With the recent updates to the Payment Card Industry Data Security Standard (PCI DSS) requirements, many organizations that are currently PCI compliant in accordance with version 3.2.1 may become noncompliant with version 4.0. This series of blogs will outline the changes to each of the eight self-assessment questionnaires (SAQs) and areas that merchant organizations should consider prior to the required implementation date of March 31st, 2024.
Merchants’ eligibility criteria for version 3.2.1 and version 4.0 remain the same and are for those merchants whose account data (cardholder data) functions are completely outsourced to PCI DSS validated and compliant third parties, and the merchant only retains paper reports or receipts with account data.
Merchant organizations that qualify and are adhering to PCI 3.2.1 SAQ-As currently have 5 requirements with 21 specific controls that must be in-place to achieve a PCI-DSS “compliant” rating. In version 4.0, merchant organizations will need to adhere to 7 requirements and 31 specific controls to receive a compliant rating. Below is a list of the additional requirements that have been included in the PCI DSS v4.0 SAQ-A:
NEW REQUIREMENT - Requirement 3.1.1
All security policies and operational procedures for protecting stored account data are defined and understood are:
NEW REQUIREMENT - Requirement 3.2.1
Account data storage is kept to a minimum through implementation of data retention and disposal policies, procedures, and processes that include at least the following:
NEW REQUIREMENT - Requirement 6.3.3
All system components are protected from known vulnerabilities by installing applicable security patches/updates as follows:
NEW REQUIREMENT - Requirement 6.4.3
All payment page scripts that are loaded and executed in the consumer's browser are managed as follows:
NEW REQUIREMENT - Requirement 8.3.5
If passwords/passphrases are used as authentication factors, they are set and reset for each user as follows:
NEW REQUIREMENT - Requirement 8.3.6
If passwords/passphrases are used as authentication factors, they meet the following minimum level of complexity:
NEW REQUIREMENT - Requirement 8.3.7
Individuals are not allowed to submit a new password/passphrase that is the same as any of the last four passwords/passphrases used.
NEW REQUIREMENT - Requirement 8.3.9
If passwords/passphrases are used as the only authentication factor for user access (i.e., in any single-factor authentication implementation) then either:
NEW REQUIREMENT - Requirement 9.4.1.1
Offline media backups with cardholder data are stored in a secure location.
NEW REQUIREMENT - Requirement 11.3.2
External vulnerability scans are performed as follows:
NEW REQUIREMENT - Requirement 11.3.2.1
External vulnerability scans are performed after any significant change as follows:
NEW REQUIREMENT - Requirement 11.6.1
A change- and tamper-detection mechanism is deployed as follows:
Another change in version 4.0 is the compliance responses available, specifically the “in place with remediation” response. In some cases of version 3.2.1, merchants would not fully be adhering to a specific requirement at the time of the assessment and would receive a “not in place” response because some or all elements of the requirement had not been met, and the merchant cannot confirm the requirement was in place. Merchants would make necessary changes to adhere to the requirement and an “in place” response would be checked. With version 4.0, a new response, “in place with remediation” is available to address these issues. In place with remediation means that the requirement was not in place when the initial testing was performed but the merchant identified and addressed the reason the control failed, has implemented the control, and has implemented ongoing processes to prevent reoccurrence of the control failure.
Merchant organizations that qualify to complete an SAQ-A should immediately identify solutions to adhere to these new requirements, prior to the required implementation date of March 31st, 2024, and specifically requirement 11.3.2 – external vulnerability scanning by an ASV. This has never been a requirement for SAQ-As and does incur an additional cost to the merchant since free tools will not meet the criteria for an “in place” remark. The PCI SSC does provide a list of 87 ASVs on their website to make the selection process easier.
Compass IT Compliance has spent the past decade serving as a trusted PCI DSS Qualified Security Assessor (QSA) for merchants and service providers across the nation. We were early adopters of PCI DSS and have the extensive expertise and resources to simplify the compliance process from start to finish. Contact our team today to discuss your unique situation!