A detailed guide to Android 4.4 KitKat’s support for Host Card Emulation (HCE), which enables NFC payments and other secure services to be delivered without the use of a secure element, is now available on the Android Developers website. The host-based card emulation guide explains how HCE works on Android devices and how developers can create apps that use the technique.
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That’s use for low secure.
It allows companies to roll their own security, to a level that meets their own risk profile. Secure element based NFC is over-engineered and needlessly complicated for most applications.
you are right
If a device with NFC feature just acts as the communication tunnel in payment transaction, then this solution will enough secure as secure element solution.