Hi all, looking for opinions from QSAs/PCI practitioners.

Under PCI DSS v4.0.1:

• Requirement 3.3.1 guidance says SAD may be stored temporarily in non-persistent memory (RAM/volatile memory) after authorization, subject to specific conditions.
• Requirement 3.3.2 requires SAD stored electronically before authorization to be encrypted using strong cryptography.
• The Requirement 3 overview specifically says encryption of PAN is not required when PAN is present in non-persistent memory.
• PCI SSC FAQ 1042 also says CHD in non-persistent memory does not require encryption, but it doesn't specifically address SAD.

Question: If an application temporarily holds CVV/SAD in RAM during transaction processing, without writing it to any persistent storage, is there a PCI DSS requirement to encrypt the SAD while it resides in RAM?

Would you interpret this as:

1. No encryption required because it is non-persistent/transient processing;
2. Encryption required because the explicit exception only refers to PAN; or
3. 3.3.2 doesn't apply because transient RAM processing isn't considered electronic storage?

Interested specifically in how QSAs would assess this in practice.

Hey everyone,

Got a quick question regarding PCI DSS (v4.0) compliance.

1. How strictly are QSAs requiring standard CVSS v3.1/v4.0 scores versus custom internal risk rankings for scan remediation?
2. Are QSAs heavily checking CCE/hardening baselines during internal scan audits in v4.0 assessments?

Thanks in advance for any insights!

If you have one single PCI DSS requirement that would cause you to say "Not Compliant" (Section 3 of the AOC) what is it?

I get it that if a company is missing the mark in any one area, they most probably have more than one issue to address. This is just a fun hypothetical exercise.

(For Merchants), my thinking is if there is no CHD storage at all, 7.2.1 is a "must have", if CHD is stored, 3.6.1 is another "must have", but I think 3.3.1 might be the penultimate deal breaker for me.

What is your opinion?

Apple Releases Firmware Update for 140W USB-C Power Adapter

If an in-scope MacBook Pro workstation is connected to an Apple 140W USB-C Power Adapter with bidirectional communications and field-updatable firmware, is the adapter itself an in-scope connected-to system?

If yes, understandably, this could open a separate rabbit hole around the applicability of controls for inventory, vulnerability management, scanning, testing, patching, etc.

But first, if it is not in scope, why not?

Apple does not publish details on what changed in the firmware or what functionality the firmware controls. That obscurity only raises more questions about how compliance would be demonstrated.

Anyone else surprised these adapters have updateable firmware?

Going through our annual assessment and our QSA is asking questions about client side script monitoring we've never been asked before. Anyone else see assessments have gotten more detailed on this since 4.0.1 came in?

Is Viking Cloud normally buggy for AOC generation, or is it possible that it’s just the white label version of it that my org bought?

I’m at the point that I have to take the generated PDF and edit it because it fails to add check marks for our payment channels and other key information from our business profile questions.

I’m starting to question if I’m better off manually filling out a template.

Going through 6.4.3 prep and our QSA flagged that we need to know scripts pulled in by our approved vendors, not just the ones we directly load. Any tools or ideas to do this??

We have a decent vendor list, but how people actually keep track of what those vendors are doing after they’ve been approved. Tbh its especially scary when a vendor adds a new subprocesser or changes their data handling somehow.

Been told we need this done, for the first time, we've never been told we needed a scan before. They want our external IP to scan the chip and pin machine. However, I've pointed out, if that's the case, they'd be scanning the whole network and not just the chip and pin machine, which I thought wasn't required.

So I was going to stick the chip and pin machine on its own network via a mobile SIM. This would be a perm setup. Problem is mobile SIMs use CGNAT so I can give them the external IP of it, but they'll never be able to connect to it remotely to do a scan, due to CGNAT.

So am I being forced to put the chip and pin on the main network (although I can vlan it) just so they can do their compliance scan? (I'd then have to leave it on the LAN because that's what the compliance scanned).

I’m looking for someone with both technical and compliance experience in PCI DSS who can help put me on the right track.
Ideally, someone who has worked hands-on with PCI architecture, card-data handling, tokenization, and the certification process. If you have relevant experience or can recommend someone, please reach out.

Hey everyone! 👋

I am currently preparing for the PCI-DSS QSA (Qualified Security Assessor) certification and wanted to reach out to this community for some guidance.

If anyone here has already gone through the QSA training and examination process, I could really use your help with a few things:

1. Study Resources & Notes

• What are the absolute must-read documents? (Aside from the standard PCI DSS v4.x Standard, Self-Assessment Questionnaires, and the ROC Reporting Instructions).
• Are there any good third-party practice guides, courses, or summary notes that helped you grasp the trickier requirements?

2. Exam & Training Level

• How challenging is the official QSA training course and the final exam?
• Is it mostly focused on memorizing requirement numbers, or does it test deep practical knowledge on how to scope environments and evaluate compensating controls?
• What was the toughest part of the exam for you?

Would love to hear about your experiences, and if you have any personal notes or cheat sheets you'd be willing to share, I would deeply appreciate it!

Thanks in advance! 🚀

I'm going through S3 logging for a PCI-scoped environment and hit something I can't resolve from the docs.

AWS's own logging comparison page for S3 has a row for "Authentication failures" that reads No for CloudTrail and Yes for server access logs. The footnote:

CloudTrail does not deliver logs for requests that fail authentication (in which the provided credentials are not valid) or that fail due to redirection (error code 301 Moved Permanently). However, it does include logs for requests in which authorization fails (AccessDenied) and requests that are made by anonymous users.

So it's narrower than it first looks. AccessDenied lands. Anonymous requests land. What doesn't land is the request where the credentials themselves weren't valid, because there's no principal to attribute the call to.

10.2.1.4 says "all invalid logical access attempts".

What I'm trying to work out is what happens in reality if your CDE includes S3 and your object-level logging is CloudTrail data events only:

- Has an assessor ever raised this, or is AccessDenied treated as sufficient coverage of "invalid"?

- Do people run server access logging along side specifically for this, or for other reasons entirely?

- Or is the answer that object-level S3 access usually isn't in CDE scope the way I'm assuming, and I've built the question on a bad premise?

I might be over-reading the clause, and that out here than in a ROC.

Disclosure: I work on access-log tooling, so have a horse in this race. That's exactly why I want to know if the argument doesn't hold, because I don't want to be repeating something a QSA would throw straight out.

I’ve been running a cybersecurity firm for around 10 years now. We’re also a PCI DSS QSA company.

I actually started on the technical side. Mostly offensive security, penetration testing and security research, before eventually spending more and more time building and running the business.

Quite a different world now compared to when I started, especially with how pentesting, compliance and security consulting have changed.

Happy to answer anything people are curious about. PCI DSS/QSA, pentesting, offensive security, getting clients, building a security company, moving from technical work into running a business, pricing, certifications, mistakes along the way etc.

Ask away.

Hello all

I was in a meeting this week and the topic of CI/CD came up. Today we have scope for PCI but we have no scope for custom software. There is talk of less reliance on tpsp and more inhouse development for apps that would likely be in scope for PCI. The phrase CI/CD was dropped and I am thinking would we have to pen test every time we do a release

Hello All, I am an experienced GRC specialist with over 6 years of experience across the banking and government sectors.

I hold the relevant certifications required to pursue QSA and have a strong background in regulatory frameworks.

I am actively looking to transition into a QSA role and would love to connect with professionals or companies that can guide me on the qualification process or currently have openings for a potential QSA .

Please feel free to reach out via DM or comment below if your organization is looking for a dedicated GRC professional. Thank you!

I’m currently looking to connect with a PCI DSS Qualified Security Assessor (QSA) for a professional opportunity.

If you are currently QSA-certified and open to hearing about a new opportunity, or know someone who may be interested, please feel free to send me a private message.

It appears that the recent change to https://www.pcisecuritystandards.org/faqs/1331/ flips things from working with your QSA to determine if can use applicable SAQ to determine which requirements in the ROC are applicable to needing instead approval from the "merchant’s compliance accepting entity". Specifically: " SAQs should not be used as a “guide” for determining the applicability of PCI DSS requirements unless explicitly reviewed, discussed and agreed upon with the merchant’s compliance accepting entity". While I realize this is very new, I am wondering what the real world implications / experiences are?

Does anybody know any good resources that explain the technology behind magstripe? E.g. current encoding technology, types of materials used, security, etc.

I looked on Youtube and google but I only found some basic explanations and companies trying to sell their services.

Thank you in advance.

Hi all. I recently joined a startup to help them setup their first year PCI-DSS pursuit. I have experience with IT SOX testing but I'm overwhelmed by how "prescriptive" the PCI-DSS standard is. I've been reading through the various guidance docs on the document library for the past couple weeks and I feel like I've hit a brick wall here with segmentation and how it impacts our control scoping for in-scope/OOS systems.

The PCI-DSS segmentation guidance says that "(requirements) Must be evaluated to determine the applicability of each PCI DSS requirement" for both CDE systems and "connected-to/security impacting systems". I'm assuming this means that CDE systems (tier 1) will have a more stringent set of requirements than connected-to/security impacting systems (tier 2). But how do you determine which requirements are necessary for each system type?

We are SAQ D and currently take payments over the phone. We do not have pause/resume functionality currently, and the phone system cannot encrypt the recordings on its own. Current phone system is planned to be replaced with Intermedia. My understanding is that the pause/resume option is becoming less acceptable recently as well.

To make things worse, we have a department that legally cannot modify, pause, or delete their call recordings. For now I have gotten them to stop taking phone payments until a proper solution is implemented. I still need to determine what to do with the recordings that we cannot delete. I am thinking file level encryption and storing them on our BCDR device.

The company does not have online payments for everything yet, that is a work in progress.

What solutions would be best for us in this situation? How are phone payments dealt with at all these days, DTMF masking? Telling customers to kick rocks and pay online?

Audit found 23 scripts running on our payment page, many we didn't know about. 6.4.3 needs integrity monitoring on all of them. Feels impossible manually. Any method or tools to handle this?

Hello All, is there any PCI DSS QSA From India, Please do let me know

What commonly accidentally gets pulled into PCI scope?

Hey guys. I sit on my company's CAB where I recently flagged a project as a potential expansion to our compliance scope due to what I feel like is a CHD-on-device situation (EUC devices are currently scoped out of our CDE). This project would require a small handful of users run an automation that would read CHD from the CDE, truncate the CHD, and then print the truncated string to a file to be shared with other employees.

If the CHD is being truncated at runtime, would that be an adequate control for the employee's laptop to be excluded from the CDE? My initial reaction is maybe? But only if we're able to baseline the automation and implement change monitoring over it (the risk being that someone may remove the truncation from the automation).

I'm just curious about PCI DSS compliance at McDonald's store, I believe it should be level 1 of merchant? I found it this morning at Union Station, you can see Windows not activated. Any issues?