For any company that stores, processes, or transmits cardholder data, understanding the Payment Card Industry Data Security Standard (PCI DSS) is critical. Adhering to these standards helps protect sensitive information and demonstrates a commitment to security. A key component of this standard is the regular performance of a penetration test on your cardholder data environment (CDE). This goes hand-in-hand with vulnerability scans performed by an Approved Scanning Vendor (ASV).
The latest version, PCI DSS 4.0.1, was released in December 2024, with a transition period until March 2025. Businesses should already be compliant with this new version to ensure they are not caught unprepared.
PCI DSS Compliance extends beyond a single application to include all surrounding and connected networks, from the internal network to the external network, and any components that interact with the CDE.
What is a PCI Penetration Test?
A PCI DSS penetration test is a cybersecurity assessment that examines the technical and operational components of a system to ensure they meet the security standards set by the Payment Card Industry (PCI) Security Standards Council. This type of testing assesses a network's infrastructure and applications, both internal and external, to proactively identify potential vulnerabilities. The penetration testing methodology mimics the steps a malicious attacker or hacker would take to infiltrate a system.
Under PCI DSS 4.0.1, penetration testing requirements are outlined in Requirement 11.3. These updates emphasize risk-based testing approaches, mandate penetration testing after any significant changes—not just annually—and require organizations to validate segmentation controls rather than assume they are effective.
Effective external penetration testing services can also help a business avoid the significant costs and reputation damage associated with a security breach. By proactively identifying and helping to exploit vulnerabilities, companies can act before irreversible damage occurs. A thorough penetration test is also a way to show customers that you take the protection of their data seriously.
Which Organizations are Compliant with PCI, and How Can Penetration Testing Help?
The PCI DSS framework defines the CDE as “the people, processes, and technology that store, process, or transmit cardholder data or sensitive authentication data.” These security assessments should be performed on any application or infrastructure that handles credit or debit card data. This provides a comprehensive review of potential vulnerabilities.
PCI DSS applies to all entities involved in payment card processing—including merchants, processors, acquirers, issuers, and service providers. In short, if your business handles cardholder data, these requirements apply to you.
What are the PCI DSS Requirements?
The PCI DSS framework is an extensive set of guidelines that help businesses maintain safe practices at every step of the payment process. Key requirements often include:
- Implementing strong password policies and regularly updating all passwords within your organization.
- Ensuring adequate cryptographic initialization and service on all ATM machines and other payment devices.
- Scanning of e-commerce environments by using an Approved Scanning Vendor (ASV).
- Effective daily log monitoring.
- Creating instructional materials for the implementation and use of secure payment systems.
- Utilizing network segmentation and firewall controls to isolate the CDE.
PCI DSS 4.0.1 introduced several new and strengthened requirements, including mandatory multi-factor authentication for all access into the CDE, stronger password rules (minimum length and complexity), expanded continuous monitoring and logging expectations, and a “customized approach” option that provides flexibility while ensuring the same security outcomes.
These are just some of the compliance standards. Maintaining PCI compliance is beneficial for companies of all types, as it demonstrates a dedication to upholding the recommended security standards.
By showing that your company engages in regular security assessments and testing, you establish trust with customers, leading to better client relationships and enhanced business outcomes.
Keeping Up with Evolving Standards
The cybersecurity landscape is constantly changing. The PCI DSS framework regularly updates its standards to address new threats and technologies. Keeping up with these updates is a critical component of maintaining an effective security posture.
PCI DSS 4.0 remained active until March 31, 2025, after which PCI DSS 4.0.1 became fully mandatory. Businesses were encouraged not to wait until 2025 to adopt the changes, since certain new requirements had earlier effective dates.
Why PCI DSS 4.0 Matters
PCI DSS 4.0.1 was designed to strengthen payment security in a modern landscape. Its goals include: improving flexibility in how organizations achieve compliance, supporting newer technologies, addressing evolving cyber threats, and enforcing stronger security practices across industries. By aligning with 4.0.1, businesses demonstrate resilience and forward-looking security practices through their improved security posture.
How Cobalt Can Help with Your Penetration Testing Requirements
We provide penetration testing services that follow the requirements set forth by the PCI Security Standards Council. Our services include a comprehensive penetration testing methodology, performed by qualified penetration testers, and provide clear, actionable reporting.
We use a vetted team of highly skilled penetration testers to find the right expertise to match your security needs.
We approach each assessment with the same diligence as if we were securing our own business, placing the utmost importance on accuracy and meticulousness, while also using the best-in-class methodologies to conduct the pentest.
But that’s not all. At Cobalt, we don’t just identify vulnerabilities; we provide clear, actionable plans for remediation and complementary retesting after remediation to help validate fixes discovered during the test..
Upon completing your penetration test, our skilled penetration testers will provide reports via your preferred workflow integrations, such as Jira or Github. This makes vulnerability remediation a streamlined process. You can collaborate directly with the penetration testers on the Cobalt platform to fix any discovered issues. Using a built-in workflow, the penetration testers will also perform retesting to verify your patches at no extra charge.
This process is essential for validating the effectiveness of your remediation efforts and ensuring you meet your PCI DSS retesting requirements. Additionally, retesting is a key step to take after any significant changes to your network, applications, or firewall rules, or any other changes that might impact your segmentation controls.
If you have been looking into PCI DSS compliance and penetration testing requirements, we encourage you to schedule a Penetration Testing as a Service (PTaaS) Platform demo today.
