PCI DSS 4.0 Timeline and Important Considerations for Compliance

PCI DSS 4.0 Timeline and Important Considerations for Compliance

If your organization handles credit card information, you must achieve full compliance with PCI DSS 4.0 by April 1, 2024. Non-compliance by this date may lead to monthly penalties until compliance is fully achieved. This article will guide you through the compliance requirements of the latest data security standard version, with the goal of helping you meet all the necessary criteria as efficiently as possible.

What Is PCI DSS 4.0?

The Payment Card Industry Data Security Standard, or PCI DSS 4.0, is a set of rules established by well-known credit card companies to thwart fraud and guarantee cardholder data security. It outlines the procedures, policies, and security measures businesses must implement to protect credit card information.

To keep up with changing cybersecurity risks, the Payment Card Industry Security Standards Council (PCI SSC) regularly updates the PCI DSS, which is the most recent version of PCI 4.0.

What Is the Timeline for PCI DSS 4.0?

What Are the Requirements for PCI DSS 4.0?

The official release date of PCI DSS 4.0 was March 31, 2022. Organizations have been granted a transition period to become used to the new standards. PCI DSS v3.2.1, the previous version, will continue to be in effect until March 31, 2024, giving businesses two years to get acquainted with and make the necessary modifications following PCI DSS 4.0. After this date, PCI DSS 4.0 will replace v3.2.1 as the current standard.

It is also important to note that 64 new requirements have been added to the most recent version of PCI DSS. Eleven of these are reserved exclusively for service providers. Furthermore, 13 of the 64 requirements apply to all PCI DSS 4.0 examinations right now. The other requirements are marked as future-dated; they will be considered best practices until March 31, 2025, when they will no longer be optional.

It means that both versions will coexist until March 31, 2024. Additionally, organizations will have one more year, until March 31, 2025, to ensure full compliance with PCI DSS 4.0.

Why Update to PCI DSS 4.0?

As technology advances, so must cybersecurity measures. PCI DSS sets security guidelines for merchants and service providers handling cardholder and authentication data. The PCI Security Standards Council, composed of the five largest credit card companies (AMEX, JCB International, Discover Financial Services, Visa, and Mastercard), updates these standards to stay current with emerging threats and evolving data security needs. The introduction of PCI DSS 4.0 is a result of these continuous efforts. The revision process focused on four key objectives:

  • Satisfying Security Requirements: PCI DSS Version 4.0 ensures efficient adjustments to counter new security risks while addressing the changing threats facing the payment card industry.
  • Persistent Security: With PCI DSS 4.0, compliance is now a continual activity rather than a one-time occurrence. This change encourages year-round alertness and flexibility in response to emerging risks.
  • More Flexibility: With greater freedom to accomplish security goals in ways that best suit their unique operations, enterprises may now take advantage of the latest edition. Organizations now have the flexibility to create and implement distinctive controls that meet the necessary “customized approach aim” thanks to the introduction of the customized approach.
  • Enhanced Validation Methods: PCI DSS 4.0’s improved validation procedures, which include Self-Assessment Questionnaires (SAQs), Attestations of Compliance (AOCs), and Reports on Compliance (ROCs), make the compliance verification process more efficient.

PCI DSS 4.0 introduces a significant shift in compliance strategies, allowing organizations more autonomy in how they meet specific requirements. For most requirements, organizations can now opt for either the Defined Approach, which provides precise guidelines on meeting and assessing compliance, or the Customized Approach, which permits organizations to implement their own methods, provided they achieve the intended security objectives.

But, as the standard clearly states with the notation, “This criterion is not eligible for the customized method,” some needs are exclusively limited to the Defined method. This makes it clear which requirements demand that certain criteria be followed.

What Are the Requirements for PCI DSS 4.0?

requirement for pci dss 4.0 compliance

As mentioned, 13 of these are required to be implemented immediately. These changes include significant updates to authentication, encryption, and access control measures to address evolving security threats. The immediate requirements effective from the release of PCI DSS 4.0 focus on enhancing data protection and security management processes.

Here are some of the key requirements that are effective immediately:

  • Stored Sensitive Authentication Data Encryption: All sensitive authentication data that is stored needs to be encrypted.
  • Multi-Factor Authentication (MFA): Every account with access to cardholder data must use MFA.
  • Management of Access Privileges: Access privileges need to be evaluated at least twice a year to ensure their suitability.
  • Protection Against Phishing: Automatic procedures and systems must be implemented to identify and stop phishing assaults.
  • Web application firewalls: Any web application accessible over the Internet needs a web application firewall installed.
  • Inventory of Scripts on Websites: All known scripts used on websites must be kept up to date to reduce the danger of dangerous scripts.
  • SSL and TLS Certificates: To guarantee their authenticity, all SSL and TLS certificates used in public domains need to be tracked, inventoried, and documented.
  • Annual Password Changes: Whenever there is a suspicion of a breach, passwords for payment applications and systems must be updated at least once a year.
  • Robust Password Requirements: Passwords should be at least 12 characters long, strong, and unique. They should also contain a combination of alphabetical and numeric characters.
  • Vendor and Third-Party Account Management: These accounts must be used only when necessary and monitored continuously for vulnerabilities.
  • Disk-Level Encryption: Using disk-level encryption for non-removable media is no longer permitted.
  • Keyed Cryptographic Hash Method: A keyed cryptographic hash method must be used to protect card data.
  • Continuous Security Monitoring: Continuous security processes and visibility into security controls are emphasized, requiring ongoing assessments and updates to security measures.

These main requirements include several sub-requirements or cybersecurity controls that organizations need to implement. For instance, the access control category further defines specific measures such as password length requirements and multi-factor authentication (MFA) to enhance security protocols.

What Are the Changes in PCI DSS 4.0?

As highlighted, PCI DSS 4.0 has been revised to address the changing landscape of cyber threats. It introduces over 60 new requirements, amends existing ones, and eliminates others. These updates significantly emphasize account security.

The updated standards mandate multi-factor authentication (MFA) and stronger passwords for internal employees to access cardholder data environments (CDE). These measures aim to protect your business from account takeover attacks and mitigate the risk should an employee be compromised by a social engineering attack, preventing cybercriminals from gaining access to your systems.

PCI 4.0 introduces the option for custom implementation, allowing your organization the flexibility to innovate in applying technology to meet PCI compliance. This approach requires you to demonstrate that your compliance strategies are coherent and cohesive. The update demands that you address all security vulnerabilities, not just the critical and high-risk ones previously mandated in version 3.2.1. This change responds to the increasingly sophisticated nature of cyberattacks, which now exploit even minor systemic weaknesses to steal cardholder data and breach defenses.

Furthermore, PCI 4.0 requires the scanning of all removable media, such as USBs and external hard drives, with malware detection software to counter the rise of malware and ransomware attacks.

This version also mandates more specific and frequent cybersecurity awareness training. Your staff must receive training at least annually, with the training materials reviewed every 12 months. The guidelines specify that training should cover phishing attacks and social engineering schemes. Additionally, there is a requirement to increase password lengths from a minimum of seven characters in PCI 3.2.1 to a minimum of 12 characters, provided your system supports it; otherwise, the minimum is eight characters.

The effort and expense involved in implementing these changes will vary depending on the complexity of an organization’s infrastructure within the scope of the PCI assessment. For instance, updating password policies to require a minimum of 12 characters could be a quick adjustment for a single web application, but applying and thoroughly testing this change across numerous corporate applications might take much longer.

Implications of Non-Compliance with PCI DSS

Implications of Non-Compliance with PCI DSS

Failing to comply with PCI DSS standards can lead to substantial financial repercussions. Risks include hefty fines, increased chargebacks, higher transaction fees, and the potential loss of customers due to compromised credit card data security. The severity of these consequences often depends on your organization’s processing level.

For example, Non-compliance with PCI standards can lead to fines imposed by credit card companies (such as MasterCard, Visa, AMEX, Discover) ranging from $5,000 to $100,000 per month. The size of the penalty often depends on the volume of clients and transactions, which also determines the required level of PCI DSS compliance for a company. A level-1 company that fails to meet its PCI DSS obligations for more than seven months could face fines as high as $100,000 per month.

Additionally, non-compliance with specific requirements at level 4 could escalate your organization to a higher compliance level, such as level 1. It is crucial to fully understand these requirements and maintain ongoing compliance to protect your organization from the severe impacts that can arise from disregarding PCI DSS standards.

Best Practices for Implementing PCI DSS 4.0

Making the switch to PCI DSS 4.0 can be a complicated and intricate process that requires careful preparation and exacting execution. It is critical to adhere to best practices that facilitate process streamlining in order to manage this transition successfully. The following are crucial tactics to guarantee a seamless and successful transition:

  • Begin Early: Make your preparations as soon as possible. Since the deadline is drawing near, time is of the essence and every month counts.
  • Understand the Changes: Thoroughly examine the change documentation and consult with internal experts to understand how the new requirements will fully impact your organization.
  • Maintain Existing Controls: Maintaining your present 3.2.1 controls will provide a solid base for the upgrade to version 4.0.
  • Select the Appropriate Validation Approach: Decide whether the defined or customized approach best aligns with your organization’s risk profile and objectives.
  • Utilize Available Guidance: The guidelines offer valuable insights, including for those completing SAQs. Take full advantage of this detailed guidance.
  • Enhance Communication: Ensure that those involved in the organization are informed and part of the transition process. Effective communication fosters cross-departmental understanding and alignment.
  • Engage Trusted Partners: Work with PCI compliance-focused Qualified Security Assessors (QSAs). Consider investing in your team’s PCI professional certification and internal security assessor certification to strengthen internal skills.
  • Prioritize Continuous Security: Treat security as an ongoing process, not just an annual compliance effort. Cultivate a security-minded culture within your organization to proactively address risks throughout the year.
  • Conduct Preliminary Assessments: Conduct internal assessments early to identify and remediate any gaps before your official assessment. This proactive approach helps streamline the compliance journey.


Organizations handling credit card information must achieve full compliance with PCI DSS 4.0 by April 1, 2024. This transition period requires careful planning and execution to meet the updated standards effectively. With 64 new requirements, including immediate implementation mandates and future-dated criteria, organizations must promptly and thoroughly navigate the changes.

The updated PCI DSS 4.0 offers more flexibility, allowing organizations to tailor their security measures to their specific needs while addressing new threats. Failing to comply with these standards can result in significant financial penalties, so protecting cardholder data and maintaining customer trust is crucial. By following best practices, such as preparing early, understanding the changes, and prioritizing continuous security, organizations can smoothly transition to PCI DSS 4.0 and effectively reduce potential risks.

Frequently Asked Questions

  1. What is the timeline for PCI DSS 4.0 compliance?

    PCI DSS 4.0 was released in March 2022, with full compliance required by April 1, 2024, after a transition period from PCI DSS 3.2.1 until March 31, 2024. Some new requirements become mandatory by March 31, 2025, allowing organizations time for significant changes​.

  2. What are some critical changes introduced in PCI DSS 4.0?

    PCI DSS 4.0 includes customized implementation options, enhanced authentication, expanded system component definitions, and formal role assignments. New requirements cover managing scope, network changes, and third-party roles​.

  3. What should organizations focus on for immediate compliance with PCI DSS 4.0?

    Organizations must conduct thorough PCI scoping, identify cardholder data flows, update data flow diagrams, and document all system components within or connected to the cardholder data environment. Formal role assignments and network infrastructure reviews are essential​.

  4. What are the benefits of upgrading to PCI DSS 4.0?

    Upgrading to PCI DSS 4.0 enhances data security and compliance management and addresses evolving threats. It encourages proactive security control management, ensures robust data protection, and helps maintain customer trust while avoiding penalties​.

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