Top 5 PCI DSS v4.0.1 Myths Debunked

Myth 1: "We Can Keep Using Our v3.2.1 Controls"

The Myth

"Version 4.0 is just a refresh—our existing controls will still pass."

The Reality

PCI DSS v4.0.1 introduces 64 new requirements, with 13 immediately mandatory and 51 becoming mandatory in March 2025. Key changes include:

• Targeted risk analysis requirements for control frequencies
• Enhanced authentication requirements including MFA expansion
• New e-commerce and payment page protections
• Strengthened encryption and key management requirements
• Expanded security awareness training requirements

Myth 2: "The Customised Approach Means Easier Compliance"

The Myth

"The customised approach lets us avoid difficult requirements."

The Reality

The customised approach requires more rigorous documentation, not less. You must:

• Demonstrate how your alternative control meets the security objective
• Prove equal or greater effectiveness than the defined approach
• Document detailed testing procedures and results
• Undergo more intensive QSA scrutiny
• Maintain comprehensive evidence of control effectiveness

The customised approach is designed for mature organisations with sophisticated security programmes, not as an escape route from difficult requirements.

Myth 3: "Multi-Factor Authentication Is Only for Remote Access"

The Myth

"MFA requirements haven't really changed from v3.2.1."

The Reality

Requirement 8.4.2 now mandates MFA for ALL access into the cardholder data environment, not just remote access. This includes:

• Console access from within the network
• Local network access to CDE systems
• Third-party and vendor connections
• Administrative access regardless of location

The scope expansion is significant and requires infrastructure changes for many organisations.

Myth 4: "Targeted Risk Analysis Is Just Documentation"

The Myth

"We just need to document why we chose certain frequencies."

The Reality

Targeted risk analysis (Requirement 12.3.1) requires a documented methodology that:

• Considers threat likelihood and vulnerability severity
• Evaluates asset criticality and business impact
• Is performed by qualified personnel with risk expertise
• Is reviewed at least annually
• Is updated when the environment changes significantly
• Justifies the chosen frequency with evidence-based rationale

This is a rigorous process requiring genuine risk assessment, not a checkbox exercise.

Myth 5: "Service Providers Handle Our Compliance"

The Myth

"Our payment processor is PCI compliant, so we're covered."

The Reality

v4.0.1 strengthens third-party oversight requirements significantly:

• Document which requirements each service provider meets
• Obtain annual compliance confirmation (AOC or attestation)
• Monitor service provider compliance status continuously
• Requirement 12.8 mandates written agreements specifying responsibilities
• You remain responsible for requirements not covered by service providers

What You Should Do Now

• Gap Assessment: Compare current controls against v4.0.1 requirements
• Prioritise Future-Dated Requirements: Focus on the 51 requirements becoming mandatory
• Review MFA Scope: Identify all CDE access points requiring MFA
• Develop Risk Analysis Methodology: Create documented processes for targeted risk analysis
• Update Service Provider Agreements: Ensure contracts reflect v4.0.1 requirements
• Engage Your QSA Early: Discuss your transition approach and timeline

Conclusion

PCI DSS v4.0.1 represents a significant evolution in payment security requirements. Don't let myths derail your compliance programme. Understand the actual requirements, plan appropriately, and engage qualified assessors early to validate your approach.