The 12 Requirements of the PCI-DSS Standard (Official PCI Security Standards Council) form the backbone of every cardholder data security program—miss one and your 2025 audit is at risk.
Imagine this: you have 64 brand-new PCI-DSS controls to satisfy, an assessor arriving next quarter, and a board that wants proof you’re already compliant. PCI-DSS 4.0.1 doesn’t pile on extra rules, but it does sharpen the wording so every merchant, service provider, and QSA reads the same playbook. The guide below turns that detailed PCI-DSS 4.0.1 requirements list into a set of practical, at-a-glance tasks you can start today. Ready? Let’s dive in.
Every checklist item below maps to an official PCI-DSS 4.0.1 control and doubles as audit evidence.
Build & Secure the Technical Foundation (Requirements 1-4)
Requirement 1 – Install and Maintain a Secure Network
• Diagram every data flow—including containers and serverless calls—and place the file in version control.
• Enforce “deny by default” in firewalls, security groups, and Kubernetes policies, reviewing rules at least every six months.
• Segregate the cardholder-data environment (CDE) with dedicated VLANs or cloud accounts, then pen-test pivot paths annually.
• Monitor drift with Terraform plan diffs, AWS Config, or Azure Policy, and record business justifications for every open port.
Requirement 2 – Apply Secure Configurations
• Build VMs, containers, and functions from CIS-benchmarked images.
• Store Ansible, Terraform, or CloudFormation files in Git with pull-request review and control IDs in commit messages.
• Scan artefacts for default passwords (admin:admin) before they ever reach prod, and re-validate baselines at least twice a year.
Requirement 3 – Protect Stored Cardholder Data
• Render PAN unreadable via AES-GCM encryption, truncation, or tokenisation.
• Guard cryptographic keys inside an HSM or cloud KMS, rotate them every 12 months, and apply dual control for activation.
• Encrypt backups with a separate key and destroy retired media with a documented wipe certificate.
Requirement 4 – Protect Data in Transit
• Disable SSLv3, TLS 1.0, and TLS 1.1 everywhere—internal micro-services included.
• Prefer TLS 1.3 with AES-256-GCM; enforce mutual TLS inside service meshes that carry PAN.
• Automate certificate issuance (ACME), rotate keys every 398 days, and pin certs in mobile apps to defeat MITM attacks.
Hunt, Patch, and Prevent Malware (Requirements 5-6)
Requirement 5 – Defend All Systems from Malware
• Deploy EDR on laptops and servers, runtime scanners on containers, and pre-upload scans for Lambda or Azure Functions.
• Block users from disabling agents, update signatures daily, and quarantine infected hosts or pods within five minutes.
• Funnel every detection into your SIEM and review the alerts weekly.
Requirement 6 – Develop and Maintain Secure Systems
• Start the 30-day patch clock when the vendor releases a critical fix, not when headlines appear.
• Pipe threat intel into your ticket system, auto-label CVSS ≥ 9.0 items as “critical,” and track “published” versus “applied” dates.
• Bake SAST, SCA, and dependency-pinning into CI/CD; log SHA-256 hashes of release artefacts and keep rollback plans handy.
Limit and Authenticate Every User (Requirements 7-8)
Requirement 7 – Restrict Access
• Map every job function (employees, vendors, CI/CD) to least-privilege roles, and review entitlements quarterly.
• Rotate vendor credentials every 90 days and issue just-in-time (JIT) admin tokens through a PAM solution.
• Export an access-matrix spreadsheet straight from your IAM tool before audit day—assessors love it.
Requirement 8 – Identify and Authenticate Users
• Assign unique IDs to every person and service; disable dormant accounts after 90 days.
• Enforce MFA for all admin and remote access, replacing SMS codes with phishing-resistant FIDO2 or smart cards.
• Keep password length at 12+ characters (15 for service accounts) and lock out after 10 failed attempts.
• Log every authentication event to the SIEM and alert on MFA bypass attempts.
Lock Down Real-World and Log Worlds (Requirements 9-10)
Requirement 9 – Secure Physical Access
• Define CDE rooms on a floor plan, protect them with badge + PIN or biometrics, and log visitors for three months.
• Inspect POS devices daily for skimmers; use tamper-evident seals and store serial numbers in the asset register.
• Encrypt CCTV footage, rotate encryption keys quarterly, and close camera blind spots near loading bays.
Requirement 10 – Log and Monitor
• Forward logs from firewalls, containers, cloud APIs, and SaaS apps to a SIEM within one minute.
• Keep 12 months of logs—three months instantly searchable—and store archives in WORM buckets.
• Hash records at ingestion, alert on integrity failures, and review critical events daily.
• Build rules for AV stops, firewall changes outside approved windows, and new privileged accounts created off-cycle.
Test, Govern, and Stay Ahead (Requirements 11-12)
Requirement 11 – Test Security Regularly
• Run ASV external scans monthly, internal scans after every production push, and full penetration tests annually (both authenticated and unauthenticated).
• Prove segmentation with semi-annual pivot tests, and hook file-integrity monitoring (FIM) alerts into the SIEM for continuous assurance.
• Track findings in your defect system and retest critical issues within 30 days.
Requirement 12 – Governance and Risk Program
• Map each PCI-DSS 4.0.1 requirement to a named control owner and review that matrix every quarter.
• Perform an annual FAIR or NIST-based risk assessment, store policies in Git with electronic sign-off, and automate BAU evidence pulls into a GRC dashboard.
• Require supplier Attestations of Compliance (AOC) with a 30-day right-to-audit clause, and test the incident-response plan twice a year—one tabletop, one live drill.
A 5-Step Sprint to Pass Your 2025 PCI Audit
- Inventory and classify assets. Tag every system that stores, processes, or transmits PAN so that tooling can scope scans automatically.
- Close the 30-day patch and MFA gaps first. They carry the heaviest penalties and derail audits fastest.
- Track progress in a living worksheet. Map each PCI-DSS 4.0.1 control to evidence, owner, due date, and status.
- Run quarterly BAU mini-audits. Collect firewall reviews, log-integrity tests, and vendor access confirmations as you go—no year-end scramble.
- Align wording with 4.0.1 now, even if you’re still being assessed against 4.0. Your QSA will expect the latest terminology.
Quick snapshot—copy this into your tracker:
- Gap assessment complete and signed off
- All critical patches ≤ 30 days old
- MFA is enforced for every administrative and user login
- Evidence attached for each of the 12 PCI-DSS 4.0.1 requirements
- Policies updated to 4.0.1 wording
- Quarterly BAU reviews scheduled and owners assigned
Bottom line: Master these PCI-DSS 4.0.1 security requirements now, and your 2025 compliance exercise shifts from a frantic fire drill to a predictable routine. Now go make it happen.