PCI DSS

PCI DSS twelve requirements and cardholder data scope explained

PCI DSS is the security standard that applies the moment your business touches payment card data, enforced by the card brands and your acquiring bank rather than by any law.

  • Glossary
  • Compliance

The short answer

PCI DSS is the Payment Card Industry Data Security Standard: twelve requirements covering how cardholder data is stored, transmitted and protected. How you validate depends on transaction volume, from a self-assessment questionnaire at the low end to an on-site assessment by a qualified assessor at the high end. Version 4.0.1 is the only active version, and every requirement in it has been mandatory since 31 March 2025.

The single most useful thing to understand early is that PCI DSS scope drives cost. What determines your effort is not the twelve requirements themselves but how much of your infrastructure sits inside the cardholder data environment.

The twelve PCI DSS requirements

The twelve PCI DSS requirements group into six goals. The grouping matters more than the numbering, because it shows where the work concentrates.

GoalRequirements
Build and maintain a secure network1. Network security controls · 2. Secure configurations, no vendor defaults
Protect account data3. Protect stored data · 4. Encrypt transmission across open networks
Maintain a vulnerability management programme5. Protect against malicious software · 6. Develop and maintain secure systems
Implement strong access control7. Restrict access by business need · 8. Identify users and authenticate access · 9. Restrict physical access
Monitor and test networks10. Log and monitor all access · 11. Test security regularly
Maintain an information security policy12. Support the programme with organisational policies

Requirement 8 is where identity and access management lands, requirement 10 is logging and monitoring, and requirement 11 pulls in scanning and penetration testing. Requirement 12 is the governance layer, including a tested incident response plan.

What changed in PCI DSS version 4.x

PCI DSS version 4.0 introduced 64 new or updated requirements. Thirteen applied immediately. The remaining 51 were designated future-dated best practices and became mandatory on 31 March 2025, which means any assessment from that date scores all of them as fully in scope with no grace period.

ChangeWhat it means in practice
MFA for all CDE accessRequirement 8.4.2 extends multi-factor authentication beyond administrators and remote users to every account entering the cardholder data environment
Payment page script inventoryRequirement 6.4.3 asks for an authorised inventory of every script running on a payment page, which fails on governance gaps more often than on technology
Payment page tamper detectionRequirement 11.6.1 requires detection of unauthorised changes to payment pages, aimed squarely at skimming attacks
Authenticated internal scanningInternal vulnerability scans must now run with credentials rather than unauthenticated
Targeted risk analysisSeveral requirements let you set your own frequency, provided a documented risk analysis justifies it
Customised approachYou may meet a requirement’s objective with a different control, if you can evidence that it achieves the same outcome

Check which version your last assessment used

PCI DSS 3.2.1 retired on 31 March 2024 and 4.0 retired on 31 December 2024, leaving 4.0.1 as the only active version. An organisation that validated in 2024 and treated the future-dated items as optional will fail its next assessment unless those controls are now in place. A successor version is in development, with no release date announced.

Which PCI DSS level applies

PCI DSS levels are set by annual transaction volume per card brand, and the thresholds vary slightly between brands. The pattern below is the common shape.

LevelRough volumeHow you validate
Level 1Over 6 million transactions a yearAnnual Report on Compliance by a qualified security assessor, plus quarterly external scans by an approved vendor
Level 21 to 6 millionSelf-assessment questionnaire, sometimes an assessor depending on the brand and acquirer
Level 320,000 to 1 million e-commerceSelf-assessment questionnaire plus quarterly external scans
Level 4Below the level 3 thresholdsSelf-assessment questionnaire, with requirements set by the acquirer

Which questionnaire you complete depends on how payments are handled. A merchant that fully outsources card entry to a hosted page answers far fewer questions than one that touches card data directly. Your acquirer confirms both the level and the questionnaire type, so ask them before assuming.

PCI DSS scope is most of the work

The PCI DSS cardholder data environment covers every system that stores, processes or transmits card data, plus anything connected to it that could affect its security. Shrinking that boundary is the highest-leverage decision available.

Card data touches your systems Web servers Application layer Databases Backups and logs Hosted page and tokenisation Payment page Out of scope Out of scope Out of scope The payment page stays in scope either way. Requirements 6.4.3 and 11.6.1 follow the page, not the card field.
TechniqueEffect on scope
Hosted payment page or redirectCard data never reaches your servers, which cuts scope more than any control you could deploy
TokenisationA token replaces the card number in your systems, so downstream databases fall out of scope
Point-to-point encryptionCard data is encrypted at the terminal, so intermediate systems cannot read it
Network segmentationIsolates the environment so the rest of the estate is not dragged in
Storing card numbersExpands scope sharply and is rarely necessary once tokenisation is in place

Note that outsourcing card capture reduces your scope without removing it. Payment page script controls still apply, because the page your customer sees is served by you even when the card field is not.

How Osto maps PCI DSS controls

PCI DSS overlaps heavily with what you already need for SOC 2 and ISO 27001. Access control, logging, vulnerability management, secure configuration and incident response appear in all three, worded differently. Osto runs those controls once and maps the evidence across 200 or more frameworks, so the second and third standard cost a fraction of the first.

On the technical side, web and API protection covers requirement 6.6, VAPT and scheduled scanning cover requirement 11, correlated logging covers requirement 10, and MFA enforced at the access gate covers the expanded requirement 8.4.2. Osto is not a qualified security assessor and does not issue a Report on Compliance. What it does is remove the gap between having a control and being able to prove it ran.

Platform walkthrough

One control set, every framework

Access, logging, scanning and web protection run in one platform and map across 200 or more frameworks. Prove the same control to a card brand, an auditor and an enterprise buyer.

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Frequently asked questions

What is PCI DSS?

The Payment Card Industry Data Security Standard: twelve requirements governing how organisations that store, process or transmit payment card data must protect it. It is maintained by the PCI Security Standards Council and enforced contractually by the card brands and acquiring banks.

Is PCI DSS a legal requirement?

Not in most jurisdictions. It is a contractual obligation that arrives through your merchant agreement or payment processor. The practical consequences of non-compliance are fines passed down by the acquirer, higher transaction costs, and liability after a breach.

Which version of PCI DSS is current?

Version 4.0.1. Version 3.2.1 retired on 31 March 2024 and version 4.0 retired on 31 December 2024. Every requirement in 4.0.1, including the 51 that were originally future-dated, has been mandatory since 31 March 2025.

What is the cardholder data environment?

Every system that stores, processes or transmits cardholder data, along with any connected system that could affect its security. Defining and shrinking this boundary is the main lever on cost, because everything inside it must meet all applicable requirements.

Does using a payment provider make us compliant?

It reduces your PCI DSS obligations substantially but does not remove them. You still complete a self-assessment questionnaire, and the payment page script and tamper detection requirements can still apply, because the page is served by you even when the card field belongs to the provider.

How does PCI DSS relate to SOC 2 and ISO 27001?

They overlap heavily. PCI DSS, SOC 2 and ISO 27001 all cover access control, logging, vulnerability management and incident response, worded differently in each. Teams that map one control set across frameworks rather than running three separate programmes save most of the duplicated effort.