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New PCI DSS v4.0 – Flexibility added

May 25, 2022

On March 31, 2022, the PCI Security Standards Council released the new version of the Payment Card Industry Data Security Standards (version 4.0), which represents an update almost four years in the making.  In addition to some clarifications and rearrangements, the new PCI DSS 4.0 includes 51 new requirements for all entities, and 13 new requirements for service providers (now called TPSPs—third party service providers).  Of those new requirements, 13 are effective immediately for anyone undergoing a PCI DSS v4.0 assessment; 51 are “best practice” until March 31, 2025, at which time they will be mandatory.  In addition, each requirement now includes an entry for “Customized Approach Objective,” because the Council will allow entities to adopt an approach that “does not strictly follow the defined requirement” as long as it meets the stated objective in accordance with the Council’s requirements.  The Council noted that this new approach “is intended for risk-mature entities that demonstrate a robust risk-management approach to security, including, but not limited to a dedicated risk-management department or an organization-wide risk management approach.”  (Standards at 28.)  The previous version of PCI DSS (3.2.1) is retired as of March 31, 2024.  Either PCI DSS 3.2.1 or 4.0 can be used for assessments between now and March 31, 2024 (page 36).

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