Regulatory compliance is a permanent headache for fintech firms, but the arrival of PCI DSS 4.0 just upped its intensity. The Payment Card Industry Data Security Standard, to give the framework its full name, announced a new iteration in 2022, along with a number of new requirements that spell significant changes for security and compliance teams.
PCI DSS 4.0 has a staggered impact on how fintechs handle credit card data and transactions. Many firms began preparing right away, but with a few weeks to go until much of it goes into full effect, the biggest mobilizations are likely taking place right now.
There are 13 new rules that called for immediate compliance last year, but the majority of the changes come into effect on March 31, 2024, when the 3.2.1 version is officially retired. Full compliance with all 64 new requirements and best practices is mandatory for all finance organizations as of April 1, 2025.
The new version is more than just an update on the existing standards. It represents a significant shift in attitudes towards security, emphasizing continuous security posture monitoring and drawing a strong connection between cybersecurity, privacy and fraud management.
Version 4.0 gives organizations new freedom to choose how to meet compliance standards, but also new responsibility to prove the effectiveness of its choices. If you’re feeling uncertain about where to start, or not clear about how to successfully comply, we’ve gathered some advice to help your organization become PCI DSS 4.0 compliant.
Evaluate your current environment
The first step in making any security-related changes is always to conduct thorough gap analysis. Make sure that you completely understand the new requirements of v4.0 so that you can effectively spot the areas where your security approaches fall short, and then scan for vulnerabilities.
You’ll need to keep a particularly careful eye out for issues that are mandated in PCI DSS 4.0 for the first time, like increased data protection and defenses against client-side attacks.
Decide when to use customized approach
One of the big changes in PCI DSS 4.0 is that organizations can choose between defined validation or customized validation. This gives you more flexibility to select the approach that’s a better fit for your security environment, instead of forcing you to squeeze your security methods into the defined framework.
However, if you use customized validation, you’ll need to be able to prove that your security controls meet v4.0’s levels of risk analysis and documentation requirements. It’s important to invest the time and effort to verify which approach is best for your organization’s risk posture and security procedures.
Implement defenses against client-side attacks
Another significant change in v4.0 is the new emphasis on preventing client-side attacks. Two of the new requirements directly address client-side attack risks, including managing payment pages against XSS and other script attacks, and protecting against unauthorized modifications.
Most fintech businesses concentrate more on server-side threats like ransomware and APTs, which are also the focus of most web-app firewalls. You may need to update or replace your tools with ones that address supply chain attacks, sideloading and chainloading attacks, skimming, and other front-end issues.
Upgrade data protection
PCI DSS 4.0 also elevates the level of client data protections that finance firms need to implement. It’s no longer enough just to use disk-level encryption; v4.0 requires more robust encryption, including keyed-cryptographic hashes. As part of these protections, you’ll need to maintain and regularly review inventories of cipher suites, protocols, trusted keys and certificates.
The new standard specifically obligates companies to confirm the current validity of certificates protecting private account numbers (PAN) during transmissions. Carrying out a full assessment of your cardholder data environment (CDE), including devices, applications, and storage, is also the best way to spot areas that need improvement.
Define roles and responsibilities
Defining the roles of everyone interacting with cardholder data, payments, or account data is already recommended to maintain data security, but now it’s also part of the requirements of v4.0. The new PCI DSS standard mandates that anyone who works with sensitive data is assigned clear roles and responsibilities.
By clarifying and confirming responsibilities, you’ll help enable rapid incident response and mitigation and minimize confusion. Defined roles also encourage accountability among your workforce, assist with risk management, and make it easier to complete audits and demonstrate compliance with regulatory standards.
Set up continuous monitoring
Meeting v.4.0’s requirements was never going to be a once-and-done experience. The new standard emphatically shifts focus from periodic and intermittent compliance checks to continuous security assessments and controls. If you don’t already have processes and tools that enable continuous security monitoring, now is the time to implement them.
As well as adopting the right tools, it’s important to carry out thorough employee training. You need every employee to fully understand the importance of PCI DSS 4.0, their role in upholding compliance, and what is required to keep payment data secure.
PCI DSS doesn’t need to be a threat
Complying with a new set of regulations is always stressful, but PCI DSS 4.0 also offers opportunities. It’s a chance to make sure that your security controls are well embedded into your daily operations, harden your security posture, and ultimately give yourself and your customers more peace of mind.
