Every business that processes, stores, or transmits payment card data is a prime target for cybercriminals. From data breaches to payment fraud, attackers are constantly searching for security gaps to exploit. This is why compliance with the Payment Card Industry Data Security Standard (PCI DSS) isn’t just a regulatory obligation – it’s a critical step in protecting sensitive financial information.
Among PCI DSS’s security controls, penetration testing stands out as one of the most effective ways to uncover vulnerabilities before they can be exploited. By simulating real-world cyber attacks, penetration testing helps businesses identify weaknesses, strengthen defenses, and maintain compliance.
In this guide, we’ll break down what PCI penetration testing process involves, why it’s essential for compliance, and how your business can prepare for a successful test – ensuring that security gaps are closed before attackers can take advantage of them.
What is PCI Penetration Testing?
Penetration testing services include a controlled, simulated cyber attack designed to uncover vulnerabilities in the Cardholder Data Environment (CDE) and any systems which may impact the security of the CDE. Unlike vulnerability scanning, which identifies known security weaknesses, penetration testing goes further by attempting to exploit them – giving businesses a real-world view of their security posture. Read our article on which is right for you – penetration testing or vulnerability scanning.
This approach is essential because compliance alone does not guarantee security. Even businesses that meet PCI security standards can still be vulnerable to zero-day exploits, misconfigurations, or emerging attack techniques.
To mitigate these risks, PCI DSS 4.0 outlines security requirements for all critical systems that store, process, or transmit cardholder data:
- PCI DSS Requirement 11.3 mandates that vulnerability scanning be conducted at least quarterly to promptly identify and address external and internal vulnerabilities, reducing the risk of system compromise.
- PCI DSS Requirement 11.4 requires conducting regular penetration testing to assess the security of networks, web applications, and critical systems. This includes annual internal penetration testing as well as external penetration tests to detect and remediate security gaps within the Cardholder Data Environment.
By integrating penetration testing and vulnerability scanning into their security strategy, businesses can proactively identify vulnerabilities and weaknesses, strengthen defenses, and maintain PCI compliance. Read more about why penetration testing is important.
What’s New in PCI DSS 4.0?
Before diving into the details of PCI penetration testing, it’s essential to understand the latest updates in PCI DSS.
PCI DSS 4.0, the latest version of the security standard, was introduced to enhance security controls, improve flexibility, and focus on continuous protection. Some key updates include:
- Flexible Compliance: Organizations can now use a customized approach if they prove security effectiveness. This offers greater flexibility while maintaining strong security postures.
- Stronger Authentication: Multi-Factor Authentication (MFA) is now required for all access to cardholder data, not just for administrators. Additionally, stricter password policies mandate longer, more complex passwords and require password changes based on risk rather than arbitrary timeframes.
- Enhanced Encryption: PCI DSS 4.0 enforces stronger encryption protocols to protect both stored and transmitted cardholder data. This includes the requirement to use modern, industry-accepted cryptographic methods and improved key management practices to minimize risks of data breaches.
- Better Monitoring: Organizations must implement automated log reviews to detect suspicious activities more efficiently. The scope of penetration testing has also been expanded to include a risk-based approach, ensuring businesses regularly test security defenses against evolving cyber threats.
- Service Provider Accountability: Service providers, including cloud vendors and payment processors, must adhere to stricter compliance requirements. This includes clearer responsibilities for cybersecurity controls, continuous security testing, and proof of ongoing compliance with PCI DSS standards.
- Continuous Security Focus: PCI DSS 4.0 places an emphasis on ongoing security awareness. Businesses are now required to conduct regular security awareness training for employees, implement phishing awareness programs, and develop a proactive risk management strategy to adapt to emerging threats.
Businesses must transition to PCI DSS 4.0 by March 31, 2025 to maintain compliance.
PCI Penetration Testing Requirements
To comply with PCI DSS 4.0, businesses must conduct penetration tests that follow specific guidelines regarding who performs the tests, what is tested, and how the testing is conducted. Here’s what organizations need to know:
Who Performs PCI Penetration Testing?
PCI penetration testing must be conducted by qualified penetration testing team who have the necessary experience and certifications. While PCI DSS 4.0 does not specify a required certification, a penetration testing company and pen testers should have credentials such as Offensive Security Certified Professional (OSCP), Certified Ethical Hacker (CEH), or CREST Certification, along with proven expertise in ethical hacking and security assessments.
Organizations can either:
- Hire a third-party penetration testing provider or penetration testers with PCI DSS experience.
- Use qualified internal resource to perform internal penetration testing only if they maintain organizational independence from the systems being tested (i.e., they cannot test their own implementations).
PCI DSS defines Qualified Security Assessors (QSAs) and Approved Scanning Vendors (ASVs), but they are not required for conducting network penetration testing and internal network vulnerability scans. However, external network vulnerability scanning must be performed by a PCI SSC Approved Scanning Vendor (ASV) to meet compliance requirements.
Scope of PCI Penetration Testing
PCI DSS penetration testing must cover the entire Cardholder Data Environment (CDE) perimeter and all critical operating systems, testing both internal and external network security. It must validate segmentation controls used to reduce PCI scope and include application-layer and network-layer penetration testing to detect vulnerabilities outlined in Requirement 6.2.4.
Testing should also consider recent threats and vulnerabilities from the past 12 months and follow a documented risk assessment process to address identified weaknesses. Businesses must retain the penetration test report and remediation records for at least 12 months. PCI DSS requires penetration testing to be conducted at least annually or after any significant changes in infrastructure or application.
Segmentation Requirements in Penetration Testing
When businesses use segmentation controls to isolate the Cardholder Data Environment (CDE) from other networks, PCI DSS requires penetration testing or segmentation testing to validate their effectiveness. Segmentation testing must be conducted at least annually and after any significant changes to the controls to ensure the CDE remains properly isolated.
Segmentation testing must validate all segmentation controls, follow the organization’s testing methodology, and confirm that unauthorized access to the CDE is blocked. It should also ensure proper isolation between systems with different security levels and be performed by a qualified, independent penetration tester.
Reporting & Remediation
Once testing is complete, organizations must receive a detailed penetration test report, which should include:
- Findings: A comprehensive list of identified vulnerabilities, categorized by severity – critical, high, medium, or low. This section should provide clear descriptions of the security gaps found, along with details on affected systems, services, or applications.
- Exploitation Details: A breakdown of how vulnerabilities were tested and exploited, including the specific attack vectors used, tools and techniques applied, and whether successful exploitation led to unauthorized access, data extraction, or privilege escalation.
- Impact Assessment: An evaluation of the potential consequences each vulnerability poses to the business, such as financial loss, regulatory non-compliance, operational disruptions, or reputational damage. This helps prioritize remediation efforts based on real-world risks.
- Recommendations: Actionable, prioritized remediation steps tailored to each vulnerability. This should include best practices for patching, configuration changes, network segmentation, access control improvements, and other security measures necessary to close security gaps.
After fixing the identified security gaps, businesses must conduct retesting to verify that vulnerabilities have been successfully mitigated and no new ones are introduced.
Conducting PCI DSS Tests
Preparing for a PCI Penetration Test
Before conducting a full PCI penetration test process, businesses must ensure proper preparation to maximize effectiveness and streamline compliance:
- Define the Scope: Identify all in-scope systems, networks, web applications, and data flows that store or process cardholder data. This includes databases, cloud environments, payment processing platforms, and third-party services. Clearly defining the scope prevents gaps in security testing and ensures all critical assets are assessed.
- Conduct a Risk Assessment: Evaluate potential security threats and prioritize critical assets that need a pen test. This involves identifying known vulnerabilities, recent security incidents, and emerging threats that could impact the business. A risk-based approach helps focus penetration testing efforts on the most high-risk areas, ensuring compliance with PCI DSS 4.0 requirements.
- Create an Asset Inventory: Maintain an up-to-date record of IT assets, including third-party integrations, APIs, and infrastructure components. This ensures nothing is overlooked during the PCI pen test. A comprehensive asset inventory should also document system ownership, data classification, software versions, and security configurations. This allows penetration testers to identify potential weak points, such as outdated software, misconfigured access controls, or unpatched vulnerabilities. Additionally, mapping out the interdependencies between different systems ensures that security weaknesses in one component do not inadvertently expose sensitive data across multiple environments.
By addressing these areas in advance, businesses can ensure accurate preparation to perform penetration testing and generate comprehensive reports on security findings.
Steps in a PCI DSS Pen Test
For penetration testing to be effective and meet PCI DSS 4.0 compliance standards, it must follow a structured, methodical approach. This ensures that security assessments are comprehensive, repeatable, and aligned with industry best practices. Each phase of penetration testing methodology – from reconnaissance to reporting – plays a crucial role. For an in-depth breakdown of penetration testing phases, check out our dedicated guide Penetration Testing Phases.
After testing, businesses must use the pen test report to remediate security vulnerabilities and undergo retesting to verify PCI DSS compliance.
What If You Fail a PCI Penetration Test?
If a business fails PCI penetration testing, it must remediate all critical and high-risk vulnerabilities before compliance can be validated. A retest is required to confirm fixes and ensure security measures and controls are properly implemented. Failure to address findings could result in PCI DSS non-compliance, potential fines, or restrictions from payment processors.
Common Pitfalls in PCI Penetration Testing (And How to Avoid Them)
Even with the best intentions, businesses often make mistakes when conducting PCI penetration testing, leading to compliance gaps and unaddressed security risks. Here are some of the most common pitfalls – and how to avoid them.
1. Scope misalignment
The Pitfall: Defining an incomplete or incorrect scope is one of the most frequent mistakes in PCI penetration testing. Businesses sometimes exclude critical assets – such as databases, APIs, or third-party integrations – leaving potential security gaps untested.
How to Avoid It:
- Ensure your scope includes all systems, networks, and web applications that process, store, or transmit credit card data.
- Regularly review and update your scope to reflect infrastructure changes.
- Work with a qualified penetration testing services provider who understands PCI penetration testing requirements.
2. Over-reliance on automated tools
The Pitfall: Some organizations assume that running automated vulnerability scans is enough to meet the PCI DSS compliance requirements. However, scanning tools only identify known vulnerabilities and cannot perform real-world exploitation or assess business logic flaws.
How to Avoid It:
- Use manual pen testing techniques alongside automated vulnerability scans to simulate real-world attacks and identify vulnerabilities that might otherwise be missed. You can read our article for more info on the Pros and Cons of Manual vs Automated Penetration Testing.
- Ensure the pen testing team attempt exploitation and privilege escalation to assess the true impact of vulnerabilities and evaluate various aspects of the organization’s security posture.
- Work with certified penetration testers who can go beyond what external vulnerability scanning tools detect by conducting network penetration testing, application-layer testing, and segmentation testing to fully protect cardholder data.
3. Neglecting Cloud Environments
The Pitfall: Many businesses focus their penetration tests on on-premise infrastructure, overlooking cloud-based payment processing systems, virtualized environments, and SaaS applications. Since many modern payment solutions rely on cloud services, failing to test them can lead to compliance and security gaps.
How to Avoid It:
- Include cloud-hosted assets, APIs, third-party integrations as well as application penetration tests in your PCI pen testing scope.
- Ensure cloud configurations follow best security practices (e.g., proper IAM settings, encryption, and access controls).
- Work with penetration testers experienced in cloud security to assess risks specific to your cloud provider.
4. Failure to Retest Vulnerabilities
The Pitfall: Finding security vulnerabilities through internal and external pentesting is only half the battle – many businesses fail to retest their critical systems after remediation, increasing the risk of non-compliance or reintroducing the same issues due to incomplete fixes.
How to Avoid It:
- Conduct retesting after remediation to confirm vulnerabilities have been fully addressed.
- Ensure that pen testers verify and document in the final PCI compliance report that all identified security gaps have been successfully resolved.
- Implement a continuous security testing strategy to stay ahead of evolving threats.
Avoiding these pitfalls ensures that PCI penetration testing is effective, compliant, and actionable. By properly defining scope, combining manual and automated testing, including cloud environments, and verifying remediation efforts, businesses can reduce risk, maintain PCI compliance, and strengthen their payment security.
PCI Pen Testing is More Than Compliance
PCI DSS penetration testing isn’t just about checking a compliance box – it’s about proactively securing customer data and preventing costly breaches. By defining a comprehensive penetration testing methodology and scope, following a structured approach, and avoiding common pitfalls, businesses can strengthen their security posture and compliance standing.
All organizations need to realize that compliance requirements are not simply a check-box exercise but have all been designed to actually bring your business to a higher level of cybersecurity maturity as a whole.
Marko Simeonov, CEO at AMATAS
At AMATAS, our CREST-certified penetration testers help businesses navigate PCI penetration testing requirements with precision. Whether you need a first-time penetration test services or a retest after remediation, we ensure comprehensive assessments that go beyond compliance requirements. Contact us today to learn more or book a meeting with our experts.
FAQs
Is the penetration test required for a specific compliance requirement?
Yes, PCI requires penetration testing for businesses that process, store, or transmit payment card data. It requires annual penetration testing and quarterly vulnerability scans to assess controls, identify vulnerabilities, and ensure compliance with industry standards.
What are the legal requirements for penetration testing?
There is no universal legal requirement, but PCI DSS mandates penetration testing for businesses handling cardholder data. Additionally, GDPR, HIPAA, and other industry regulations may require penetration testing as part of broader cybersecurity compliance. Legal obligations depend on jurisdiction, industry, and regulatory frameworks.
What is the PCI DSS Requirement 7?
PCI DSS Requirement 7 mandates restricting access to system components and cardholder data by business need-to-know. Organizations must implement role-based access controls (RBAC), least privilege principles, and multi-factor authentication (MFA) to prevent unauthorized access to sensitive payment data.
What’s the difference between internal and external PCI DSS penetration testing?
External penetration testing evaluates internet-facing systems for vulnerabilities exploitable by remote attackers, while internal penetration testing simulates insider threats by assessing security risks within the corporate network. Both tests are required to meet PCI DSS compliance and protect against different attack vectors.
What are the business benefits of PCI penetration testing beyond compliance?
PCI penetration testing identifies security weaknesses before attackers exploit them, reduces data breach risks, strengthens customer trust, and improves incident response preparedness. It also helps businesses assess security investments, meet contractual security obligations, and enhance overall cyber resilience strategy.
How much does PCI DSS penetration test typically cost?
The PCI penetration testing cost varies based on scope, complexity, and provider expertise. Factors such as the number of systems, testing methodologies, cloud environments, and network size influence pricing. Businesses should work with certified third-party penetration testers to ensure PCI compliance, accurate assessments, and actionable security improvements.
