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PCI DSS 4.0.1 · 16 RECURRING ACTIVITIES

PCI DSS 4.0.1 Compliance Calendar — quarterly + annual cadence

PCI DSS is the most cadence-heavy of the major frameworks: daily log reviews, quarterly ASV scans, semi-annual segmentation tests, annual penetration tests + ROC/SAQ. Miss any one and your acquirer or QSA will note it as a non-compliance.

Cadence mix:2× Weekly2× Monthly2× Quarterly2× Every 6 months6× Annually2× Event-triggered
Who this is for
  • Merchants Level 1–4 (with or without QSA-led audit)
  • Service providers handling cardholder data
  • Engineering teams operating the cardholder data environment (CDE)
Typical effort
Variable by scope. Small SAQ-A merchant: <40 hrs/yr. Level-1 service provider with full ROC: multi-FTE.

The calendar

Weekly (2)

Daily log review (rolled up weekly)
Logging
Daily review of security events on CDE systems. Auto-tooling acceptable, but documented investigation of anomalies required.
Reference
Req. 10.4
Owner
Security + DevOps
Effort
30 min/day
Evidence
Log review evidence
Critical security control checks
Network
Confirm firewall rules, IDS/IPS alerts, anti-malware signatures.
Reference
Req. 1, 11.5
Owner
Network + Security
Effort
1–2 hrs
Evidence
Control check log

Monthly (2)

Critical patch installation
Patching
Critical security patches installed within 1 month of release.
Reference
Req. 6.3.3
Owner
DevOps
Effort
4–8 hrs
Evidence
Patch records
Internal vulnerability scans
Vulnerability
Required by 11.3.1 — internal scans by qualified personnel; remediate per risk.
Reference
Req. 11.3.1
Owner
Security
Effort
4 hrs
Evidence
Internal scan report

Quarterly (2)

External ASV scan (Approved Scanning Vendor)
ASV Scan
Pass scan from ASV; remediate Highs and rescan if needed; submit attestation.
Reference
Req. 11.3.2
Owner
Security + ASV
Effort
Vendor + 4–8 hrs internal
Evidence
ASV attestation
User access review (CDE accounts)
Access
Manager-certified review; remove dormant; verify privileged still appropriate.
Reference
Req. 7, 8.2.6
Owner
Manager + IT
Effort
4 hrs
Evidence
Access review report

Every 6 months (2)

Firewall / router rule review
Network
Review every CDE firewall rule for business justification + necessity. Remove obsolete.
Reference
Req. 1.2.7
Owner
Network
Effort
4–8 hrs
Evidence
Firewall review
Network segmentation test (service providers)
Segmentation
Service providers must test segmentation effectiveness every 6 months. Merchants: annually.
Reference
Req. 11.4.5 / 11.4.6
Owner
Pen tester
Effort
Vendor-led
Evidence
Segmentation test report

Annually (6)

Penetration test — application + network (internal + external)
Pen Test
Per 11.4 — methodology, scope = CDE + connected systems. Remediate critical/high before report close.
Reference
Req. 11.4
Owner
Pen tester
Effort
Vendor + ~24 hrs internal
Evidence
Pen test + remediation
Targeted risk analysis (per Customised Approach controls)
Risk
PCI DSS 4.0 introduced targeted risk analyses for any control implemented via Customised Approach + for periodic frequency definitions.
Reference
Req. 12.3.1
Owner
Security
Effort
8 hrs
Evidence
Targeted risk analysis
Security awareness — CDE personnel + role-based
Training
All personnel with CDE access; role-based training for developers, sysadmins.
Reference
Req. 12.6
Owner
Security + HR
Effort
4 hrs admin
Evidence
Training records
Policy + procedure review
Policy
Update for environment / scope / regulation changes. Documented review.
Reference
Req. 12.1
Owner
Security + Compliance
Effort
8 hrs
Evidence
Updated policy library
Service provider list + responsibility matrix review
Vendor
Maintain list per 12.8.1; obtain attestation per 12.8.4; review responsibility matrix per 12.8.5.
Reference
Req. 12.8
Owner
Procurement + Security
Effort
8 hrs
Evidence
Service provider register
ROC or SAQ + Attestation of Compliance
Validation
QSA-led ROC for Level 1; SAQ self-validation for lower levels. Submit AOC to acquirer.
Reference
PCI DSS Validation
Owner
QSA / Security + Exec
Effort
Variable; weeks for ROC
Evidence
ROC / SAQ + AOC

Event-triggered (2)

Significant change to CDE
Change
Any significant change → reassess scope, retest segmentation, rescan, update documentation.
Reference
Req. 6.5.2, 11.3.1.1
Owner
Security + Eng
Effort
Variable
Evidence
Change + revalidation record
Cardholder data incident response
Incident
Activate IR plan; preserve evidence; notify acquirer + brands per agreement timelines.
Reference
Req. 12.10
Owner
Incident lead + Legal
Effort
Variable
Evidence
Incident record

Pitfalls — where teams actually fail

Want this calendar mapped to YOUR controls?

Drop your existing PCI DSS 4.0.1 policy or upload a draft — ComplianceIQ scores it against the framework and produces a 0–100 audit, gap-by-gap with the cadence work you're missing.

Run free PCI DSS 4.0.1 audit See readiness checklist

What happens when the cadence slips — real PCI DSS 4.0.1 actions

~$202M
Target · 2013
~$256M
TJX Companies · 2007

FAQ

How often is the ASV scan required?
Quarterly per Req. 11.3.2. Plus after any significant change to the CDE. Failed scans must be remediated and rescanned to a passing result.
Is annual penetration testing always required?
Yes per Req. 11.4 (and after any significant change). Both internal and external; segmentation controls must be validated. Methodology must be industry-accepted (e.g. PTES, OSSTMM, OWASP).
What's new in PCI DSS 4.0.1 ongoing cadence vs 3.2.1?
Targeted risk analyses for periodic frequencies + Customised Approach controls (12.3.1), expanded service provider segmentation testing, MFA on all CDE access, role-based developer training, and more documented evidence around scoping.
Does this calendar apply to SAQ-A merchants?
Many cadences scale down. SAQ-A only outsources card data fully — but you still need vendor management, training, policy review, and incident response prep. Ignore the cadence and you'll fail your acquirer's annual SAQ check.

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