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Limaz

PCI DSS readiness service

Define PCI DSS scope, remediate gaps, and prepare evidence.

Limaz helps merchants, payment providers, fintechs, and service providers define the cardholder data environment, assess readiness, implement remediation, and prepare evidence for the required validation path.

Start with the payment data flow

PCI DSS applies to entities that store, process, or transmit cardholder or sensitive authentication data. It also covers systems that can affect the security of that environment. Readiness work starts with data flows, connected-system boundaries, and segmentation decisions.

Limaz provides readiness, remediation, and evidence support.

What Limaz delivers

Scope and data flow
Payment channels, account-data flows, cardholder data environment, connected systems, people, and third parties.
Segmentation review
Boundary assumptions, network paths, access, shared services, and evidence supporting scope reduction.
Gap assessment
Requirement-by-requirement review of control design, implementation, operation, and available evidence.
Remediation
Prioritized technical and process work with accountable owners and retesting.
Targeted risk analysis
Support for documented risk analysis where PCI DSS requires or permits it.
Evidence and validation support
Evidence index, sampling support, SAQ or ROC preparation inputs, and assessor-question coordination.
Sustainable operation
Recurring tasks, ownership, monitoring, change triggers, and handover after the assessment cycle.

PCI DSS v4.0.1 in brief

The Payment Card Industry Data Security Standard (PCI DSS) protects payment account data. It applies to every entity that stores, processes or transmits cardholder data or sensitive authentication data, and to every entity that can affect the security of that data: merchants, processors, acquirers, issuers and service providers.

PCI DSS v4.0.1 is the only active version. The PCI Security Standards Council (PCI SSC) published v4.0 on 31 March 2022 and retired v3.2.1 on 31 March 2024. It published v4.0.1, a limited revision, in June 2024 and retired v4.0 on 31 December 2024. The 51 future-dated requirements introduced in v4.0 became mandatory on 31 March 2025.

PCI SSC writes the standard. The card brands enforce it. American Express, Discover, JCB International, Mastercard, UnionPay and Visa each run their own compliance programme and decide who must validate, how and how often. Your acquiring bank passes those rules to you.

Account data has two parts. Cardholder data is the primary account number (PAN), cardholder name, expiration date and service code. Sensitive authentication data is full track data, the card verification code, and PINs or PIN blocks. Sensitive authentication data must never be stored after authorisation, even encrypted.

In Saudi Arabia, PCI DSS reaches merchants through their acquirers. Banque Saudi Fransi's published mada point-of-sale merchant agreement, for example, requires merchants to comply with PCI DSS, demonstrate compliance and carry out required remediation. Payment service providers licensed by SAMA also follow SAMA and National Cybersecurity Authority (NCA) cybersecurity requirements, so the PCI DSS programme sits inside a wider control set.

The 12 PCI DSS requirements

1. Install and maintain network security controls
Goal: build and maintain a secure network and systems. Firewalls, cloud security groups and other network controls, with documented rules, reviewed rule sets and restricted traffic into and out of the cardholder data environment (CDE).
2. Apply secure configurations to all system components
Hardened builds, vendor default accounts changed or removed, and only the services, protocols and functions the system needs.
3. Protect stored account data
Goal: protect account data. Keep storage to a minimum with a retention policy, mask PAN on display, render stored PAN unreadable with strong cryptography, hashing, truncation or tokenisation, and manage keys under documented procedures.
4. Protect cardholder data with strong cryptography during transmission
Strong cryptography and trusted certificates whenever PAN crosses open, public networks, with an inventory of trusted keys and certificates.
5. Protect all systems and networks from malicious software
Goal: maintain a vulnerability management programme. Anti-malware on systems at risk, periodic review of systems judged low risk, and automated protection of personnel against phishing.
6. Develop and maintain secure systems and software
Secure development, code review, timely patching of critical vulnerabilities, change control, and authorisation and integrity checks for every script on payment pages.
7. Restrict access by business need to know
Goal: implement strong access control measures. Least privilege, role-based access and periodic review of all user accounts and privileges.
8. Identify users and authenticate access
Unique IDs, strong authentication, multi-factor authentication (MFA) for all access into the CDE, and control of system and application accounts.
9. Restrict physical access to cardholder data
Facility entry controls, visitor management, media handling and destruction, and inspection of point-of-interaction (POI) devices for tampering.
10. Log and monitor all access
Goal: regularly monitor and test networks. Audit logs on all CDE components, protected from change, reviewed with automated mechanisms and retained for at least 12 months.
11. Test security of systems and networks regularly
Internal and external vulnerability scans every three months, external scans by an Approved Scanning Vendor (ASV), penetration testing, segmentation testing, intrusion detection and tamper detection on payment pages.
12. Support information security with policies and programmes
Goal: maintain an information security policy. Policies, targeted risk analyses, scope confirmation, security awareness, third-party service provider management and an incident response plan.

What changed in v4.0 and v4.0.1

  • v4.0.1 is a limited revision: it corrects formatting and typographical errors and clarifies intent. It adds no requirements and deletes none, and it leaves the 31 March 2025 effective date unchanged.
  • v4.0 brought more than 50 new requirements. 51 of them were future-dated and became mandatory on 31 March 2025.
  • Multi-factor authentication now covers all access into the CDE, not only remote and administrative access.
  • Payment page scripts: every script loaded in the consumer's browser must be authorised, integrity-checked and listed in an inventory with a written justification (6.4.3). A change- and tamper-detection mechanism must alert on unauthorised changes to payment pages (11.6.1).
  • Phishing: processes and automated mechanisms detect and protect personnel against phishing attacks (5.4.1).
  • Targeted risk analysis (12.3.1): where the standard lets you set how often an activity runs, a documented risk analysis sets and justifies the frequency.
  • Scope confirmation (12.5.2): the entity confirms its PCI DSS scope by identifying every location and flow of account data and every system that connects to or can affect the CDE.
  • Disk-level or partition-level encryption alone no longer protects PAN on non-removable media. PAN needs a second mechanism (3.5.1.2).
  • The Customized Approach: an alternative way to meet a requirement's stated Customized Approach Objective with a different control. It is built for risk-mature entities, needs a controls matrix and a targeted risk analysis for each customized control, and a Qualified Security Assessor (QSA) validates it.
  • SAQ A update: PCI SSC removed 6.4.3, 11.6.1 and 12.3.1 from SAQ A and added an eligibility criterion. SAQ A merchants confirm their site is protected from script attacks that could affect their e-commerce systems.

Scoping the cardholder data environment

Scope decides cost. Every system component in scope must meet the applicable requirements, so the first job is to find every place account data lives and moves. PCI SSC's scoping guidance tells entities to start from the assumption that everything is in scope until verified otherwise.

The guidance sorts systems into three categories. CDE systems store, process or transmit account data, or sit on the same network segment as systems that do. Connected-to and security-impacting systems, such as authentication servers, jump hosts and logging and patching servers, reach the CDE or affect its security, and they are fully in scope. Out-of-scope systems meet every exclusion test: no account data, no connection to the CDE and no path to affect its security.

Segmentation is how scope shrinks. PCI DSS leaves segmentation optional and strongly recommends it, because isolating the CDE from the rest of the network reduces assessment scope, cost and risk. If you rely on segmentation, prove it: penetration-test the segmentation controls at least once a year as a merchant and every six months as a service provider.

Architecture reduces scope further. Tokenisation, hosted payment pages and iframes from a PCI DSS compliant processor, and validated point-to-point encryption (P2PE) solutions each remove systems from the CDE. Each choice also moves responsibility, so record which party owns which requirement in a responsibility matrix with every third-party service provider.

SAQ vs ROC

PCI SSC defines the validation documents. The card brands decide who uses which one. Each brand sets its own merchant and service-provider levels and the validation each level submits, and acquirers pass those rules to their merchants. Your acquirer or the brand confirms your level and your document.

Self-assessment

Self-Assessment Questionnaire (SAQ)

The entity assesses itself. Merchants use SAQ A, A-EP, B, B-IP, C, C-VT, P2PE, SPoC or D, each matching a payment channel and architecture. SAQ D for Service Providers is the only SAQ for service providers. Your acquirer or the brand confirms eligibility.

Assessor-led

Report on Compliance (ROC)

A Qualified Security Assessor (QSA) tests every applicable requirement, with sampling, interviews and evidence, and documents the result in the ROC template. The Customized Approach is documented only through a ROC.

Declaration

Attestation of Compliance (AOC)

The formal declaration of the assessment result. It accompanies every SAQ and ROC, goes to the acquirer or brand, and is the evidence customers collect when they monitor a service provider's PCI DSS status every 12 months (12.8.4).

Quarterly evidence

ASV scan reports

External vulnerability scans by a PCI SSC Approved Scanning Vendor every three months, with passing results. Acquirers check them alongside the SAQ or ROC.

Common PCI DSS gaps

Scope drawn around the database
Jump hosts, identity providers, logging, CI/CD pipelines and shared admin workstations connect to or affect the CDE, so they belong in scope.
Segmentation with no test evidence
A network diagram is a claim. The assessor wants penetration test results that show the segmentation controls work.
Unmanaged payment page scripts
No script inventory, no integrity check and no tamper detection on the payment page. Requirements 6.4.3 and 11.6.1 have been mandatory since 31 March 2025.
MFA that stops at the VPN
Version 4 requires MFA for all access into the CDE, including administrative access from inside the corporate network.
Sensitive authentication data in logs
Card verification codes or track data in application logs, debug traces or support tickets. Storage after authorisation is prohibited, even encrypted.
Missing targeted risk analyses
Where you set your own frequency for an activity, the assessor expects the documented targeted risk analysis behind it.
Undocumented third-party responsibilities
Cloud, processor and managed service providers each own part of the requirements. Without a responsibility matrix and a current AOC from each one, the gap lands on you.
Compliance as an annual event
Log reviews, access reviews, scans and scope confirmation run all year, and assessors sample the whole period.

A PCI DSS readiness programme

How Limaz runs PCI DSS readiness with payment teams in the Kingdom.

  1. Confirm the validation path

    Get your level and required document from your acquirer or the card brands. Merchant or service provider, SAQ or ROC: this fixes the target.

  2. Map every account data flow

    Trace e-commerce, mobile, POS, call centre, refunds, chargebacks and reporting. Find every place PAN and sensitive authentication data appear, including logs and backups.

  3. Reduce scope

    Delete stored data with no business need, tokenise the rest, segment the CDE and move payment pages to compliant hosted components.

  4. Assess requirement by requirement

    Test each applicable requirement for design, implementation and operating evidence, including every requirement that became mandatory on 31 March 2025.

  5. Remediate

    Close gaps with named owners and dates: MFA, script management, logging, hardening, key management and vulnerability management. Limaz implements the technical fixes alongside the plan.

  6. Build the evidence index

    Map each requirement to its evidence, owner and sampling period, then run a pre-assessment against it.

  7. Validate

    Complete the SAQ, or support the QSA through the ROC, and issue the AOC.

  8. Operate all year

    Run the recurring controls on a calendar: quarterly scans, access and rule reviews, penetration tests, scope confirmation and targeted risk analyses.

Questions

  • PCI DSS v4.0.1 is the only active version. PCI SSC published it in June 2024 as a limited revision of v4.0 that corrects errors and clarifies intent, with no requirements added or deleted. PCI DSS v4.0 was retired on 31 December 2024, and v3.2.1 was retired on 31 March 2024. Every assessment today runs against v4.0.1.

Discuss your requirements with Limaz

Tell us which system, control, or requirement you are working on. We’ll come back with a clear next step.