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If your business handles credit card payments, PCI compliance is essential. Earlier this year, PCI DSS 4.0 was released, bringing new challenges and opportunities for organizations to strengthen their defenses. Whether you’re a merchant or a service provider, understanding the latest changes is critical to protecting your customers’ sensitive data and avoiding penalties.

In this article, we break down the key updates introduced in PCI DSS 4.0 and help you understand what to do to keep your organization in compliance.

What is PCI DSS 4.0?

The Payment Card Industry Data Security Standard (known as PCI DSS, or PCI to shorten it even further) was developed by the PCI Security Standards Council to ensure the secure handling of credit card data. The first version of the standard was released in 2004, and has evolved over the past twenty years alongside technological advancements and changes in consumer behavior. 

PCI DSS 4.0 is the latest version of the standard. It was officially released in March 2022 to replace version 3.2.1. There was a transition period of three years so that organizations could adapt their policies and procedures to prepare for the change. As of March 31, 2025, version 3.2.1 was officially retired, and all organizations must move to the 4.0 framework.

The update reflects a shift in cybersecurity best practices, emphasizing flexibility, continuous compliance, and stronger, risk-based security controls.

Key Changes Introduced in PCI DSS 4.0

Many of the key changes released in version 4.0 have to do with adapting to the security threats of today’s world. If your organization has been keeping up to date with security policy and procedures, you may have already implemented changes like increased password length and multifactor authentication. Other changes provide more flexibility for organizations with mature security programs to meet the requirements. Let’s look at some of the key updates to PCI DSS in version 4.0.

Customized Approach Option

PCI DSS 4.0 introduces a customized approach, allowing businesses to implement alternative security controls that meet the intent of a requirement. This offers flexibility, especially for organizations with mature security programs or unique operational needs.

Continuous Compliance Model

Rather than assessing compliance at a single point in time, 4.0 emphasizes ongoing monitoring and validation. This helps businesses move from a “check-the-box” mindset to a culture of continuous security.

Stronger Authentication Requirements

Multi-factor authentication (MFA) is now required for all access to cardholder data environments, including access by personnel within the organization and not just remote access.

Expanded Scope for Service Providers and Cloud

Service providers and third-party platforms are now more explicitly included, requiring more transparency and security assurance in shared environments like cloud services.

Enhanced Risk Management

Organizations must adopt a formal targeted risk analysis process to justify and tailor control implementations. This allows for better alignment with real-world risk.

Updated Technical Requirements

These changes adapt some of the technical requirements to be more in line with modern security standards and technology. Examples include:

  • Stricter password policies (e.g., minimum 12 characters).
    More detailed requirements for TLS encryption, web application firewalls, and vulnerability scanning.
  • Enhanced logging and monitoring obligations.

How Does PCI DSS 4.0 Compare to PCI DSS 3.2.1?

Let’s take a closer look at how some of the specific requirements have changed in version PCI DSS 4.0 compared to version 3.21. 

Authentication
Password Requirements
Custom Implementation
Risk Management
Encryption
Logging and Monitoring
Software Development
Anti-Malware
Penetration Testing
Sensitive Data Storage
Requirement Flexibility
Third-party Service Providers
PCI DSS 3.2.1
MFA required only for remote access
Minimum 7 characters, complexity rules
Prescriptive controls only
Periodic risk assessments
TLS 1.1+ allowed in some cases
Logging required, but limited detail
SDLC guidelines, limited specificity
AV or anti-malware must be deployed
Required yearly or after significant change
Defined restrictions
All requirements uniformly applicable
Must meet requirements
PCI DSS 4.0
MFA required for all access to CDE
Min 12 characters (or 8 with compensating controls), stronger rules
New customized approach with risk justification and testing
Emphasis on targeted risk analyses to determine frequency
TLS 1.2+ generally required, clear end-of-life guidance
Detailed logging of failures, access attempts, and alerting
Secure SDLC with threat modeling, code reviews, security tests
Enhanced requirements to evaluate malware type and risks
Clarifies segmentation testing, adds more structure to testing
More explicit requirements for data discovery and inventory
Options for customized validation under customized approach
Increased responsibility on organizations to manage providers

The updates make a lot of sense in today’s security environment and require organizations that process credit card information to take additional precautions to keep that information secure.

What Businesses Need to Do to Stay PCI-Compliant

So, where to begin? There are five main steps to making sure your organization is compliant with the PCI DSS 4.0 updates. 

1. Conduct a Gap Analysis

Assess your current compliance posture against the requirements in PCI DSS 4.0. Identify areas where you fall short and prioritize remediation efforts.

2. Update Security Policies and Procedures

Your security documentation should reflect the new standards, especially changes in access control, MFA, risk analysis, and incident response. 

3. Implement Necessary Technologies

Review your systems to ensure that they support:

  • MFA across all user access points
  • Proper encryption
  • Continuous monitoring and logging

4. Train Your Team

Educate your IT staff, developers, and any employees who handle cardholder data on the changes to policies and procedures. Awareness is critical to compliance.

5. Engage a Qualified Security Assessor (QSA)

A QSA can guide you through the transition, validate your implementation, and help avoid costly missteps.

Conclusion

PCI DSS 4.0 marks a significant evolution in payment data security. While the new standard introduces more complexity, it also provides opportunities to strengthen your defenses and build customer trust. By taking proactive steps like conducting a gap analysis, training your staff, and engaging with a QSA, your organization can ensure a smooth transition and maintain a strong security posture. If you are in need of guidance, TCM Security is here to help! Our team provides PCI DSS QSA auditing and can also support you with security testing. Use the form below to contact us.

About TCM Security

TCM Security is a veteran-owned, cybersecurity services and education company founded in Charlotte, NC. Our services division has the mission of protecting people, sensitive data, and systems. With decades of combined experience, thousands of hours of practice, and core values from our time in service, we use our skill set to secure your environment. The TCM Security Academy is an educational platform dedicated to providing affordable, top-notch cybersecurity training to our individual students and corporate clients including both self-paced and instructor-led online courses as well as custom training solutions. We also provide several vendor-agnostic, practical hands-on certification exams to ensure proven job-ready skills to prospective employers.

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