Preparing for PCI DSS v4.0: Adapting to the 2025 Mandatory Requirements

PCI DSS v4.0 is here, and it’s a big deal. Introduced in 2024, this version was designed to tackle modern security challenges and adapt to how businesses handle payments today. To make the transition a bit easier, the PCI Security Standards Council split the rollout into two phases: 13 requirements became mandatory in March 2024, and the remaining 51 recommendations will be required by March 31, 2025.

That means you still have time, but not as much as you might think. This article breaks down the changes you need to know, with a focus on where to start. HeroDevs is not a PCI assessor, but we hope this guide will point you in the right direction. For a full list of changes, you can check out the PCI DSS v4.0 Summary of Changes.

What’s New in PCI DSS v4.0?

PCI DSS v4.0 isn’t just an update. It’s a complete overhaul to meet today’s security threats. These changes are all about making compliance more proactive and ongoing, rather than a once-a-year box-checking exercise.

Key Themes in v4.0

1. Reducing Protected Information: One of the main goals is to minimize the amount of sensitive information in your environment. This includes using tokenization and only collecting what’s absolutely necessary.
2. Stronger Encryption: Encryption requirements have been tightened for data in transit and at rest to keep up with modern threats.
3. Clearer Documentation: Businesses are now expected to document their cryptographic practices, roles, vulnerabilities, and any custom code.
4. Incident Response Plans: Organizations need to have solid plans for detecting breaches, alerting the right people, and resolving issues quickly.
5. Risk Analysis at All Levels: Whether it’s your tech stack or your business operations, understanding and addressing risks across the board is a major focus.
6. Better Scanning and Vulnerability Management: Scanning requirements have been expanded to include all vulnerabilities (not just critical ones).
7. Limiting Privileges: Access to the Cardholder Data Environment (CDE) must be strictly controlled, following a “need-to-know” basis.
8. Enhanced Authentication: Multi-factor authentication (MFA) is now required in more areas, and password rules have been updated to align with modern security standards.
9. Automating Monitoring: Automating log and code reviews is becoming a best practice to catch potential issues faster and with fewer errors.
   
   

What to Focus on for 2025

By March 2025, many of the previously optional changes will become mandatory. The entire list of changes are required to become compliant but here’s a snapshot of some of the big ones:

1. Phishing Defenses (Requirement 5.4.1): You’ll need processes or tools to detect and prevent phishing, such as employee training or automated email scanning.
2. Expanded Vulnerability Scanning and Managing (Requirement 11.3): All vulnerabilities (not just critical or high ones) need to be addressed. This ensures smaller risks aren’t ignored.
3. Software Inventories (Requirement 6.3.2): You’ll need a detailed inventory of all custom and third-party software to make patching and vulnerability management easier.
4. Continuous Web Monitoring (Requirement 6.4.2): Any public-facing web apps must use automated tools to detect and block attacks in real time.

Again, these changes reflect PCI DSS’s bigger push toward proactive, continuous security. For more details, check out the official PCI DSS v4.0 Summary of Changes.

How to Prepare for 2025

The deadline might seem far away, but the work required isn’t something you want to leave until the last minute. Here’s how you can get started:

1. Assess Your Current State

Take a close look at where you are today. Do you have phishing defenses in place? Is vulnerability scanning up to date? Are software inventories complete? A clear understanding of your gaps will make it easier to prioritize what needs to happen next.

2. Tackle the Big Changes First

Focus on updates that will have the most significant impact, like improving phishing defenses or expanding your scanning tools. Breaking larger tasks into smaller steps can help avoid feeling overwhelmed.

3. Build a Clear Roadmap

Lay out a timeline for what needs to be done and when. Assign responsibilities and make sure your team is aligned. Training your staff on the new requirements can also save headaches down the road.

4. Seek Expert Guidance

Whether it’s consulting a Qualified Security Assessor (QSA) or using PCI SSC’s resources, getting help from experienced professionals can streamline your efforts and avoid unnecessary setbacks.

Why Start Now?

The phased rollout of v4.0 gave organizations time to adapt, but waiting too long increases the risks. Here’s why acting now matters:

• Security Breaches: Delayed compliance means potential vulnerabilities stay open longer.
• Operational Disruptions: Rushing to meet deadlines can lead to mistakes or downtime.
• Fines and Penalties: Non-compliance can result in financial penalties and reputational damage.

On the flip side, starting early means you can approach the changes thoughtfully and avoid the last-minute scramble.

Moving Forward

PCI DSS v4.0 is about more than following rules. It’s about building trust with your customers and strengthening your organization against the constantly evolving threat landscape.

Focus on areas like phishing defenses, vulnerability scanning, and encryption to set yourself up for success. For the full breakdown of changes, visit the official PCI DSS v4.0 Summary of Changes.

The March 2025 deadline will be here before you know it, so don’t wait. Start today to make the transition smoother and your systems more secure.

‍