ATM processing is underwritten on your business entity, so the paperwork has to be in order first. Here is the sequence, the documents underwriting asks for, and what is genuinely required versus commonly oversold.
Processing applications are underwritten on a business entity, not on a person with a machine. That means the paperwork comes first: a properly formed entity, an EIN, a business bank account, and the documents that prove all three. Getting the order wrong is the most common reason a first ATM sits in a garage waiting on an application.
This guide covers the sequence, what underwriting actually asks for, and — just as usefully — which requirements are commonly claimed but do not apply to ordinary cash-dispensing ATMs.
This is general information, not legal or tax advice. Requirements vary by state and by processor, and a local attorney or accountant is the right source for your specific situation.
Each step depends on the one before it, which is why doing them out of order creates delays rather than parallel progress.
Requirements vary by processor, but this set covers most applications:
A practical note on the EIN letter: if you have lost the original CP 575, the IRS will issue a 147C letter on request, and processors generally accept it. Do not let a missing piece of paper stall an application that is otherwise ready.
For an ordinary cash-dispensing ATM, generally no — and this is the area where new operators are most often sold things they do not need.
FinCEN addressed this directly in guidance FIN-2007-G006, issued December 3, 2007. A non-bank owner-operator of an ATM that offers customers nothing beyond remote access to their own accounts at their own depository institutions — balance inquiries and cash withdrawals — is not a money services business under the Bank Secrecy Act. The FFIEC BSA/AML examination manual reflects the same position: independent ATM owners and operators are not generally money services businesses and are therefore not required to maintain AML compliance programs.
The conditions on that conclusion matter. It applies to limited-service ATMs only. An ATM-like kiosk that exchanges convertible virtual currency — a crypto ATM — is a money transmitter, with registration, licensing, and AML obligations that are entirely different in kind. If you are considering a crypto kiosk, treat it as a separate regulated business and get specific legal advice.
What you do need is ordinary business compliance: a registered entity, any general business license your city or county requires, and correct tax registration. Check your own state and municipality rather than assuming, because local business-licensing rules vary considerably even though ATM-specific licensing is uncommon.
| Claimed requirement | Actually required? | What is true | |
|---|---|---|---|
| Federal ATM license | No | No federal license exists for operating a cash-dispensing ATM | |
| FinCEN MSB registration | Generally no | FIN-2007-G006 excludes limited-service ATM owner-operators | |
| AML compliance program | Generally no | Follows from not being an MSB; crypto kiosks are a different case entirely | |
| Business entity and EIN | Yes, in practice | Processing is underwritten on the entity | |
| Business bank account | Yes | Settlement must land in the entity’s account | |
| On-screen surcharge disclosure | Yes | Regulation E requires notice before the customer commits to the fee | |
| Physical fee placard on the machine | No longer | Eliminated by statute in December 2012; Reg E conformed in 2013 | |
| ADA-compliant machine | Yes | 2010 ADA Standards §707 — speech output, tactile keys, reach range | |
| Separate ATM insurance | No | Uncommon in practice; generally does not cover the cash |
Three sets of rules apply to the ATM in operation, and all three are largely satisfied by buying a current machine from a reputable source and configuring it correctly.
Fee disclosure under Regulation E. Before a customer commits to paying your surcharge, the machine must disclose it — on screen or on paper issued by the machine. This is why the on-screen "you will be charged $X, accept or cancel" prompt exists. The separate requirement to post a physical placard on or at the machine was eliminated by legislation in December 2012, with the CFPB conforming Regulation E in a final rule the following March. Some vendors still sell placards; they are no longer a federal requirement.
Accessibility under the ADA. Section 707 of the 2010 ADA Standards requires ATMs to be speech-enabled, with tactilely discernible input controls, Braille instructions, screen and privacy provisions, and operable parts within a reach range of roughly 15 to 48 inches. Current retail machines are built to these standards; the part you control is installation — mounting height, clear floor space, and an approach route.
Payment security. EMV chip capability determines who absorbs fraud on a disputed transaction, following the Mastercard (October 2016) and Visa (October 2017) ATM liability shifts. PCI PIN security rules required TR-31 key blocks as of January 1, 2025, which is a hardware-level question about the encrypting PIN pad. Both are settled at purchase — see How Much Does an ATM Machine Cost? for what to verify, particularly on used equipment, and ATM Compliance Without the Scare Tactics for what each requirement actually means in practice.
Entity formation is a state filing fee, commonly under a few hundred dollars, plus a registered-agent fee if you use one. The EIN is free from the IRS. A business bank account is usually free or close to it. Compared with the machine and the cash float, the paperwork is the least expensive part of starting — its cost is time, not money.
The two things worth spending on are an hour with an accountant on entity type and tax treatment, and actually reading your processing agreement before you sign it. What to Read Before You Sign covers the second. Before your first load, How Much Cash to Keep in an ATM covers sizing the float and the loading routine.
When your documents are together, get started and we will tell you what your specific processor application needs.
Not by law, but in practice yes. Processing is underwritten on a business entity, and while some processors accept sole proprietorships, an LLC or corporation is the norm and makes underwriting straightforward. It also keeps settlement funds and business banking cleanly separated from personal accounts.
Generally no. FinCEN guidance FIN-2007-G006 (December 3, 2007) concluded that a non-bank owner-operator of an ATM offering only balance inquiries and withdrawals against customers’ own bank accounts is not a money services business under the Bank Secrecy Act. Crypto-currency kiosks are treated entirely differently and are money transmitters.
When the documents are complete, underwriting is usually a short process. Delays are almost always missing paperwork — most often an EIN confirmation letter or proof the entity is in good standing — rather than a substantive problem with the application. Gathering the documents before applying is the single best way to speed it up.
Not a physical placard. Congress eliminated the on-machine posting requirement in December 2012, and the CFPB conformed Regulation E in March 2013. The on-screen (or printed) disclosure before the customer commits to the fee is still required, and current machines handle it automatically.
Yes — that is exactly what a placement agreement is for. You own and service the machine, the venue provides the space and power, and you pay the location a share of the revenue, typically a flat amount per transaction. Get the terms in writing, including length, exclusivity, and what happens when either side wants the machine gone.