Thought Leadership
Jan 17, 2025

PCI DSS 4.0: The Ultimate Guide to the 12 Requirements

Your Complete Guide to PCI DSS 4.0: Key Requirements, EOL Software Risks, and How to Stay Secure

PCI DSS 4.0: The Ultimate Guide to the 12 Requirements

Table of Contents

  1. Introduction
  2. Why PCI DSS 4.0 Matters
  3. Who Needs PCI DSS Compliance?
  4. The 12 Requirements, Explainedsome text
    • Requirement 1: Install and Maintain Network Security Controls
    • Requirement 2: Apply Secure Configurations to All System Components
    • Requirement 3: Protect Stored Account Data
    • Requirement 4: Protect Cardholder Data with Strong Cryptography During Transmission
    • Requirement 5: Protect All Systems and Networks from Malicious Software
    • Requirement 6: Develop and Maintain Secure Systems and Software
    • Requirement 7: Restrict Access by Business Need to Know
    • Requirement 8: Identify and Authenticate Access to System Components
    • Requirement 9: Restrict Physical Access to Cardholder Data
    • Requirement 10: Log and Monitor All Access to System Components and Cardholder Data
    • Requirement 11: Test Security of Systems and Networks Regularly
    • Requirement 12: Support Information Security with Organizational Policies and Programs
  5. PCI DSS 4.0 Checklist
  6. EOL Software and Why It’s Critical to Stay Updated
  7. How HeroDevs Helps with PCI Compliance
  8. Key Takeaways and Next Steps
  9. Frequently Asked Questions (FAQs)

1. Introduction

PCI DSS (Payment Card Industry Data Security Standard) compliance is not optional if your business processes, stores, or transmits payment card data. The latest version—PCI DSS 4.0—was introduced to keep pace with the rapid evolution of e-commerce, mobile payments, and sophisticated cyberattacks.

In this comprehensive guide, we’ll walk you through:

  • Why PCI DSS 4.0 matters
  • Who needs to comply
  • The 12 core requirements
  • A handy checklist to jump-start your compliance
  • How outdated (EOL) software can derail compliance
  • A quick look at how HeroDevs can help

By the end, you’ll have a clearer understanding of how to protect cardholder data, reduce the risk of breaches, and maintain a robust security posture in line with industry standards.

Note on Bias

All best practices and tips provided here are based on widely recognized industry standards such as the PCI Security Standards Council recommendations, CIS Benchmarks, OWASP guidelines, and general security frameworks like NIST. We do not promote or favor any specific vendor solution or platform. The references to popular tools (e.g., AWS Security Groups, Chef, Puppet) are purely illustrative examples of how you could automate or monitor security configurations.

2. Why PCI DSS 4.0 Matters

PCI DSS was first established in 2006 to unify data security practices across all major card brands. Version 4.0 incorporates new security controls and addresses evolving threats, ensuring that businesses are more proactive in:

  • Preventing data breaches
  • Protecting consumer trust
  • Maintaining continuous security (rather than a one-time compliance exercise)

Key Goals of PCI DSS 4.0

  1. Modernize Security Controls
    • Transition from traditional firewalls to broader “network security controls,” incorporate multi-factor authentication (MFA) best practices, and encourage stronger password rules.
  2. Enable Continuous Compliance
    • Require ongoing monitoring, more frequent testing, and robust documentation to ensure compliance is consistently upheld.
  3. Offer Flexible Approaches
    • Introduce new “Customized Approaches” to meet requirements, allowing innovative security solutions beyond a “one-size-fits-all” model.

3. Who Needs PCI DSS Compliance?

Any organization—large or small—that handles payment card data must comply with PCI DSS. This includes:

  • E-commerce sites
  • Brick-and-mortar retailers
  • Payment processors
  • SaaS platforms with embedded payment features
  • Third-party service providers (e.g., hosting companies, cloud service providers)

Compliance Levels

The compliance "level" depends on annual transaction volume. Large enterprises handling millions of transactions (Level 1) require an assessment by a Qualified Security Assessor (QSA), while smaller merchants (Levels 2–4) may self-assess but must still meet all 12 PCI DSS requirements.

4. The 12 Requirements, Explained

PCI DSS 4.0 is organized around six overarching goals and 12 requirements. Let’s break them down one by one.

Requirement 1: Install and Maintain Network Security Controls

Why It Matters: Attackers often exploit network misconfigurations for unauthorized access. PCI DSS 4.0 expands beyond physical firewalls to cloud-based “network security controls.”

Key Actions

  1. Document Network Topology
  2. Harden Firewall/Router Rules
  3. Implement Segmentation (CDE from other areas)

Pro Tip: Use AWS Security Groups, Azure NSGs, or GCP firewall rules for cloud security. Document each change for audit traceability.

Requirement 2: Apply Secure Configurations to All System Components

Why It Matters: Default credentials and out-of-the-box settings are easy hacker targets.

Key Actions

  1. Remove Default Credentials
  2. Follow Hardening Guides (e.g., CIS Benchmarks)
  3. Maintain a Config Management Process

Pro Tip: Automate config checks with tools like Chef, Puppet, or Ansible to ensure consistent, secure baseline settings.

Requirement 3: Protect Stored Account Data

Why It Matters: Storing unencrypted payment data is a huge liability. Encryption and tokenization reduce scope and exposure.

Key Actions

  1. Encrypt PAN Using Strong Algorithms (e.g., AES-256)
  2. Tokenization
  3. Restrict Data Retention

Pro Tip: Maintain explicit policies for encryption key generation, rotation, and retirement to avoid unauthorized decryption.

Requirement 4: Protect Cardholder Data with Strong Cryptography During Transmission

Why It Matters: Data in transit can be intercepted (Man-in-the-Middle attacks). Secure your connections.

Key Actions

  1. Use TLS 1.2 or Higher
  2. Certificate Management (Avoid expired or self-signed certs)
  3. Secure Remote Admin Access (VPNs, SSH keys, etc.)

Pro Tip: Regularly scan for insecure ports or deprecated ciphers using tools like Qualys SSL Labs.

Requirement 5: Protect All Systems and Networks from Malicious Software

Why It Matters: Malware can steal data or cripple systems. PCI DSS emphasizes continuous anti-malware coverage.

Key Actions

  1. Deploy Anti-Malware/EDR Solutions
  2. Regular System Scans
  3. Restrict Administrative Privileges

Pro Tip: Consider application whitelisting on critical servers to prevent unauthorized executables.

Requirement 6: Develop and Maintain Secure Systems and Software

Why It Matters: Vulnerabilities in custom or third-party software are top breach vectors.

Key Actions

  1. Patch Management
  2. Secure SDLC (Threat modeling, code reviews, etc.)
  3. Software Inventory

Pro Tip: Adopt a DevSecOps approach, integrating security scanning early in the software development lifecycle.

Requirement 7: Restrict Access by Business Need to Know

Why It Matters: Excessive privileges make it easy for attackers (or insiders) to pivot and escalate.

Key Actions

  1. Role-Based Access Control (RBAC)
  2. Periodic Access Reviews
  3. Document Access Policies

Pro Tip: Always default to least privilege when creating new user accounts.

Requirement 8: Identify and Authenticate Access to System Components

Why It Matters: Weak or shared passwords open the door to unauthorized access. MFA is increasingly mandatory.

Key Actions

  1. Enforce MFA
  2. Strong Password Policies (12+ characters by 2025)
  3. Lockout & Monitoring (Limit failed login attempts)

Pro Tip: Train employees to avoid credential reuse or easily guessed passwords.

Requirement 9: Restrict Physical Access to Cardholder Data

Why It Matters: Physical theft can be as damaging as a cyberattack if servers or POS devices are stolen or tampered with.

Key Actions

  1. Secure Facilities (Locks, alarms, visitor logs)
  2. Protect POS Devices (Inspect for skimmers)
  3. Media Controls (Store/destroy backups securely)

Pro Tip: Keep surveillance footage for at least 90 days; ensure coverage of all sensitive areas.

Requirement 10: Log and Monitor All Access to System Components and Cardholder Data

Why It Matters: Logs are critical to detecting breaches and investigating suspicious activity.

Key Actions

  1. Centralized Logging (SIEM)
  2. Daily Log Reviews
  3. Log Retention (At least one year, with quick access to the last 90 days)

Pro Tip: Configure alerts for critical events (e.g., admin login failures, system file changes).

Requirement 11: Test Security of Systems and Networks Regularly

Why It Matters: Cyberthreats evolve constantly; regular vulnerability scans and pentests ensure your defenses stay current.

Key Actions

  1. Quarterly Vulnerability Scans (Internal & External)
  2. Annual Penetration Tests
  3. Intrusion Detection/Prevention

Pro Tip: Adopt continuous testing beyond mandatory intervals; small, frequent scans catch vulnerabilities early.

Requirement 12: Support Information Security with Organizational Policies and Programs

Why It Matters: Policies formalize your security approach and ensure consistent adoption across teams.

Key Actions

  1. Document All Security Policies
  2. Security Awareness Training
  3. Vendor Management (Verify third-party PCI compliance)
  4. Incident Response Plan (Who does what in a breach?)

Pro Tip: Conduct tabletop exercises simulating data breaches to refine incident response readiness.

5. PCI DSS 4.0 Checklist

Below is a condensed checklist to help you track your PCI DSS progress. Adapt it to your specific environment for the best results.

  1. Scoping & Documentation
    • Identify cardholder data flows (network diagrams)
    • Segment the Cardholder Data Environment (CDE)
    • Document roles and responsibilities
  2. Network Security & Configuration (Req. 1 & 2)
    • Harden firewall rules and remove default creds
    • Follow OS hardening guides (e.g., CIS)
    • Maintain change control documentation
  3. Protecting Data (Req. 3 & 4)
    • Encrypt stored cardholder data (e.g., AES-256)
    • Enforce TLS 1.2+ for data in transit
    • Use tokenization to reduce scope
  4. Malware & Patching (Req. 5 & 6)
    • Deploy anti-malware or EDR
    • Schedule and track software patching
    • Follow secure SDLC practices
  5. Access Controls (Req. 7 & 8)
    • Implement role-based access, enforce MFA
    • Adopt strong password policies
    • Conduct periodic account reviews
  6. Physical Security (Req. 9)
    • Restrict physical access (badges, locks)
    • Inspect POS devices for tampering
    • Secure or destroy all media with cardholder data
  7. Monitoring & Testing (Req. 10 & 11)
    • Centralize logging, review daily
    • Perform quarterly vulnerability scans
    • Conduct annual penetration tests
  8. Policies & Continuous Compliance (Req. 12)
    • Maintain updated security policies
    • Provide regular security awareness training
    • Have an incident response plan for breaches

6. EOL Software and Why It’s Critical to Stay Updated

End-of-life (EOL) software—whether it’s an unsupported operating system, database, or application—poses a huge risk to PCI DSS compliance. Once a product hits EOL:

  • No more security patches: Vulnerabilities remain unpatched, leaving a door open for attackers.
  • Increased compliance gap: PCI DSS calls for keeping systems up to date. Using EOL software can fail requirement 6 (secure systems) and 5 (malware protection).
  • Greater liability: In a breach scenario, using EOL software can be seen as negligence, leading to steeper fines or penalties.

Tip: Keep an accurate inventory of all software and their support end dates. Develop a migration or update roadmap to ensure systems remain within vendor support lifecycles.

7. How HeroDevs Helps with PCI Compliance

HeroDevs specializes in helping companies modernize and upgrade legacy applications—often moving them away from EOL platforms that jeopardize PCI compliance. Our services include:

  1. Legacy System Assessment
    • Identify high-risk EOL software and create a migration roadmap.
  2. Code Modernization & Upgrades
    • Migrate outdated frameworks or libraries to actively supported, secure versions.
  3. PCI-Aware Development Practices
    • Incorporate secure coding, threat modeling, and vulnerability testing directly into your development process.

By partnering with HeroDevs, businesses can streamline their path to PCI DSS 4.0 compliance while reducing the risks associated with outdated technologies.

8. Key Takeaways and Next Steps

  • Scope Minimization: Offload what you can to PCI-compliant third-party providers and tokenize card data to reduce risk.
  • Continuous Security: PCI DSS 4.0 emphasizes ongoing monitoring, not a “once-and-done” approach.
  • Keep Software Current: Retiring EOL software is critical for maintaining a compliant, secure environment.
  • Seek Expert Guidance: Whether from a QSA or a specialized partner like HeroDevs, expert input can save time, money, and reduce compliance headaches.

9. Frequently Asked Questions (FAQs)

Q1. Do small businesses really need PCI DSS 4.0 compliance?

Yes. Even if you process fewer transactions, PCI DSS still applies. Smaller merchants may self-assess, but the 12 requirements remain mandatory.

Q2. What are the consequences of non-compliance?

Non-compliance can lead to fines, increased audit requirements, and potential loss of merchant accounts. Reputational damage from a breach can be even more severe.

Q3. Does tokenization remove all PCI compliance obligations?

Tokenization significantly reduces your PCI scope, but it does not eliminate obligations entirely. You still must secure your environment, complete SAQs or audits, and maintain proper policies.

Q4. Why is EOL software such a problem for PCI?

EOL software no longer receives security updates. This directly conflicts with PCI’s emphasis on secure systems and can lead to immediate compliance gaps.

Q5. How can HeroDevs help my business maintain PCI DSS compliance?

HeroDevs can assess legacy systems, retire EOL software, and incorporate secure development practices—ensuring your business continuously aligns with PCI DSS requirements.

Conclusion

Achieving and maintaining PCI DSS 4.0 compliance is a journey—not a destination. Use this guide and the PCI DSS 4.0 Checklist above to systematically tackle each of the 12 requirements. By proactively retiring EOL software and integrating secure coding practices, you can build a sustainable compliance program that protects cardholder data and nurtures long-term customer trust.

If you need assistance in modernizing your systems, HeroDevs is here to help. Contact us today to learn how we can streamline your compliance process, remove high-risk EOL software, and keep your business secure in an ever-evolving threat landscape.

Ready to Take Action?

  • Share this article with your team to align everyone on PCI DSS 4.0 best practices.
  • Bookmark our PCI DSS 4.0 Checklist for your next internal audit.
  • Reach out to HeroDevs for help in phasing out EOL platforms and strengthening your compliance posture.

By investing in PCI DSS 4.0 compliance now, you’re not just checking a regulatory box; you’re actively safeguarding your business’s reputation, customer trust, and long-term success in today’s competitive market.

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Article Summary
Learn how to achieve PCI DSS 4.0 compliance with this comprehensive guide. Explore key requirements, the importance of retiring EOL software, and how HeroDevs helps businesses stay secure and compliant.
Author
HeroDevs
Thought Leadership
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