Breaking Down the Key Updates of PCI DSS 4.0

The Payment Card Industry Data Security Standard (PCI DSS) is a crucial part of business operations. It has become the standard for protecting payment card data by providing a comprehensive framework for organizations to safeguard cardholder information throughout the transaction process, from storage and transmission to processing and authentication.
However, due to the constantly evolving cyber threat landscape, the PCI -DSS framework has undergone a significant update with the release of version 4.0. This update aims to ensure the standard continues to meet the security needs of the payment industry, support security as an ongoing process, improve validation methods and procedures, and add flexibility and support for additional methodologies to achieve security.
This article breaks down the fundamental changes in PCI DSS 4.0 to help organizations understand how the new update addresses complex cyber threats and vulnerabilities facing today’s digital payment systems. It also explains how the update provides a more flexible framework for organizations striving to secure payment environments.

An Overview of PCI 4.0

In PCI DSS 4.0, organizations are encouraged to prioritize security measures based on risk profiles. This allows for more effective and targeted risk mitigation strategies. The updated standard, which entered effect on March 31, 2024, introduces a customized approach to risk-based security controls. Version 4.0 enables organizations to customize their requirements and testing procedures. This way, they can tailor their security controls to their specific environments.
The departure from the one-size-fits-all approach of previous PCI DSS versions provides greater flexibility in addressing unique risks and operational requirements. The customized approach in version 4.0 offers the advantage of defining a more permanent solution for compliance validation of specialized security controls. This differs from compensating controls, where organizations must document a justification for a control with a business or technical constraint.
The good news is PCI DSS 4.0 allows organizations to rely on their existing security implementations, which saves on new capital expenses. However, with PCI DSS 4.0 requirements, organizations must thoroughly document, test, and conduct risk analysis. These processes require more reporting on an organization’s side.

PCI-DSS 4.0’s Relevance

In PCI 4.0, the importance of risk assessments for customized and defined approaches has increased significantly. It’s worth noting that these risk assessments are more complex than a simple 30-minute process. Instead, organizations must follow a structured and formalized risk assessment process to ensure they are comprehensive and effective.
For instance, if an organization makes significant changes to its computing environment, such as adding a new intrusion detection system, it must conduct a thorough risk assessment. In such cases, engaging with a third party is essential to avoid additional efforts in the transition process. By taking a structured approach to risk assessments, organizations can ensure that they comply with PCI 4.0 requirements while minimizing potential risks.

A Comparative Analysis of PCI DSS 3.2.1 and PCI DSS 4.0

Digital payment infrastructures have significantly changed since the introduction of Payment Card Industry Data Security Standard (PCI DSS) version 3.2.1 in early 2018. Many companies have moved from traditional on-premises data hosting to cloud-hosted data containers. However, version 4.0 of the PCI DSS standard introduces 63 new requirements, some of which are effective immediately.
Most will take effect on March 31, 2025, to help organizations adapt to the new requirements.
Compared to version 3.2.1, the new version aims to improve critical processes within emerging technologies. It enhances authentication requirements, which now include the broader use of multifactor authentication (MFA), increasing the password length to 12 characters, and extending the standard’s scope to include mobile, Internet of Things (IoT), and cloud. Version 4.0 addresses evolving threats targeting payment applications and processes, such as phishing, social engineering, and other business email compromise (BEC) attacks.
Below is a comparative analysis of PCI DSS 3.2.1 and 4.0:


  • PCI 3.2.1 introduced multifactor authentication (MFA) for personnel with non-console administrative access and all remote access to the cardholder environment.
  • PCI 4.0 expands on MFA by reinforcing additional authentication requirements, including longer passwords (12 characters) for all access to cardholder data.

Protection of Cardholder Data:

  • PCI 3.2.1 focuses on encryption of cardholder data during transmission over open, public networks.
  • PCI 4.0 expands encryption requirements to protect stored cardholder data and encrypted transmission over more networks.

Customizable Controls:

  • PCI 3.2.1 primarily focuses on prescriptive controls, offering detailed instructions on what organizations should do to remain compliant.
  • PCI 4.0 emphasizes security outcomes, thus allowing businesses more flexibility in choosing the security strategies that best fit their unique environment.

Risk Assessment and Management:

  • PCI 3.2.1 requires an annual risk assessment, but there is less emphasis on integrating risk management into the overall PCI DSS compliance processes.
  • PCI 4.0 strongly focuses on continuous risk assessment and adaptive security tailored to the evolving cyber threats landscape.

Continuous Security:

  • PCI 3.2.1 views compliance from a point-in-time assessment.
  • PCI 4.0 encourages continuous security and monitoring requirements, highlighting compliance as an ongoing process, not an ‘annual audit.’

Services Providers’ Responsibilities:

  • PCI 3.2.1 outlines service provider responsibilities in a limited, a la carte manner.
  • PCI 4.0 extends service provider responsibilities, encouraging organizations to maintain a documented description of cryptographic architecture and increasing oversight on change management processes.

Cryptographic Architecture Management:

  • PCI 3.2.1 stipulates that organizations should maintain a record of cryptographic algorithms that are either weak or unacceptable for future use.
  • PCI 4.0 requires organizations to document their cryptographic architecture thoroughly, including a comprehensive overview of their encryption, decryption, and key management processes. Additionally, PCI 4.0 mandates using keyed cryptographic hash techniques that differ from the commonly used hash algorithms. This means that organizations may have to switch to methods such as HMAC, CMAC, or GMAC, with a cryptographic strength of at least 128 bits.

Challenges Implementing PCI-DSS 4.0

The PCI Security Standards Council (PCI SSC) announced that in their latest security standards, version 4.0, organizations must provide documentation and risk assessment data for qualified security assessors (QSA) to evaluate outcomes-based compliance. However, this new validation approach may result in more initial organizational risk assessment work. It may disrupt business continuity, as the QSA must conduct specialized testing procedures during evaluation.

Solutions for Addressing Implementation Challenges of PCI-DSS 4.0

Streamline Documentation and Risk Assessment Processes

Develop standardized templates and procedures for documenting security controls and risk assessments to ensure consistency and efficiency.
Provide comprehensive training to internal staff on effectively gathering, organizing, and presenting documentation for QSA evaluation.

Proactively Operational Measures

Conduct thorough planning and risk analysis before engaging in PCI DSS 4.0 compliance activities to anticipate potential disruptions to business continuity.
Implement backup and contingency plans to mitigate the impact of any disruptions that may occur during the evaluation process.
Communicate proactively with stakeholders, including employees, customers, and partners, about potential disruptions and the steps to minimize their impact.

Optimize Resource Allocation for Small to Midsize Businesses

Prioritize compliance efforts based on risk assessment findings to allocate resources efficiently. Consider outsourcing specific compliance tasks, such as documentation preparation or specialized testing procedures, to third-party vendors or consultants to reduce the burden on internal resources. Explore cost-effective solutions and technologies that meet PCI DSS 4.0 requirements without significantly increasing expenses.

Leverage Existing Security and Risk Assessment Processes

Capitalize on existing security technologies, processes, and personnel investments to align with PCI DSS 4.0 requirements.
Conduct a gap analysis to identify areas where current security and risk assessment processes may need enhancement or realignment to meet the new validation approach.
Implement continuous monitoring and improvement mechanisms to ensure ongoing compliance with PCI DSS 4.0 requirements and adapt to evolving security threats and industry standards.

Engage QSAs Early in the Process

Establish an open line of communication with QSAs to address queries and ensure a smooth assessment experience.
Collaborate with QSAs early in compliance to gain insights into their expectations and streamline the evaluation process.
Implement a proactive risk management framework, identifying and mitigating potential risks before the QSA evaluation.

Establish a Continuous Improvement Cycle

Implement a feedback loop based on assessment outcomes to continually refine security practices and documentation processes.
Regularly update and adapt organizational security measures based on lessons learned from each assessment cycle.
PCI DSS 4.0 represents a significant update to the security standard that addresses the constantly evolving cyber threat landscape and the need for greater flexibility in addressing unique risks and operational requirements. The new version provides organizations with a customized approach to risk-based security controls, allowing them to tailor their security controls to specific environments. While the transition to PCI DSS 4.0 may require more effort, it ultimately results in a more comprehensive and effective security framework that protects payment card data throughout the transaction process.

With strategic planning, diligence, and a proactive mindset, organizations can embrace the opportunities presented by PCI DSS 4.0 to enhance security posture, build customer trust, and drive sustainable growth in an increasingly digital world.

Learn about some companies 360 Advanced helped to get PCI-DSS compliance:
DataBank Successfully Achieves SSAE 18 SOC 1/2, PCI-DSS, and HIPAA Compliance Seven Years in a Row

Colo Solutions Achieves 5 Consecutive Years of SOC 1, HIPAA, and PCI Compliance

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