PCI DSS v4.0 is coming: how to meet its continuous compliance challenges

If your organisation accepts card payments—think Visa, Mastercard, American Express and so on—then you’ll know it has to comply with the Payment Card Industry Security Standards Council’s PCI Data Security Standard version 3.2.1 (PCI DSS v3.2.1).

No ifs. No buts. If your organisation accepts card payments, then compliance is a requirement. And of course so too are the regular—and usually annual—audits that compliance entails.

PCI DSS v3.2.1 came out in 2018. And version 3.2.1 was little changed from version PCI DSS v3.2.0, and indeed version PCI DSS 3.0.0: simply put, within the business world, the standard—and its accompanying audits—are by now well understood.

All change

But in March 2022, the Payment Card Industry Security Standards Council released a new version of the standard: version 4.0—and PCI DSS v4.0 is something of a radical departure from PCI DSS v3.2.1 and earlier PCI standards.

The core PCI DSS v3.2.1 requirements remain, revised for today’s world, today’s technologies, and today’s threats. But a whole new set of requirements have been introduced, reflecting a very different view of what contemporary data security best practice looks like.

The challenge: compliance is still mandatory, and the clock is ticking.  PCI DSS v3.2.1 will be retired on 31 March 2024, after which organisations must immediately move to PCI DSS v4.0 in respect of those core updated aspects of PCI DSS v3.2.1. And they have until a year later—early 2025—to comply with PCI DSS v4.0’s wholly new requirements.

All of which is already focusing minds.

So what is new in PCI DSS v4.0?

Let’s get something straight, at the start.

PCI DSS v4.0 is no cloistered, ivory tower-based, theoretical, and abstract security standard. It’s very much grounded in the real-world thinking.

It was developed with global industry collaboration. Over 200 companies provided detailed feedback—over 6,000 pieces of feedback in total. No fewer than three drafts were sent out for comment.

So in setting out these new requirements, PCI DSS v4.0’s goals very much reflect a direction of travel that is grounded in real-world best practice. And the four goals in question make that clear.

First, to increase flexibility for organisations to use different methods to achieve security objectives, fostering innovation and risk-based security controls. Second, the use of enhanced validation methods and procedures. And third, the promotion of security as a continuous process.

All of which combine to deliver a fourth and final objective: evolution of security practices so as to meet the changing needs of organisations as threats themselves emerge and evolve.

So what must we do?

That’s the question that organisations are asking themselves. And in doing so, they’re focusing on the notion of security as a continuous process, and the move away from periodic audits, which—let’s face it—could often to some extent be stage-managed.

Moving instead to a process of continuous compliance is obviously quite a radical departure. Adding flexibility and enhanced validation methods and procedures to the mix only adds to the challenge.

Yet it’s a necessary challenge if data security practices are to be fit for purpose in an ever-changing threat landscape. The world is not the same place as it was when PCI DSS v3.0 was formulated—which is why organisations must move with the times and embrace PCI DSS v4.0, and do so in good time, rather than in a rush as 2025 approaches.

But how?

As it happens, here at Quod Orbis we know quite a lot about continuous compliance. It’s what we do, and is what our solution—called Continuous Controls Monitoring—delivers.

With Continuous Controls Monitoring, every security control is audited continuously, in real time, using telemetry. Not a sample of controls. Not periodically. Every security control.

Doing so delivers ‘hard’ information that is accurate, definitive, completely non-subjective, and complete. It’s not a PCI assessor’s opinion at a point in time: it’s solid factual evidence, gathered continuously.

And gathered flexibly, as well—so that as threats and technologies evolve, the organisation can respond appropriately, rather than being confined to strictures codified in an out-of-date standard. And those enhanced validation methods and procedures? That’s what Continuous Controls Monitoring is, in short.

Where next?

Want to know more about continuous compliance, and the Quod Orbis approach to it? Check out our recent blog solely on the subject of continuous compliance, here.

Want to know how we might be able to help your organisation transition to PCI DSS v4.0? Then we’d be pleased to assist, so please call Alastair Dickson on 07939 286 006.

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