Pentesting for PCI DSS Compliance

Cardholder data security has become a non-negotiable priority for companies processing electronic transactions. The PCI DSS (Payment Card Industry Data Security Standard), currently in version 4.0, defines technical and operational guidelines to protect this sensitive information throughout all stages of the transaction. 

In this context, penetration tests (pentests) are mandatory for companies that process cardholder data. They help validate the effectiveness of security controls, identify exploitable weaknesses, and reduce the risk of data breaches. By simulating real-world attacks, pentests reveal vulnerabilities that could be leveraged by malicious actors — contributing not only to PCI DSS compliance, but also to strengthening the organization's overall security posture. 

What is PCI DSS? 

PCI DSS is a set of requirements created by major credit card brands (Visa, MasterCard, Amex, Discover, and JCB) to standardize the security of cardholder data processing. It applies to any organization that stores, processes, or transmits payment data, regardless of its size or transaction volume. 

Version 4.0 of PCI DSS, released in March 2022, introduced updates such as risk-based approaches, allowing for more threat-focused security management. It also offers greater flexibility in control implementation, making it easier for companies to adapt the requirements to their specific needs. 

In addition, the standard encourages the adoption of modern authentication and encryption technologies to enhance the protection of sensitive data. These changes aim to strengthen security and provide greater agility for organizations while maintaining compliance with regulatory requirements. 

The framework is organized into six key objectives, divided into twelve requirements. These guidelines cover everything from network and data protection to continuous monitoring and incident response. 

One critical point is Requirement 11, which mandates the regular validation of security controls, including intrusion testing conducted in a systematic and documented manner. For instance, Requirement 11.4 states that both external and internal penetration tests (pentests) must be performed regularly to identify and remediate exploitable vulnerabilities and security weaknesses. 

PCI DSS v4.0 outlines specific goals and requirements for conducting intrusion tests. This reinforces the importance of pentesting as an integral part of compliance with the standard. 

One of the key aspects is frequency. Pentests must be conducted at least once a year and whenever significant infrastructure changes occur — such as modifications to firewalls, routing systems, applications, or any component that could impact the security environment. 

Additionally, the scope of testing must be comprehensive. It should cover the entire Cardholder Data Environment (CDE), including all systems, networks, and components connected to it, whether internal or external. Each test must be thorough, as any integration point could become an attack vector. All potential paths an attacker could exploit to access sensitive data must be evaluated. 

The required types of tests include both internal and external pentests, focusing on web applications and network infrastructure. These tests aim to uncover real vulnerabilities that could be exploited by either external actors or internal threats. 

Finally, the methodology used must be well-documented and structured. It should include clear steps for planning, execution, and reporting, as guided by the PCI Security Standards Council (PCI SSC). 

Steps to Define the Scope of a PCI DSS-Aligned Pentest 

Defining the scope of a pentest aligned with PCI DSS involves several essential steps to ensure both compliance and the effectiveness of the testing process. 

The first step is identifying the Cardholder Data Environment (CDE), which includes all systems that directly handle cardholder data — such as servers, databases, networks, and payment devices. In the case of an e-commerce platform, for example, this would involve web servers, payment gateways, and order management databases. 

The second step involves including systems that are connected to the CDE. Even if only indirectly involved, these must be assessed to avoid vulnerabilities caused by poorly segmented integrations. This includes, for instance, backup servers that have access to sensitive data, even if they do not process the data directly. 

The third step is mapping the data flows — from initial capture through processing to storage. For example, data from an online transaction may leave the customer's browser, pass through the payment gateway, and eventually be stored in an ERP system. 

Finally, a review of third-party services involved in the data flow — such as payment platforms and cloud providers—is conducted. These vendors must also be evaluated for their compliance with PCI DSS, ensuring they meet the applicable security requirements. 

This includes, for example, cloud environments such as AWS instances that host systems with access to cardholder data. While AWS is already PCI DSS certified for the infrastructure it provides, it is the organization’s responsibility to ensure the secure configuration of the environment. These steps ensure that all parties involved in processing sensitive data are properly tested and aligned with PCI DSS guidelines. 

How Our Pentest Solution Can Help 

Integrating pentesting into the PCI DSS v4.0 compliance process goes far beyond simply meeting a requirement. This practice enables organizations to: 

• Anticipate vulnerabilities before they are exploited by attackers and APT (Advanced Persistent Threat) groups 

• Technically validate the effectiveness of implemented security controls 

• Significantly reduce the risk of security incidents 

It also demonstrates, in practice, the organization's commitment to safeguarding customer data, as well as the information of acquirers and card brands. 

In an increasingly complex landscape filled with sophisticated cyber threats, prevention must be ongoing. Conducting intrusion tests regularly—using well-defined scopes and consistent methodologies—remains one of the most effective ways to protect payment environments and ensure compliance with industry standards. 

At iT.eam, we have conducted intrusion tests for various organizations seeking to align their security posture with PCI DSS v4.0, both for compliance and audit readiness. Our hands-on experience shows that a well-executed pentest is far more than a compliance requirement — it’s a strategic tool to identify real vulnerabilities before they’re exploited, validate implemented controls, and strengthen overall security. 

Our reports are clear, objective, and audit-ready. As a result, they not only help reduce risks but also reinforce the trust of customers, partners, acquirers, and card brands. 

By partnering with iT.eam, you ensure proven security and compliance. Speak with one of our specialists and schedule a consultation about our pentest service!