PCI DSS Gap Assessment Process The Essential First Step Toward Compliance

Before any organization embarks on the journey to PCI DSS compliance, it must answer one question: “Where do we stand today?” The PCI DSS gap assessment is the structured answer.

Think of it as a diagnostic phase that uncovers vulnerabilities, prioritizes remediation, and sets the direction for your compliance roadmap. In this article, we break down the gap assessment process—ideal for startups, growing SaaS businesses, fintechs, and even mature enterprises looking to adopt PCI DSS v4.0.

What Is a PCI DSS Gap Assessment?

A PCI DSS gap assessment is a formal evaluation of your current security posture against the 12 core requirements of PCI DSS (v4.0 as of 2025). It identifies:

• Which requirements you currently meet

• Which controls are partially implemented

• Which are entirely missing or non-compliant

It is often conducted by internal security teams or a Qualified Security Assessor (QSA) to build a detailed compliance action plan.

Why It’s Critical in 2025

The 2025 PCI DSS landscape is more stringent:

• Version 4.0 introduces enhanced requirements around authentication, encryption, and continuous monitoring

• Increasing pressure from acquirers, regulators, and enterprise clients

• Proactive cybersecurity is no longer optional

A gap assessment is your low-risk, high-value move before formal audits or SAQ/ROC submissions.

Who Should Perform the Gap Assessment?

• Startups and SMBs: Often engage consultants or vCISOs

• Mid-sized firms: Leverage GRC tools or MSSPs

• Large enterprises: Involve internal InfoSec teams with external validation

In every case, the goal is clarity and prioritization.

Step-by-Step PCI DSS Gap Assessment Process

Step 1: Define the Scope

Start by identifying:

• Where cardholder data (CHD) is stored, processed, or transmitted

• All systems, applications, and networks that touch card data

This defines your Cardholder Data Environment (CDE).

Tip: Keep scope minimal by using tokenization, point-to-point encryption, and outsourcing card processing where possible.

Step 2: Review the 12 PCI DSS Requirements

The 12 core areas include:

1. Install and maintain network security controls

2. Apply secure configurations to all system components

3. Protect stored account data

4. Encrypt transmission of cardholder data

5. Protect systems from malware

6. Develop and maintain secure systems

7. Restrict access to cardholder data

8. Identify and authenticate access

9. Restrict physical access

10. Log and monitor access

11. Test security systems regularly

12. Maintain information security policies

You’ll evaluate your systems and processes against each.

Step 3: Conduct Data Discovery

Use automated tools (e.g., Spirion, Ground Labs, or Varonis) to:

• Locate all instances of PAN (Primary Account Numbers)

• Identify unstructured data stored across servers, endpoints, and cloud platforms

This reveals shadow data risks and helps avoid non-compliance.

Step 4: Interview Key Stakeholders

Involve:

• IT/security engineers

• Developers

• Compliance and legal teams

• Third-party vendors

Gather information about current processes, access controls, policies, and third-party integrations.

Step 5: Analyze Technical Controls

Review configuration and effectiveness of:

• Firewalls, IDS/IPS, WAFs

• VPN and remote access policies

• Authentication methods (MFA, SSO)

• Data encryption practices

• Logging and SIEM tools

Look for any outdated tools or misconfigurations.

Step 6: Review Policies and Documentation

Evaluate whether your security policies are:

• Comprehensive

• Up-to-date

• Aligned with PCI DSS v4.0

• Enforced across teams

Policies that exist but are not followed are considered non-compliant.

Step 7: Map Out Gaps

Now, map the results:

• Fully compliant controls

• Partially implemented or ad-hoc controls

• Missing or non-compliant areas

Create a gap matrix that aligns findings to the 12 requirements.

Step 8: Prioritize Remediation Efforts

Score each gap based on:

• Risk impact (High/Medium/Low)

• Complexity to fix

• Dependency on external vendors

Develop a remediation roadmap:

• Short-term (Quick wins)

• Mid-term (Process/policy updates)

• Long-term (Tech overhaul, architectural redesign)

Step 9: Create a Compliance Readiness Report

Summarize findings into a structured report that includes:

• Scope definition

• Gap matrix

• Risk analysis

• Recommended actions

• Timeline for implementation

This becomes your compliance baseline for future audits.

Step 10: Monitor Progress & Prepare for the Next Phase

Once remediation begins:

• Track progress using GRC tools (e.g., Drata, Vanta, LogicGate)

• Assign owners to each control area

• Document changes as evidence for future audits

Bonus: Tools That Help With PCI DSS Gap Assessment

• OpenVAS/Nessus – Vulnerability scanning

• Qualys PCI Compliance Suite – Scan + report generation

• Trustwave – Managed compliance services

• AWS Artifact – Download PCI responsibility matrix for cloud environments

• Atlassian Confluence – Track documents and audit trails

Mistakes to Avoid

• Skipping data discovery and assuming scope

• Relying solely on vendor attestations

• Ignoring physical security or mobile device access

• Over-engineering controls instead of segmenting

• Neglecting documentation

Final Thoughts

The PCI DSS gap assessment is your compliance compass—pointing out where you are and where you need to go. It allows businesses of all sizes to build a risk-informed, efficient path to certification.

And in 2025, with evolving threat vectors and regulatory expectations, it’s not just about passing an audit—it’s about building secure systems from the ground up.

Need help running a PCI DSS gap assessment for your organization? Book a free consultation with our audit experts today.