As most Information Security professionals are aware, the Payment Card Industry (PCI) has released in late 2013 version 3.0 of its Data Security Standards (DSS). As done already in the past, the PCI council has released a document with a summary of changes highlighting the differences between version 2.0 and 3.0 of the standard.
THIS ARTICLE highlights the 5 most important changes for merchants introduced by version 3.0 of the PCI Data Security Standard (DSS):
The majority of the changes in PCI DSS version 3.0 are clarification-related and supplemental, not (for the most part) new requirements. The underlying reason for the changes are the new ways in how technology is used, both by merchants and by attackers. In general, PCI 3.0 provides better guidance to Qualified Security Assessors (QSAs) about what to assess and what evidence is needed to confirm that a control is in place.
This article groups into 5 categories the updates to the standard that are likely to present the biggest roadblocks for the largest segment of the merchant population.
1. Penetration testing
Perhaps the most visible change to the existing requirements has to do with updates to penetration testing requirements (11.3), including the requirement (11.3.4) to verify methods used to segment the cardholder data environment (CDE) from other areas. One portion of the update that’s likely to be particularly challenging for merchants to meet is the requirement that penetration testing activities (internal and external) must now follow an “industry-accepted penetration testing methodology,” such as the specifically referenced NIST SP 800-115, Technical Guide to Information Security Testing and Assessment. This is however good news for those specialized Penetration test service providers who can prove to adhere to industry-accepted penetration testing methodologies: those will likely experience boost in their business because merchants must now be careful to select their service providers only among those.
2. Inventorying system components
Another area of potentially huge impact from a practical standpoint relates to the new requirement (2.4) to “maintain an inventory of system components that are in scope for PCI DSS. The testing procedure for this specifically requires that assessors to verify that a list of hardware and software components is maintained and includes a description of function/use for each. As we all experienced, keeping inventories current isn’t easy to do mostly because they change often and, worse, frequently require manual effort in order to keep them reflective of the environment as it actually exists. This complexity is compounded when virtualization is thrown into the mix (because a system component includes virtual images too) or when the environment sprawls out in multiple geographic locations, as most distributed retail locations are likely to do. Furthermore, complexity also arises when proprietary, vendor-supplied systems are maintained by outside personnel (for example, application vendors or system integrators).
3. Vendor Relationships
Requirements 12.8.5 and 12.9 now call for explicit documentation about which PCI DSS requirements are managed by vendors vs. which are managed by the organization itself. The requirement for documentation means that now it’s necessary not only to maintain a list of the vendors and to track their compliance status when that service intersects your Cardholder Data Environment (CDE), both requirements before DSS 3.0, but also to maintain a matrix of the PCI DSS requirements with a corresponding responsibility assignment matrix for each applicable vendor that the vendor must sign off on.
In practice, merchants must now know exactly what the vendor or service provider does (to determine what its scope is), where responsibility should lie for controls, and how to create a document that describes those things. Then comes the fun part: getting the service providers in question to agree and to enter into a formal, written agreement about it. As anybody who’s been involved in vendor negotiations in the past can tell you, negotiating these points (particularly after a contract with a service provider is already in place) will be time-consuming and may be (depending on the service provider) contentious.
Also to be noted: PCI 3.0 mandates that service providers with remote access to Cardholder Data Environments (CDEs) must use a unique authentication credential for each customer environment — a requirement that will undoubtedly enhance security. It is not unusual for QSAs to find service providers using a common authentication credential to manage multiple client environments. From now on, service providers are expected to implement new customer and password management processes, and merchants should obtain confirmation from their service providers that this control is being met.
4. Anti-Malware
Requirement 5.1.2 now requires merchants to: “identify and evaluate evolving malware threats” for “systems considered to be not commonly affected by malicious software”. That means that if you use a system that isn’t usually affected by malware (think mainframes or Unix servers), you’ll need to have a process to make sure that this continues to be the case and that, should some malware emerge for those platforms, you’ll know about it. Depending on the organization, these requirements can have some impact. Under PCI DSS 2.0, the standard specified only that there be antivirus software in place, that it be operational, that it be updated or current, and that it have the ability to generate logs; now, the anti-malware system must be capable of locking out the user from disabling it (this will probably require specific configuration) and be configured to make use of that capability.
5. Physical access and point of sale
Requirement 9.3 now requires that merchants control physical access for on-site personnel: that access must be authorized, based on individual job function and must be revoked immediately upon termination. Also, requirement 9.9 now requires that merchants “protect devices that capture payment card data … from tampering and substitution”. How many merchants right now have an inventory of their PoS devices? While it’s certainly a good practice, the reality is that surprisingly few do. And consider where Req. 9.9 is most likely to be applicable from a merchant standpoint: retail locations, restaurants, doctors’ offices, food trucks, taxi cabs and other unique retail environments. Are those retailers accustomed to “periodically inspecting” point-of-sale (PoS) devices — for example, checking the serial numbers to ensure that devices haven’t been swapped? Not likely.
To meet these new requirements, many organizations will need to develop and implement new PoS security processes, such as maintaining up-to-date inventories, performing periodic PoS inspections and providing employee training about PoS security. QSAs will expect all such processes to be thoroughly documented and regularly performed.
If you want to read further on PCI DSS 3.0 I suggest a look to the following articles:
PCI 3.0: New requirements cover pen testing, service providers
PCI QSA analysis: PCI DSS 3.0 to bring new PCI challenges, benefits
PCI DSS 3.0 preview highlights passwords, providers, payment data flow
DISCUSSION QUESTION:
Which requirement in PCI DSS 3.0 do you think will be most difficult to meet, and why?

















