three face-to-face routes
| Situation | What makes it allowed |
|---|---|
| Queue busting | All cards are accepted at other acceptance devices at the same merchant outlet |
| Under USD 1 million in annual Visa volume | No other device needed at the outlet, provided international transactions do not exceed 10% of total annual Visa volume |
| Everything else | Both conditions: international under 10%, and all other cards accepted either at other devices at the outlet or on your website or application |
Read the first row carefully. A tap-only lane for throughput is a supplement, not a replacement. The rule assumes the rest of your counter still takes every card.
The USD 1 million line
The middle row is the only route to a genuinely tap-only outlet with nothing else on the counter, and it has two gates. Annual Visa transaction volume at or under USD 1 million, and international transactions at no more than 10% of your total annual Visa volume.
Both are annual figures, which means this is not a stable permission. A business that crosses either line has to add an acceptance device that takes everything, or move itself onto the third row by taking all other cards through its website or app.
A footnote narrows what counts as international in the Europe Region, excluding European Economic Area transactions. It does not change the US reading.
Tap To Phone cannot be unattended
A short footnote carries a hard restriction: a Tap To Phone solution must not be deployed as an unattended cardholder-activated terminal.
So the phone in a staff member's hand is fine. The same phone mounted in a kiosk, on a vending unit, or at a self-service point is not. If you are planning a self-checkout built on a handset, that plan is against the rule before you price it.
Unattended devices have separate conditions
For unattended transactions the rule splits by type rather than by volume.
A quasi-cash transaction may run on a contactless-only device with no other device available, provided the terminal requires a PIN or a consumer device cardholder verification method under Section 5.6.1.1.
For most other unattended transactions, excluding ATM cash disbursements, automated fuel dispensers and urban mobility points not otherwise specified, a contactless-only device needs no companion device if the amount is below the applicable Visa Easy Payment Service limit, or above it where the terminal meets the cardholder verification requirements in Section 5.6.1.1.
Here is a gap worth knowing before you quote a number at anyone. The VEPS maximum amounts in this edition are published per region, with tables for the AP, Canada, CEMEA, Europe and LAC regions. There is no US Region table among them. So the rulebook sets the US threshold by reference without publishing the figure in this document, and a US operator should get the applicable amount from their acquirer rather than from a blog. We are not going to invent one.
Urban mobility turnstiles
A passenger vehicle such as a bus or ferry may run a contactless-only device at a turnstile, fare gate or point of access if all contactless payment devices are accepted and all cards are accepted at the operator's other locations.
Where such a device always performs offline data authentication before letting someone through, four more conditions attach. It has to be configured in the same mode or network for offline data authentication, support real-time or deferred online authorization at every gate, not support contactless using static data authentication, and support contactless using dynamic data authentication.
Why the rule exists at all
Section 5.6.2.3 is the named exception to two of the most basic acceptance obligations.
Honor All Cards, Section 1.5.4.2, requires a merchant to accept all cards properly presented. Uniform Services, Section 1.5.4.9, requires accepting all cards properly presented and rendering services uniformly to all cardholders. Both carve out contactless-only devices by pointing at this section. The uniform service rules are covered in our post on surcharge parity and similar treatment.
That framing is the useful part. A tap-only terminal is a limited-acceptance arrangement, and limited acceptance has signage consequences too, which we set out in what you must and must not display. The technology side of running payments off a handset is in our guide to tap to pay on a phone, and the hardware options sit on our POS systems page.
Frequently Asked Questions
Can I run a tap-only counter with no chip reader at all?
Only on one of two routes. Either your annual Visa volume is at or under USD 1 million with international transactions at no more than 10% of the total, or you accept all other cards on your website or application instead.
Does a tap-only queue-busting lane need anything else?
Yes. That route is conditional on all cards being accepted at other acceptance devices at the same outlet. The lane cannot be your only way to take a card.
Can I mount a phone running Tap To Phone as a self-service kiosk?
No. The rule states that a Tap To Phone solution must not be deployed as an unattended cardholder-activated terminal.
What is the US VEPS limit?
This edition of the rulebook does not publish one. It lists VEPS maximum transaction amounts for the AP, Canada, CEMEA, Europe and LAC regions, with no US Region table, while still setting unattended conditions by reference to the applicable limit. Ask your acquirer for the current figure.
What happens if my volume crosses USD 1 million?
The exemption you were relying on stops applying. You need an acceptance device at the outlet that takes all cards, or acceptance of all other cards through your website or application.
Jeffrey Anderson, Merchant Placement Specialist
Merchant placement specialist at Gray Merchants. Jeffrey works directly with acquiring-bank underwriting teams across the firm’s 70+ banking relationships to place high-risk and hard-to-place businesses, structure multi-MID accounts, and keep flagged merchants processing. His writing draws on the placement files he works every week: what underwriters ask for, why accounts get declined, and what keeps an approved account open.