Apple recently provided their Issuer Functional Requirements for Apple Pay.  Apple stated that by January 15, 2026, if you have an app you must implement in-app provisioning. 

Our initial interpretation is that Apple's requirements are at the card-processor level; if a credit union today wishes to enable Apple Pay, the credit union enables the solution at the card processor and the member manually puts in the card in the Apple Pay wallet. However, while examining due diligence on this, we spoke with several card processors who advised their understanding is if the credit union has a relationship with Apple Pay and has any mobile app, a push provisioning solution is required. 

As you know from our Leadership Conference, push provisioning is already a focus for CU*Answers, and we have begun active development of this product now with a vendor that can support all EFT vendors.  As we finalize the plans for the product, including the costs associated with the solution, we will be advising credit unions of its availability. We anticipate onboarding to include coordination with the vendor as well as a deployment update to your mobile app. 

Since the communication on this has been spotty and not always crystal clear, we would appreciate your passing along any additional insights or information you get about the requirements to our Cards and Payments team at cardsandpayments@cuanswers.com.