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PCI DSS testing requirements

PCI DSS v4.0.1 is the card industry security standard for every entity that stores, processes, or transmits cardholder data or can affect its security. PCI DSS testing verifies data retention, PAN masking, secure software, access, and penetration testing requirements. FintechAssuranceLabs produces a requirement-to-test traceability matrix, penetration test reports, and retest evidence for the PCI DSS assessment.

Jurisdiction
Global (validation set by payment brands and acquirers)

Engineering interpretation of testing requirements, not compliance advice.

What PCI DSS v4.0.1 requires from payment software

The PCI Security Standards Council published PCI DSS v4.0.1 in June 2024. The PCI DSS v4.0.1 Requirements and Testing Procedures (PCI SSC document library, checked on 2026-09-16) replaced v4.0, which the Council retired on 31 December 2024. The requirements that v4.0 marked as best practice until 31 March 2025 now apply in every assessment.

The standard applies to merchants, processors, acquirers, issuers, and other service providers that store, process, or transmit cardholder data or sensitive authentication data. The standard also applies to systems that can affect the security of that data. Payment brands and acquirers decide which entities must validate compliance and in which form.

PCI DSS has 12 principal requirements. For a team that builds payment software, most of the test scope sits in five of them:

  • Requirement 3, stored account data. Sensitive authentication data, such as the card verification code, is not stored after authorisation (3.3.1). A displayed PAN shows at most the BIN and the last four digits (3.4.1). A stored PAN is unreadable through a one-way hash, truncation, an index token, or strong cryptography with key management (3.5.1). Tokenisation and encryption both satisfy 3.5.1. The difference is scope: the standard keeps encrypted cardholder data in scope when the same environment or entity has access to the decryption key.
  • Requirement 6, secure software. Bespoke and custom software is reviewed before release (6.2.3). Developers use techniques against injection, attacks on cryptography, and attacks on business logic through APIs (6.2.4). Every script on a payment page is authorised, integrity-checked, and listed in an inventory with a written justification (6.4.3). Live PANs stay out of pre-production environments unless those environments are inside the cardholder data environment (6.5.5). Test data and test accounts are removed before the system goes into production (6.5.6).
  • Requirement 7, access. Access is assigned by job function and least privilege (7.2.2).
  • Requirement 11, security testing. Internal and external vulnerability scans run at least once every three months, and an Approved Scanning Vendor (ASV) runs the external scans (11.3.1, 11.3.2). Internal and external penetration tests run at least once every 12 months and after any significant change (11.4.2, 11.4.3). Exploitable findings are corrected and the test is repeated (11.4.4). Segmentation controls are tested every 12 months, or every six months for service providers (11.4.5, 11.4.6). A change- and tamper-detection mechanism checks payment pages at least weekly or at the frequency of a targeted risk analysis (11.6.1).
  • Requirement 12, scope. The entity confirms its scope at least once every 12 months and after significant change. The scope confirmation identifies data flows for authorisation, capture, settlement, chargebacks, and refunds (12.5.2). Service providers confirm scope every six months (12.5.2.1).

PCI DSS requirements that testing verifies

RequirementWhat we testEvidence produced
3.3.1 Sensitive authentication data is not stored after authorisationDatabases, logs, queues, and retry payloads after a completed test authorisationSearch queries and results per data store, with test transaction IDs
3.4.1 PAN is masked when displayedBack-office screens, support tools, and API responses for each role that views card dataScreen and response captures per role, with the displayed PAN format
3.5.1 Stored PAN is unreadableTables, backups, exports, and log platforms after test transactions with known test PANsClear-text PAN search results per data store
6.2.4 Software is protected against common attacksInjection, broken object authorisation, and business logic abuse on payment and refund APIsPenetration test findings with severity and reproduction steps
6.4.3 Payment page scripts are managedScripts that the payment page loads, compared with the authorised script inventoryScript inventory comparison with the integrity check result
6.5.5 and 6.5.6 Test data stays out of the wrong environmentPre-production data stores for live PANs, and release builds for test accounts and test API keysPre-release check result per release
7.2.2 Access follows least privilegeEach role against the permissions that the role needs, including PAN reveal and refund actionsAccess control and authorisation test matrix
11.4.2 and 11.4.3 Penetration tests run on scheduleApplication and network layers of the defined scope, per the documented methodology of 11.4.1Web, API, and mobile penetration test report
11.4.4 Exploitable findings are corrected and retestedEach exploitable finding after the development team deploys a fixRetest result linked to the original finding
11.4.5 and 11.4.6 Segmentation controls are effectiveNetwork paths from out-of-scope systems into the cardholder data environmentSegmentation test report with test date and scope

Artifacts a PCI DSS assessor requests

For software and testing requirements, a Qualified Security Assessor (QSA) typically requests:

  • scope documentation and data flow diagrams for authorisation, capture, settlement, chargebacks, and refunds (12.5.2);
  • the inventory of bespoke and custom software and third-party components (6.3.2);
  • the payment page script inventory with a written justification for each script (6.4.3);
  • code review records for changes released to production (6.2.3);
  • the penetration testing methodology (11.4.1);
  • internal and external penetration test reports from the last 12 months, and the retest evidence for each exploitable finding (11.4.2 to 11.4.4);
  • segmentation test results (11.4.5, and 11.4.6 for service providers);
  • ASV scan reports from the last 12 months with passing results, as testing procedure 11.3.2.a and 11.3.2.b describe;
  • internal vulnerability scan results and rescans (11.3.1);
  • the role and permission matrix for systems in scope (7.2.2);
  • from each third-party service provider, its compliance status and responsibility split (12.9.2).

A QSA documents the assessment in a Report on Compliance (ROC). An entity that is eligible to self-assess uses a Self-Assessment Questionnaire (SAQ). Both routes end with an Attestation of Compliance (AOC).

Common PCI DSS findings in payment software

  • Card verification code in application logs. Request-body logging on the payment API writes the full card object, including the verification code, to the log platform. The defect breaks 3.3.1.
  • Full PAN in webhook and error payloads. A processor error response echoes the PAN, and the service stores the response in a clear-text event table. The defect breaks 3.5.1.
  • Full PAN visible to every support role. The support tool masks the PAN in the list view and shows it in full on the detail view. The defect breaks 3.4.1 and 7.2.2.
  • Refund on another merchant's payment. The refund endpoint accepts any payment ID and does not check that the payment belongs to the caller. Money leaves through a refund that the payment owner never requested. The defect is a business logic attack that 6.2.4 names.
  • Unlisted script on the checkout page. A tag manager adds a marketing script to the payment page outside the script inventory, and no alert fires. The defect breaks 6.4.3 and 11.6.1.
  • Production snapshot in staging. A team restores a production database with live PANs into staging to reproduce a settlement defect. The defect breaks 6.5.5.
  • Sandbox credentials in production. A release ships with a test merchant account or a test API key enabled. The defect breaks 6.5.6.
  • Penetration test older than the checkout rebuild. The last penetration test predates a new payment flow or processor integration. The gap breaks the "after any significant change" condition of 11.4.2 and 11.4.3.
  • Finding closed without a retest. A ticket for an exploitable finding moves to "done" after the fix, with no repeated test. The gap breaks 11.4.4.
  • Refund and chargeback flows missing from scope. The data flow diagram covers authorisation and capture but omits a third-party dispute tool that receives the PAN. The gap breaks 12.5.2.

How we cover PCI DSS testing

The security testing service runs web, API, and mobile penetration tests against a documented methodology, as 11.4.1 requires, with the PCI SSC Penetration Testing Guidance (information supplement v1.1, September 2017, checked on 2026-09-16) as a reference. The service delivers findings with severity, reproduction steps, and retest results, plus PCI DSS requirement 11 test evidence. Our engineers work as an external third party, which gives the organisational independence of the tester that 11.4.2 and 11.4.3 require. Penetration tests and ASV scans answer different requirements; the comparison of penetration testing and vulnerability scanning explains the split.

The audit evidence testing service builds a requirement-to-test traceability matrix, a test evidence pack per audit scope, a gap report before the assessment, and retest evidence after remediation. The QSA completes the ROC; the evidence pack gives the QSA test results mapped to each requirement. The PCI DSS assessment preparation scenario sets out the sequence and timeline before an assessment date.

The payment flow testing service delivers a payment flow map with every state, transition, and failure path, which is input for the data flow identification in 12.5.2. Our test cases use published sandbox test card numbers, so PAN searches under 3.4.1 and 3.5.1 look for known values.

We test PCI DSS requirements for payment acquiring, POS, card issuing, neobank, and spend management products.

FintechAssuranceLabs has PCI DSS service provider level 2 status, verified via A2SECURE and valid until 2030. On request, we state which requirements we manage and which requirements you manage, as 12.9.2 requires.

Questions

Who does PCI DSS apply to?

PCI DSS v4.0.1 applies to every entity that stores, processes, or transmits cardholder data or sensitive authentication data. The list includes merchants, processors, acquirers, issuers, and other service providers. PCI DSS also applies to entities whose systems can affect the security of that data, such as an e-commerce server that redirects customers to a payment page.

Is PCI compliance required by law?

PCI DSS is an industry standard from the PCI Security Standards Council and is not itself a law. Payment brands and acquirers decide which entities must comply with PCI DSS and validate compliance, and they enforce PCI DSS through merchant and service provider agreements. PCI DSS v4.0.1 states that a country, state, or local law applies where it conflicts with a PCI DSS requirement.

What are the 12 requirements of PCI DSS compliance?

The 12 principal PCI DSS requirements are: network security controls; secure configurations; protection of stored account data; strong cryptography in transmission; protection from malicious software; secure systems and software; access by business need to know; user identification and authentication; physical access restriction; logging and monitoring; regular security testing; and information security policies and programs.

How to prepare for a PCI DSS audit?

Preparation for a PCI DSS assessment starts with a scope confirmation that maps every card data flow, as PCI DSS requirement 12.5.2 describes. The requirements in scope are then tested against the PCI DSS v4.0.1 testing procedures. Gaps found by those tests are fixed and retested. Penetration test reports, ASV scan reports, and retest evidence are collected before the assessment starts.

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