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Pablo Gallardo's Blog
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Differences between PCI DSS 3.2.1 and 4.0

PCI DSS is an information security standard for organizations that handle branded credit cards from the major card schemes. You can check a general post about PCI DSS on this post.

As the standard is updated regularly, there are different versions of this standard.

PCI DSS 3.2.1 was issued on May 2018. Valid PCI DSS audits can be done with this version until March 2024.

PCI DSS 4.0 was issued on March 2022.

This post summarizes the differences between PCI DSS 3.2.1 and 4.0. It is not intended as a through analysis of the topic, but as a quick overview.

Differences between PCI DSS 3.2.1 and 4.0

Below you can find a brief overview of the new requirements, point by point.

X.1.2. Roles and responsibilities must be defined (in 3.2.1 there was only that known) (in previous version, it was required that the team was familiars with roles and responsibilities).

As a suggestion, it can be implemented through a RASCI matrix for each role and task mentioned in PCI DSS requirements.

12.5.2. Scope must be documented and updated annually.

It must be specifically defined through inventories, etc.

12.9.2. Service providers must support requirement compliance. [applies only to service providers]

3.2.1. All authentication data can be stored, as long as they are necessary

3.3.2. Sensitive Authentication Data (SAD) must be solidly encrypted.

3.3.3. It is a mix of 3.2.1. and 3.3.2 [applies only to Service providers]

3.5.1.1. Simple hash or salted hashes are no longer required. HMAC (hash message authentication code) must be used. Some NIST SP 800 standards (107r1, 38B and 38D) are specified.

3.5.1.2. Non-SAD data that can be stored externally on removable media (USB drives, DVDs, etc.) or non-removable media (backup tapes, internal disks).

3.6.1.1. [applies only to Service providers] Avoid using same cryptographic keys on production and test environemnts

4.2.1. Certificates used to protect PAN must be valid and up-to-date

4.2.1.1. Keep and inventory of all passwords and certificates used to protect PAN

5.3.3. When using removable media, antivirus must be triggered as soon as it is connected or all the time while USB is connected

5.4.1. Controls to protect from phising must be implemented

6.3.2. Inventory of all bespoken software

6.4.2. All public applications needs an annual code review and a WAF (web application firewall)

6.4.3. All scripts run in navigator must be reviewed and listed in an inventory

7.2.4. All acconts must be reviewed on a semiannual basis

7.2.5. System accounts (in opposition to user accounts) have specific requirements

8.3.6. Password requirements: alphanumerical, and length of 12 characters or 8 when it is not technically pheasible

8.3.10.1. [applies only to service providers] Change password each 90 days

8.4.2. All users accessing to CDE (cardholder data environment) must use MFA (multi factor authenticatoin)

8.6.2. Passwords cannot be stored on unsafe files

8.6.3. Passwords must be securely protected

9.5.1.2.1. Risk analysis must be applied to POI devices

10.4.1.1. An automatic tool to analyze logs is required

It means that a SIEM must be used.

10.4.2.1. The frequency of log review depends on risk analysis

An inventory of assets that require risk analysis is convenient

10.7.2. and 10.7.3. All control system must be monitored and should have implemented alerts. Previously, this requirement was only required for serivce providers

11.3.1.1. Vulnerabilities below high and critical must be solved in 90 days, and they must be reviewed

11.3.1.2. Vulnerability scans must be authenticated

11.4.7. [applies only to service providers] Service providers providers must facilitate external pentesting

11.5.1.1. [applies only to service providers] Prevent or detect covered channels

11.6.1. Monitor changes using HTTP headers

12.3.1. Details about what risk analysis content

12.3.3. Encryption algorithms must be reviewed annually.

12.3.4. Hardware and software technologies must be reviewed annually

12.5.2.1.and 12.5.2.2. [applies only to service providers] scope must be reviewed semiannualy

12.6.2. Awaraness program must be reviewed annualy

12.6.3.1. and 12.6.3.2. Training related to threats and vulnerabilities

12.10.4.1. Staff skills is proportional to result of risk analysis

12.10.5. Modification detection alert must be part of incident response processes

12.10.7. Incident response documented when PAN is not stored where expected

A1.1.1. Isolates provider and customer enviroments

A1.1.4. Monitor isolation in pentests

A1.2.3. Customer notification of incidents

A3.3.1 Automatic review of audit record and automatic code reviews must be incorporated into system monitoring

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External references

pmgallardo

About pmgallardo

I studied Computer Science at University of Salamanca. Since then, I have been working first as developer and then as SAP consutant. This blog is about problems I dealt when using computers, and more important, the solutions I found. Whenever I am on an issue and suddenlly I have a flash that leads me to a solution, I document my discoveries in a post.

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