Introduction: What is PCI DSS?

PCI DSS, or the Payment Card Industry Data Security Standard, is a set of information security standards governed by the PCI SSC, or Payment Card Industry Security Standards Council.

The goal of these standards, established in 2004, is to protect card users against data theft and fraud related to credit and debit cards. 

Interestingly, the PCI SSC does not have the legal authority to compel compliance, it does require that any business that processes a card transaction is PCI DSS compliant

Not only is customer data protected when a business has PCI certification, but the business also can protect its reputation as a reliable and safe vendor with consumers.

A business’ compliance is validated on a regular schedule based on the volume of transactions that business processes according to the following levels:

Level 1 compliance is required for businesses that process over 6 million transactions on an annual basis. Their compliance is validated through an audit conducted by an authorized PCI auditor each year. Level 1 businesses must also undergo a PCI scan conducted by an Approved Scanning Vendor, or ASV, once every quarter. 

Level 2 compliance is required for those businesses that process between 1 and 6 million transactions each year. These businesses must take a Self-Assessment Questionnaire, or SAQ, each year, as well as a PCI scan each quarter.

Level 3 compliance is for merchants who process less than 1 million but more than 20,000 e-commerce transactions in a year. As with level 2, these businesses need to do the annual SAQ, but are only required to run quarterly scans under certain circumstances.

Finally, Level 4 compliance is for any vendor that processes fewer than 20,000 e-commerce transactions annually or up to 1 million real-world transactions annually. Again, an annual SAW is necessary, but the quarterly PCI scan occurs on an “as needed” basis. 

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PCI DSS Requirements

The PCI SSC has defined 12 requirements split across six categories for businesses that handle cardholder data and maintain a payment processing network. Any business that wishes to be in compliance must meet all of these requirements.

  1. Maintaining a Secure Network – The first category of requirement relates to the maintenance of a secure network, and requires that a business:
  • Installs and maintains a firewall
  • Utilizes original, customer-selected passwords on customer data and not vendor-supplied passwords
  1. Securing cardholder data – The second category addresses how business secure cardholder data and requires that a business:
  • Protects any stored cardholder data
  • Encrypts any data that is transmitted across public networks
  1. Managing vulnerability -  the third category involves how a business manages vulnerabilities in its network and requires that a business:
  • Use and regularly updates its anti-virus software
  • Develops and maintains secure systems and apps
  1. Controlling access – The fourth category oversees how businesses control access to data and requires that a business:
  • Limits business access to cardholder data to a “need-to-know” basis
  • Assigns a unique ID to every business user with computer access
  • Restricts physical access to cardholder data
  1. Monitoring and testing the network – The fifth category of requirements addresses how a business monitors and tests their network and requires that the business:
  • Tracks and monitors all access to cardholder data and resources on the network
  • Tests security systems and protocols on a regular basis
  1. Securing information – Finally, the sixth category of PCI DSS requirements addresses how a business secures information and requires that a business:
  • Maintains a policy that addresses specific protocols and practices related to information security

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How to Get PCI DSS Certification

Getting PCI DSS certification is a multi-step process. As a first step, a business should analyze its current compliance level. Assess:

  • How you handle data
  • How you process customer transactions
  • With which banks you work
  • Your volume of transactions

Cross-reference this with PCI general standards to understand how the business currently performs in terms of these standards.

Next, a business should take the self-assessment questionnaire that is a regular part of the PCI compliance process. There are several different versions of the SAQ so businesses should make sure that they are using the one that is right for their business type. Taking the SAQ will further highlight the areas where a business needs improvement in order to be in compliance.

As a next step, a business should take the steps needed to enhance data and transactional security at the company. This can include working with a provider that utilizes data tokenization to secure customer credit card data.

Once these improvements are in place, a business should complete and submit a formal attestation of compliance (AOC). 

As with the SAQ, different AOCs are used for different business types. A QSA can then perform a review of a business’ compliance and generate a report to validate compliance. These documents can then be submitted to credit card companies and banks to confirm a business’ compliance. 

PCI DSS Compliance Checklist / Questionnaire

The following is a checklist that can help a business determine whether or not they are in compliance with PCI DSS requirements:

  • Is the system that stores and transmits customer data protected by a firewall or similar security?
  • Does the business run regular maintenance and upgrades on that firewall?
  • Are strong passwords used in lieu of default passwords?
  • Does the business protect cardholder data in internal systems with sufficient security controls?
  • Is in-transit cardholder data secured, including using approved encryption methods and protecting it in open networks?
  • What antivirus software does the business use? Is it sufficient given the high stakes of cardholder data?
  • Is any virus protection program used updated on a regular basis?
  • How secure are your systems and applications?
  • How often does the business run maintenance and updates on your systems and applications?
  • What are the business’ plans for securing systems so that they are in compliance with PCI DSS?
  • Is the business currently restricting internal access to cardholder data?
  • Do internal restrictions on credit card data limit access on a “need to know” basis?
  • Does the need to execute a task with cardholder data outweigh the risk to that data?
  • Are all users at the company using a unique user ID when logging into the system?
  • Does a system administrator oversee and manage permissions and controls for those user IDs?
  • Are all permissions aligned with the “need to know” data policy?
  • Are all visits to a facility that houses systems containing credit card data logged and monitored?
  • What processes does the business utilize to review its network and ensure data security?
  • Are any processes used logged and stored to create a valid audit trail?
  • How often does the business test systems for vulnerabilities?
  • Are any identified vulnerabilities addressed as quickly as possible?
  • When new software or configurations are introduced, are they subjected to vulnerability testing?
  • Does the business monitor critical system files regularly to make sure they have not been accessed or modified outside the scope of regular business?
  • Has the business developed an information security policy for the company and distributed it to all users?
  • If an information security policy is in place, is it reviewed on an annual basis or when system changes occur?
  • Does the information security policy include sections that address PCI compliance and service providers?
  • If a breach occurs, does the business have an emergency response plan in place?

Credit Card PCI Compliance: What's New in 2024 and What to Include in the Updated Checklist

The changes in PCI DSS 4.0 reflect the changes in technology, cybercrime, and payments over the past few years. The COVID-19 pandemic has significantly impacted consumer behavior, specifically through a prompt boost of online and contactless payments. 

Modern businesses use cloud platforms to store personal data much more often, so cybercriminals are devising new ways of compromising user data. The PCI DSS compliance checklist 4.0 will show what to do to minimize such risks. 

The key changes that must have been done by April 1, 2024, according to PCI DSS audit requirements, include the following:

  • You must define the roles and responsibilities to properly conform with PCI DSS requirements.
  • You must define and document the scope of the cardholder data environment annually and after making any significant changes.
  • Changes to networks must comply with the same change control as any other aspect in scope.
  • You must secure all the files you use to create the network infrastructure.
  • You must share documented requirements within your organization as well as with any third-party service providers you cooperate with.

What Should Be Done by April 2025 to Be PCI-Compliant

There are 51 new PCI DSS requirements that will become compulsory starting April 1, 2025. Here's what you can expect from the upcoming update:

  • Using disk or partition-level encryption for any encrypted data you store will no longer be acceptable.
  • Stored PAN hashes will have to be cryptographically keyed.
  • You will have to produce an inventory of all the cryptography you're utilizing to protect cardholder data.
  • You will need to conduct an annual risk estimation of all your cryptography uses to ensure sufficient flexibility to adapt requirements in case the algorithms become less secure.
  • Any JavaScript included in the payment web pages must be actively managed, and you must react to any unauthorized changes. 
  • The use of technology developed to detect and prevent phishing attacks will become compulsory, as well as the requirement to conduct more user training. This way, you'll help your staff quickly and efficiently identify and report attacks like phishing.
  • Multifactor authentication will be mandatory for every user able to access the cardholder data environment.
  • Your log reviews must be automated.
  • Apart from maintaining an inventory of your hardware and software, you will also need to perform a risk assessment of any assets approaching their end-of-life, have plans in place to ensure their security, and replace them as appropriate.
  • You will have to authenticate every quarterly internal vulnerability scans. 

The Bottom Line

Becoming PCI DSS compliant may be overwhelming for some businesses, but it is a necessity. 

It is a relatively straightforward process when approached systematically, and the downside of not being in compliance far outweighs the cost and trouble of getting in compliance. 

Businesses that are found to not meet PCI requirements can be sanctioned and left unable to accept payment online, cutting off a business’ primary stream of revenue. When financial death for a business is a possibility, it seems clear that becoming PCI compliant should be a priority for any and all businesses.

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Michael Barskyi
Business Development Lead and Fintech Expert
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