Enjoy this character code puzzle.
http://realmode.com/punch22.html
We can assume then that it's not a requirement to be able to over-punch their existing used 5-bit punched stock. Then it's possible, and my proof above of why it's not possible to convert a 4-hole U to more than 7 other characters is a big hint as to one solution... think of a primary encoding and a secondary encoding. What property must the primary encoding have in order to guarantee any character in the primary encoding can be over-punched to one of 25 characters in the secondary encoding?