How is this Going to Impact my Business?

Overall Impact of PCI DSS v4.0

Organizations will have until March 31, 2024 before they will no longer be able to validate their compliance using version 3.2.1 of the SAQs.

While organizations can continue to validate their compliance using version 3.2.1, you should start now to implement any missing controls that would be required to validate to version 4.0.

SAQs Will Take Longer to Fill Out

Something to be aware of is that almost every question in the PCI v4.0 SAQ was re-worded and re-ordered, meaning that filling out the SAQ may take more time. Since all of the questions have been reworded, it means that EVERY business will need to answer additional questions, even if nothing in your network has changed. 

To help mitigate this, our very best support agents worked together, combing through the 3.2.1 and the 4.0 SAQs to find as many questions as possible that would map over. By using SecurityMetrics' FastPass, you could reduce the amount of questions you'd need to answer by a significant amount.

What are the Actual Changes?

The release of the new 4.0 version may cause anxiety for those already familiar with the current PCI DSS requirements. Rest assured that the 12 core PCI DSS requirements remain fundamentally the same; version 4.0 is not a totally new standard.

However, PCI DSS v4.0 introduced 64 new requirements (11 of which are only applicable to service providers). Most of these new requirements are future-dated to March 31, 2025, with notable exceptions being requirements around documentation and performing a targeted risk analysis. To find out more about specific requirement updates, check out this resource. There were also significant changes to the wording of questions.

To find out about more of the fundamental changes within PCI DSS v4.0, read our white paper PCI DSS Version 4.0: What You Need to Know.

Top PCI v4.0 Requirement Changes

PCI DSS Section 3 

• Remote access technology used must prevent copy/relocation of PAN to remote system  (3.4.2) (2025)
• Must use keyed hash (3.5.1) (2025)

PCI DSS Section 4 

• SSL certs used for transmission must be inventoried/documented (4.2.1.1) (2025)

PCI DSS Section 5 

• Process and mechanism in place to detect and protect against phishing attack (5.4.1) (2025)

PCI DSS Section 6 

• Method and process to review, inventory, authorize all scripts on payment pages (6.4.3) (2025)
  • Confirm scripts are authorized and justified (document)
  • Assure integrity of scripts on payment pages (CSP / SRI)

PCI DSS Section 8

• Minimum password length moving to 12 (8.3.6) (2025)
• MFA for ALL access to the CDE + new MFA features required (8.4.2) (2025)
• Can’t put system/software passwords in files/scripts (8.6.2) (2025)

PCI DSS Section 10 

• No manual log analysis, must automate (10.4.1.1) (2025)
• Failure of critical security controls detected, alerted, responded (10.7.2) (now)

PCI DSS Section 11 

• Internal VA scans must include authenticated scanning techniques (11.3.1.2) (2025)
• SAQ A added external VA scans (11.3.2) (now)
  • This is not FIM
  • Detects new scripts or changes to included scripts, runs at least weekly
  • Applicable to SAQ A, A-EP, D for Merchants, and D for Service Providers
• Deploy change and tamper detection system for payment page monitoring (11.6.1) (2025)

PCI DSS Section 12 

• Annual scope confirmation process more formal, moved out of introduction (12.5.2) (now)
  • Every 6 months for Service Provider (12.5.2.1) (2025)
• Regular Data Discovery technology needed for above tasks (12.5.2)
  • Exercise incident response as soon as PAN detected where not expected (12.10.7) (2025)
• Require employee training on Phishing and Social Engineering (12.6.3.1)

Tips to Start PCI v4.0 Compliance

While there is plenty of time to prepare for v4.0, start your transition to implement PCI v4.0 requirements early. You can move to v4.0 SAQ now, while working to implement future-dated requirements over the next few years. 

1. Get Up to Speed on PCI v4.0 Changes

• Read the Changes Document 
  • https://docs-prv.pcisecuritystandards.org/PCI%20DSS/Standard/PCI-DSS-v3-2-1-to-v4-0-Summary-of-Changes-r2.pdf
• Read Introductory sections (e.g., scoping, definitions, Business as usual section) 
  • https://docs-prv.pcisecuritystandards.org/PCI%20DSS/Standard/PCI-DSS-v4_0.pdf
• Review whole standard, including changes in the guidance columns
  • https://docs-prv.pcisecuritystandards.org/PCI%20DSS/Standard/PCI-DSS-v4_0.pdf
• Read PCI DSS v4.0 blogs and white papers
  • https://www.securitymetrics.com/blog/pci-dss-v40
  • https://www.securitymetrics.com/learn/pci-dss-v40
• Talk to a QSA about PCI v4.0
• Make a list of future-dated requirements that will affect you
  • https://www.securitymetrics.com/learn/key-pci-dss-v4-0-requirements    

2. Prepare for Your PCI v4.0 Assessment

• Document and confirm your PCI scope annually (to ensure all flows and locations of cardholder data are taken into account)
• Work with a QSA to get a v4.0 gap analysis
• Consider working with a QSA or third party on your annual targeted risk assessment for each PCI requirement
  • Note: The Customized Approach will be a bigger lift compared to the Defined Approach. Mature IT and risk organizations are needed to implement.
• If you do decide to use the Customized Approach, you need to start your preparation now.
• Find and test solutions for future-dated requirements before 2025