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PCI DSS Compliance Checklist: The 12 Requirements [2024]

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Ensuring the security of cardholder data is more critical than ever as transactions are increasingly conducted online. PCI DSS (Payment Card Industry Data Security Standard) serves as a comprehensive framework to safeguard the entire payment card value chain. In this article, we explore the significance of PCI DSS compliance, its evolution with Version 4.0, and a PCI DSS compliance checklist to help you maintain compliance and protect cardholder data.

What is PCI DSS Compliance?

PCI DSS (Payment Card Industry Data Security Standard) is a set of standards enforced by leading credit card firms to establish uniform policies for safeguarding cardholder data. It furnishes precise directives on the collection, handling, and retention of delicate cardholder details. Any business involved in storing, processing, or transmitting cardholder data must adhere to these standards. Moreover, PCI extends its requirements to encompass any entity capable of influencing the security of payment card transactions. Compliance levels differ based on the volume of card transactions processed annually. The higher the volume of transactions, the more rigorous the PCI compliance assessment becomes.

Why is It Important to Implement PCI DSS?

Implementing PCI DSS compliance is crucial in today's digital landscape, especially with the increasing risk of data breaches due to the rise in digital payments. Compliance safeguards the confidentiality, integrity, and availability of this data, preventing theft, unauthorized access, and fraud. This includes encrypting card data during its transmission and implementing necessary security measures.

Additionally, PCI compliance not only fulfills regulatory requirements but also demonstrates a company's commitment to data security, fostering trust among customers and enhancing the business's reputation. Customers show increased trust and goodwill towards companies that are PCI compliant and show a willingness to protect cardholder data. 

Non-compliance with PCI carries severe consequences, including financial penalties, legal actions, and reputational damage. Fines vary based on the violation's gravity, and legal expenses for fraud recovery can be substantial. The long-term impact on reputation can hinder business sustainability. Therefore, embracing PCI compliance is not just a regulatory obligation but a strategic investment in safeguarding the business and building trust with stakeholders.

Objectives of PCI DSS Version 4 vs Version 3.2.1

With the evolving threat landscape and technological advancements, PCI DSS undergoes periodic updates. The transition from Version 3.2.1 to Version 4.0 aims to enhance the security posture of organizations. 

Key objectives of PCI DSS Version 4.0 include:

  • Meeting Evolving Security Needs: Ensuring that PCI standards evolve to meet the dynamic security requirements of the payments industry.
  • Flexibility and Methodology Support: Adding flexibility by supporting various methodologies to enhance payment security.
  • Continuous Cardholder Security: Promoting cardholder security as a continuous process, merging security with business processes.
  • Enhanced Validation Methods: Introducing improved validation methods and procedures to streamline the compliance process.

Summary of Changes from PCI DSS 3.2.1 to 4.0:

Aspect PCI DSS 3.2.1 PCI DSS 4.0
Security Focus Prescriptive controls Outcome-focused
Authentication Introduction of MFA for specific access scenarios Reinforcement of MFA, recognition of evolving methods
Password Requirements Minimum of eight characters Increased to a minimum of 12 characters
Account Management General guidance Clearly defined roles and responsibilities
Threat Prevention and Detection Limited focus on ongoing threats New requirements for threat prevention and detection
Security Outcomes Prescriptive controls Emphasis on security outcomes, allowing flexibility
Continuous Security Monitoring Viewed as a point-in-time assessment Emphasis on continuous monitoring and security
Encrypted Data Management Limited guidance on key management Precise guidance on managing encrypted data
Vendor Responsibility Outlines service provider responsibilities Extended responsibilities, increased oversight
Cryptographic Architecture List of weak cryptographic algorithms Documented description of cryptographic architecture

PCI DSS Compliance Levels

PCI DSS compliance is crucial for any organization involved in handling cardholder data. To ensure consistency and effectiveness in compliance efforts, the Payment Card Industry Security Standards Council (PCI SSC) has established requirements that account for different levels of compliance based on the volume of transactions processed by a business. These levels, ranging from Level 1 to Level 4, determine the stringency of requirements imposed on organizations.

Below is an overview of the different compliance levels and their corresponding criteria:

Compliance Level Criteria
Level 1 • Organizations processing over 6 million transactions per year (or those deemed by card networks as level 1 based on risk assessments)
• Any organization that has suffered a data breach resulting in compromised cardholder data
• Service providers handling large volumes of transactions, irrespective of the number of transactions processed
Level 2 • Organizations processing between 1 million and 6 million non-online transactions per year
Level 3 • Organizations processing between 20,000 and 1 million e-commerce transactions annually
• All other organizations processing between 1 million and 6 million non-online transactions per year
Level 4 • Organizations processing fewer than 20,000 e-commerce transactions annually
• Organizations processing up to 1 million non-online transactions per year

Regardless of the compliance level, adherence to PCI DSS is essential to ensure the secure processing of cardholder data. While Level 1 organizations face the most stringent requirements due to their higher transaction volumes and increased risk exposure, all levels must implement robust security measures to protect sensitive information effectively.

Failure to comply with PCI DSS requirements can lead to severe consequences, including financial penalties, reputational damage, and increased vulnerability to data breaches. Navigating these requirements can be challenging, but by following the steps outlined in the PCI compliance checklist below, organizations can ensure they meet the necessary standards and protect sensitive cardholder data.

12 PCI DSS Compliance Requirements Checklist

We’ve compiled a PCI compliance checklist that breaks compliance down into 12 actionable steps:

1. Install and Maintain a Firewall

Initiating PCI compliance begins with the implementation and ongoing maintenance of a robust firewall system, serving as the primary defense against potential threats. Firewalls act as a crucial barrier against unauthorized access and malicious activities. Proper configuration, coupled with regular testing and updates, is paramount to identify vulnerabilities and ensure the efficacy of the firewall defense mechanism. Firewall vendors such as AWS for cloud and traditional vendors such as Check Point, Palo Alto, and Cato can help maintain a high level of PCI compliance. It's imperative to meticulously configure firewall and router rules to govern the types of network traffic allowed and restricted within the environment. 

2. Reconfigure Vendor Default Settings

Eliminating reliance on default settings provided by vendors is essential for aligning with PCI DSS standards and enhancing overall security posture. Default passwords and security parameters are common targets for cyber attackers. Organizations must prioritize changing default settings for servers, network devices, and software applications before deployment. This involves upgrading settings for new devices and meticulously documenting configurations or ensuring your solution is preconfigured to meet PCI standards effectively. Ensuring custom configurations and robust access controls further fortifies the defense against potential breaches.

3. Protect Cardholder Data

Safeguarding stored cardholder data stands as a critical requirement for PCI compliance, necessitating meticulous awareness of data location, storage duration, and encryption protocols. Employing card data discovery tools assists in identifying vulnerabilities and preventing the storage of primary account numbers (PAN) in an unencrypted format. Segregating databases containing cardholder data from other network resources and restricting access, in conjunction with thorough testing of network segmentation, enhances data security. Strict adherence to data retention policies and secure deletion practices ensure compliance with PCI standards, minimizing the risk of data exposure.

4. Encrypt Transmission

Encrypting data during transmission is vital to prevent interception by unauthorized parties and meet PCI compliance requirements effectively. Organizations must prioritize the use of strong encryption protocols for all data transfers, and ensure their storage solutions provide field-level encryption, ensuring compliance with approved standards such as TLS. By implementing secure encryption practices and avoiding the transmission of PANs in plain text format, organizations bolster data security and mitigate the risk of data breaches during transit.

5. Use Updated Antivirus Software To Protect Against Malware

Basic antivirus software is insufficient for meeting PCI compliance standards, necessitating regular updates and patching across the IT infrastructure. Continuous monitoring and threat detection tools play a pivotal role in detecting, neutralizing, and destroying malware effectively. Ensuring the installation of advanced antivirus software such as Norton 360, Bitdefender, and Avast on all connected devices and updating to the latest version strengthens the defense against potential threats, safeguarding the cardholder data environment.

6. Maintain the Security of Critical Systems and Applications

Conducting thorough risk assessments is foundational for deploying secure systems and applications in alignment with PCI standards. Timely application of patches, especially for critical systems such as databases and point-of-sale terminals, is pivotal for compliance. Implementing secure DevOps practices and conducting continuous security assessments enable organizations to identify and address emerging threats effectively, ensuring the integrity and security of critical systems and applications.

7. Restrict Access to Cardholder Data

Implementing robust access control measures based on business necessity is integral to maintaining data integrity and confidentiality in the cardholder data environment. Adhering to well-documented access control policies ensures that access to cardholder data is granted only to authorized individuals. When using third-party solutions, ensure they maintain a high standard of access control, such as by supporting IAM (Identity and Access Management) systems to restrict access to sensitive data. Combining digital access controls with physical security measures, such as Zero Trust principles and strict monitoring of access protocols, strengthens the defense against unauthorized intrusions and mitigates the risk of data breaches.

8. Assign Unique User Access IDs

Enforcing unique user credentials, such as IAM, access tokens, and JWT (JSON Web Token) access controls, coupled with two-factor authentication, enhances security and traceability in the event of internal breaches. Eliminating shared or group credentials is fundamental to upholding PCI standards and ensuring accountability for user actions within the network environment. Organizations must prioritize user awareness training and routine audits of access policies to enforce compliance with PCI standards effectively.

9. Restrict Physical Access to Cardholder Data

Implementing stringent physical security measures, such as access controls and surveillance systems, is an indispensable method used to protect cardholder data against unauthorized access. Monitoring and enforcing access protocols for all devices involved in the cardholder data environment, including mobile devices and storage accessories, mitigates the risk of unauthorized physical access. Secure disposal practices for devices containing cardholder data further minimize the risk of data theft and restrict physical access to devices not in use, ensuring compliance with PCI standards.

10. Track and Monitor Network Access

Continuous monitoring of network access, supported by robust audit trail records, enhances threat detection capabilities and ensures compliance with PCI standards. Security Information and Event Monitoring (SIEM) tools, such as DataDog, Imperva, and IBM QRadar SIEM, play a pivotal role in logging system activity and identifying anomalies in real time. Ensure all devices and solutions log and track network access. Generating audit trails for access requests and user activities involving cardholder data, coupled with regular scans and assessments, contributes to ongoing security enhancements and adherence to compliance requirements.

11. Regularly Test Security Systems and Processes

Periodic testing, including penetration and vulnerability assessments, is essential to identify and address security vulnerabilities effectively. External and internal network tests conducted by Approved Scanning Vendors (ASVs) help organizations evaluate the effectiveness of their security systems and measures. Solutions that support PCI compliance, such as Piiano’s Vault, can often provide pen testing reports. Continuous testing processes, such as change detection systems and intrusion detection systems, enable organizations to detect and respond to emerging threats promptly, ensuring compliance with PCI standards and mitigating the risk of data breaches.

12. Create and Apply an Information Security Policy

Establishing an organization-wide information security policy that is regularly reviewed and disseminated forms the foundation of PCI DSS compliance. The policy encompasses all security controls present on the network and documents their alignment with PCI standards. It outlines guidelines for accessing sensitive data, incident response procedures, and third-party requirements. Routine policy reviews and updates ensure alignment with PCI best practices, enabling organizations to maintain comprehensive security measures and uphold compliance standards effectively.

PCI Compliance Best Practices

PCI DSS Compliance Practice Description
Use a Firewall Installing and configuring a firewall serves as a frontline defense mechanism, regulating incoming and outgoing traffic to fortify network defenses and meet compliance requirements.
Avoid Using Default Passwords Promptly replacing default passwords with strong, unique substitutes reduces the risk of unauthorized access, enhancing your security posture and protecting sensitive systems and data.
Use Both Digital and Physical Measures to Protect Cardholder Data Combining digital access controls with physical security measures strengthens network security. Using technology such as key cards, passcodes, and biometrics can help safeguard cardholder data.
Create and Enforce a Security Policy Creating a comprehensive security policy that outlines data handling procedures, access controls, and incident response strategies can help foster a culture of security and enhance compliance by establishing a clear security protocol.
Establish an Incident Response Process Developing and testing an incident response plan arms security teams with the tools to respond to security breaches quickly and efficiently by defining roles, responsibilities, and the escalation procedures needed to mitigate risks effectively.
Keep Track of Changes Maintaining an accurate inventory of system components and configurations enables effective monitoring of security controls and allows organizations to track their compliance status and promptly respond to potential threats.
Keep Software Patched and Install Security Updates Timely application of security patches and updates is crucial for addressing known vulnerabilities and reducing the risk of future exploitation. Regularly updating security software ensures that security stays up to date and remains relevant as a defense against emerging threats.

The Future of PCI Compliance

As digital technologies advance, the future of PCI compliance involves adapting methodologies and processes to meet new challenges. PCI DSS Version 4.0 emphasizes integrating technology and business processes to make compliance more flexible and responsive to emerging financial and payments sector technologies. Following the steps outlined in the PCI compliance checklist can help organizations keep up with changing standards and maintain compliance. 

Additionally, continuous monitoring of updates from the PCI Security Standards Council, along with proactive engagement with key infosec personnel, is crucial for staying ahead in the ever-evolving PCI compliance landscape.

Looking ahead, PCI compliance will evolve dynamically, driven by advancements in digital technologies and emerging cybersecurity threats. While the core objectives and requirements of PCI DSS remain consistent, there's a continual need to refine methodologies and processes to address evolving security challenges.

Introduced in March 2022, PCI DSS Version 4.0 represents a significant step forward. It places increased emphasis on integrating technology with business processes, aiming to provide organizations with greater flexibility in meeting compliance requirements. Instead of just checking boxes, PCI DSS 4.0 encourages a deeper understanding of how security measures align with broader business objectives.

Key features of PCI DSS 4.0 include stricter multi-factor authentication requirements, enhanced guidance for configuring payment systems (including contactless and mobile devices), customization options for cloud-based platforms, and specific controls to prevent code injection attacks. Additionally, this version deprecates outdated transfer protocols like SSL and earlier versions of TLS, reflecting the need for robust encryption standards.

While these updates signify a progressive approach to PCI compliance, organizations must remain vigilant. Continuous monitoring of updates and proactive engagement with industry standards are essential practices for navigating the evolving compliance landscape.

Staying informed about PCI DSS updates and engaging with key stakeholders within the organization are vital steps towards ensuring ongoing compliance. Leveraging the expertise of experienced PCI compliance partners can also help organizations address any compliance gaps and navigate the complexities of evolving security standards effectively.

How to Be PCI DSS Compliant With Piiano

Piiano’s SaaS production stands as a complete turnkey solution for PCI compliance, removing the burden of compliance from implementers. Our iFrame support further streamlines the compliance process by enabling users to transmit customer data directly to the Vault’s PCI-compliant storage without expanding their own PCI Scope. Piiano’s PII data privacy vault offers a comprehensive solution for organizations seeking to achieve compliance with various regulatory requirements, including those outlined in PCI standards. By leveraging Piiano's secure platform, users benefit from robust features designed to address key PCI DSS requirements seamlessly. With Piiano Vault, users can ensure secure configuration, as the platform is inherently secured to align with PCI standards, providing peace of mind against potential vulnerabilities. 

Additionally, Piiano Vault enables organizations to protect cardholder data effectively by blocking any unauthorized access to sensitive information and implementing field-level encryption, ensuring data remains secure both at rest and in transit. Through strong access control measures and Identity and Access Management (IAM) capabilities, Piiano Vault facilitates precise control over access to cardholder data, enabling organizations to adhere to PCI DSS requirements regarding access control and authenticated access. 

Furthermore, Piiano Vault simplifies compliance with PCI mandates related to logging access to cardholder data by providing comprehensive audit logs, enabling organizations to track and monitor all access activities effectively. With Piiano's integrated security testing capabilities, including penetration testing reports, users can proactively assess and address security vulnerabilities, meeting PCI DSS compliance requirements seamlessly. Overall, Piiano Vault serves as a robust solution for organizations looking to ensure compliance with PCI standards while safeguarding sensitive data effectively.

PCI Requirement How Piiano Vault Helps
Secure Configuration Piiano Vault is inherently secured to align with PCI standards, providing a secure database environment for storing sensitive cardholder data.
Protect Cardholder Data Piiano Vault blocks unauthorized access to cardholder data and employs field-level encryption and data tokenization to ensure credit card data remains protected at rest and in transit.
Cardholder Data Encryption Piiano Vault offers robust encryption features, including field-level encryption, to ensure that cardholder data is securely encrypted.
Access Control Piiano Vault provides fine-grained access controls and Identity and Access Management (IAM) capabilities, enabling precise control over data access.
Identify Users and Authenticated Access With Piiano Vault, organizations can implement strong authentication mechanisms and access policies to ensure authenticated access to cardholder data.
Log All Access to CHD Piiano Vault generates comprehensive audit logs, allowing organizations to track and monitor all access activities to cardholder data effectively.
Security Testing Piiano Vault offers integrated security testing capabilities, including penetration testing reports, to proactively assess and address security vulnerabilities.


PCI DSS compliance serves as the cornerstone for ensuring the security and integrity of processing payment transactions and working with cardholder data in today's digital economy. By adhering to the 12 key requirements outlined in the PCI compliance checklist and implementing best practices, organizations can mitigate risks, safeguard sensitive information, and build trust with customers. With the evolution of PCI DSS standards and the support of innovative solutions like Piiano Vault, businesses can navigate the complexities of compliance with confidence, ensuring robust protection against cyber threats and maintaining the highest standards of data security.

With Piiano Vault, the journey to implement your PCI DSS in the cloud for your homegrown application can be drastically reduced. Piiano Vault can even fully serve as an isolated PCI scope so you don’t need to develop more components next to it, saving you time and integrations. As it sports all data management, data tokenization and data encryption and security requirements that you will have to otherwise implement on your own.

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Skip PCI compliance with our tokenization APIs

It all begins with the cloud, where applications are accessible to everyone. Therefore, a user or an attacker makes no difference per se. Technically, encrypting all data at rest and in transit might seem like a comprehensive approach, but these methods are not enough anymore. For cloud hosted applications, data-at-rest encryption does not provide the coverage one might expect.

John Marcus

Senior Product Owner

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