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PCI DSS v4.0.1 Security Policy Audit

Grade your information security policy against the 12 PCI DSS requirements every merchant and processor must meet — cardholder data protection, encryption, access control, logging, vulnerability scanning, and incident response. Get the exact wording to add for every gap before your QSA finds it.

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Payment Card Industry Data Security Standard v4.0.1 · Any merchant, processor, or service provider that stores, processes, or transmits cardholder data (global)

What PCI DSS non-compliance actually costs

$5,000 – $100,000/mo
Acquirer fines for non-compliance
Per Visa/Mastercard operating rules
$5 – $90 per card
Per-record breach assessment
Card brand recovery + reissuance fees
$292M+
Target (2013 breach settlement)
40M cards exposed; ~$202M legal + $18.5M state AG settlement + card brand fines
$200M+
Home Depot (2014 breach settlement)
56M cards; $25M consumer + $134.5M card issuer settlements + remediation

Who must comply with PCI DSS?

What this audit checks

12 required clauses, scored as Present / Partial / Missing with the exact regulatory citation and suggested fix.

1
Network segmentation + firewall ruleset documentation
Req. 1 — explicit deny-all default, documented justification for every allow rule, reviewed every 6 months
2
No vendor-default passwords or accounts
Req. 2 — vendor defaults changed, hardening standards aligned to CIS/NIST
3
Stored cardholder data protection (PAN masking + truncation)
Req. 3 — PAN unreadable wherever stored; render via strong crypto, hashing, truncation, or tokenization
4
Strong cryptography for PAN in transit over open/public networks
Req. 4 — TLS 1.2+ minimum, trusted keys/certs only
5
Anti-malware on systems commonly affected
Req. 5 — kept current, periodic evaluations of evolving threats including phishing per v4.0.1
6
Secure software development + change control
Req. 6 — SDLC, code review, OWASP coverage, separation of dev/test/prod, patching SLA
7
Need-to-know access + least privilege
Req. 7 — RBAC, documented access matrix, default-deny
8
Unique IDs + MFA for all access to the CDE
Req. 8 — MFA now required for ALL access into the CDE (not just admin) per v4.0
9
Physical access controls + media handling
Req. 9 — visitor logs, badge controls, media destruction
10
Audit logging + 1-year retention (3-month online)
Req. 10 — daily review, integrity monitoring, time sync
11
Quarterly external ASV scans + internal vuln scans + annual pen test
Req. 11 — ASV passing scan every 90 days, segmentation testing annually
12
Information security policy + annual risk analysis
Req. 12 — formal policy reviewed annually, security awareness, incident response plan, customized approach documentation if used
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Why PCI DSS audits actually fail

Treating SAQ-A as 'no compliance work'
Even fully-outsourced e-commerce (SAQ-A) requires written policies, vendor mgmt for service providers (Req. 12.8), and quarterly attestation. Most QSAs find missing TPSP inventories first.
Storing CVV/CVC2/CID anywhere
Req. 3.2 — sensitive authentication data must NEVER be retained after authorization, even encrypted. Found in app logs, email order confirmations, and call recordings on almost every audit.
MFA only for admins
v4.0 made MFA mandatory for ALL access into the CDE, including individual application users. The deadline is now in effect (after Mar 31, 2025).
Customized Approach without a Targeted Risk Analysis (TRA)
v4.0 allows alternative controls, but you must produce a written TRA per requirement you customize. Skipping the TRA invalidates the customized control.

PCI DSS FAQ

What merchant level am I?
Level 1: >6M Visa/MC transactions/year (or any breach). Level 2: 1M–6M. Level 3: 20K–1M e-commerce. Level 4: <20K e-commerce or <1M total. Levels 2–4 may self-assess via SAQ; Level 1 requires an annual on-site QSA assessment + quarterly ASV scans.
Does tokenization eliminate PCI scope?
It reduces scope significantly but does not eliminate it. Any system that touches the PAN before tokenization (capture page, IVR, POS) is still in scope. Properly architected redirect/iframe + Service Provider tokenization can reduce most merchants to SAQ-A.
What changed in PCI DSS v4.0.1?
v4.0.1 (June 2024) clarifies v4.0 wording but introduces no new requirements. Key v4.0 changes already in effect: MFA for all CDE access, customized approach option, targeted risk analyses, anti-phishing controls, payment-page script integrity monitoring (Req. 6.4.3, 11.6.1).

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