PCI controls: A strategic guide to payment card security implementation

Payment Card Industry Data Security Standard (PCI DSS) controls are more than regulatory checkboxes; they form the foundation of a strategic security investment that protects both customer data and business reputation. 

For organizations processing payment card information, implementing robust PCI controls creates measurable value through reduced breach risk, streamlined audit processes, and enhanced customer trust.

The financial impact of PCI non-compliance extends well beyond potential fines. Data breaches involving payment card information cost organizations an average of $4.88 million per incident (IBM), while the reputational damage can persist for years. Conversely, organizations that view PCI controls as strategic security investments often discover these measures strengthen their overall cybersecurity posture and create efficiencies across multiple compliance frameworks.

“We see organizations treating PCI compliance as an annual fire drill, but the most successful clients view it as foundational security infrastructure. When you implement PCI controls strategically, you’re not just protecting payment data—you’re building the security backbone that supports sustainable business growth.” Chris Strand, Chief Strategy Officer, Factor Cybersecurity

PCI controls naturally complement other frameworks such as SOC 2, ISO 27001, and NIST Cybersecurity Framework, enabling organizations to build comprehensive security programs that satisfy multiple standards simultaneously. This integrated approach transforms compliance from a series of isolated audits into a cohesive security strategy that supports business growth.

Key takeaways

  • PCI controls create strategic business value by reducing breach risk, improving operational efficiency, and enabling multi-framework compliance integration
  • The six PCI control objectives encompass 12 specific requirements that work together to protect cardholder data throughout its lifecycle
  • Successful implementation requires a phased approach that integrates with existing security infrastructure and leverages automation to maintain continuous compliance

What are PCI controls and requirements?

Understanding PCI DSS requires viewing its six control objectives as interconnected components of a comprehensive payment security strategy. Rather than isolated compliance requirements, these objectives create a framework that reduces business risk while integrating seamlessly with existing security investments.

The PCI DSS framework organizes security requirements into logical groupings that address the most critical aspects of payment card data protection. Each control objective contains specific requirements that, when implemented effectively, create multiple layers of defense against both external threats and internal vulnerabilities.

1. Build and maintain a secure network and systems

This foundational control objective establishes the security perimeter that protects all payment processing activities. Effective network security creates the baseline protection upon which all other controls depend.

Requirements:

  • Install and maintain a firewall configuration to protect cardholder data
  • Do not use vendor-supplied defaults for system passwords and other security parameters

Network security controls extend beyond basic firewall management to encompass comprehensive network segmentation, secure configuration management, and regular security updates. Organizations must create documented standards for all network components and maintain inventories of systems that process, store, or transmit cardholder data.

2. Protect cardholder data

Data protection represents the core purpose of PCI DSS—ensuring that sensitive payment information remains secure regardless of where it resides or how it moves through organizational systems.

Requirements:

  • Protect stored cardholder data
  • Encrypt transmission of cardholder data across open, public networks

Effective cardholder data protection requires understanding data flows, implementing appropriate encryption methods, and establishing clear data retention policies. Organizations must identify all locations where cardholder data exists and apply consistent protection measures across their entire environment.

3. Maintain a vulnerability management program

Proactive vulnerability management prevents security weaknesses from becoming exploit opportunities. This control objective emphasizes continuous improvement and systematic risk reduction.

Requirements:

  • Protect all systems against malware and regularly update anti-virus software or programs
  • Develop and maintain secure systems and applications

Vulnerability management extends beyond patch management to include secure development practices, regular security testing, and comprehensive malware protection. Organizations must establish processes that identify, prioritize, and remediate security vulnerabilities across their entire payment processing environment.

4. Implement strong access control measures

Access controls ensure that only authorized individuals can access cardholder data, implementing the principle of least privilege across all systems and processes.

Requirements:

  • Restrict access to cardholder data by business need to know
  • Identify and authenticate access to system components
  • Restrict physical access to cardholder data

Strong access controls require role-based access management, multi-factor authentication, and comprehensive user account management. Organizations must maintain detailed records of who has access to what systems and regularly review these permissions to ensure they remain appropriate.

5. Regularly monitor and test networks

Continuous monitoring provides visibility into security events and enables rapid response to potential threats. This control objective emphasizes the importance of ongoing security oversight.

Requirements:

  • Track and monitor all access to network resources and cardholder data
  • Regularly test security systems and processes

Effective monitoring requires comprehensive logging, regular log review, and systematic security testing. Organizations must implement security information and event management (SIEM) capabilities and conduct regular penetration testing to validate their security controls.

6. Maintain an information security policy

Comprehensive security policies provide the governance framework that ensures consistent security practices across the organization and with third-party service providers.

Requirement:

  • Maintain a policy that addresses information security for all personnel

Security policies must address all aspects of cardholder data protection, including employee responsibilities, incident response procedures, and vendor management requirements. These policies serve as the foundation for security awareness training and operational procedures.

How do PCI controls integrate with SOC 2, ISO 27001, and NIST?

Organizations typically operate under multiple compliance frameworks simultaneously. PCI controls share significant overlap with other security standards, creating opportunities for integrated compliance approaches that reduce audit burden while strengthening overall security posture.

  • SOC 2: PCI access controls align closely with SOC 2 Trust Service Criteria, particularly in areas of logical and physical access controls, system operations, and change management. Organizations can leverage PCI authentication requirements to satisfy SOC 2 access control objectives, while PCI monitoring requirements support SOC 2 system monitoring criteria. The documentation and testing requirements for both frameworks often produce evidence that satisfies multiple audit needs.
  • ISO 27001: ISO 27001’s information security management system (ISMS) approach complements PCI’s specific technical requirements. PCI vulnerability management aligns with ISO 27001’s information security incident management, while PCI policy requirements support ISO 27001’s documentation and awareness requirements. Organizations implementing both frameworks can develop integrated risk management processes that address payment card security within their broader information security program.
  • NIST CSF: The NIST Cybersecurity Framework’s identify, protect, detect, respond, and recover functions map directly to PCI control objectives. PCI network security requirements support NIST’s protect function, while PCI monitoring requirements align with the detect function. Organizations using NIST as their primary cybersecurity framework can implement PCI controls as specific tactical requirements within their broader strategic security program.

This multi-framework approach enables organizations to create comprehensive security programs that satisfy multiple regulatory requirements through integrated processes and shared evidence collection.

Organizations implementing strategic PCI approaches often discover significant cost savings beyond compliance. For example, Forage saved over $100,000 in development costs by consulting with PCI experts during their product design phase, avoiding costly remediation cycles later.

“I was able to ask the auditors about PCI requirements upfront before spending engineering resources to build the product. That was genuinely invaluable.” – Rob Gormisky, Information Security Lead at Forage

How do you implement PCI controls in your organization?

Successful PCI implementation requires a strategic approach that considers organizational capabilities, existing security infrastructure, and business requirements. Effective implementation focuses on building sustainable processes rather than achieving short-term compliance milestones.

Phased implementation approach for organizations

Begin with foundational controls that establish basic security hygiene: Network security, access controls, and policy development. These elements create the infrastructure necessary for more complex requirements such as encryption implementation and continuous monitoring.

Phase two focuses on data protection and vulnerability management, building upon the secure foundation established in phase one. The final phase implements comprehensive monitoring and testing capabilities that validate the effectiveness of all other controls.

Each implementation phase should include pilot programs that test new processes in controlled environments before organization-wide deployment. This approach identifies potential challenges early and allows for process refinement before full-scale implementation.

Automation opportunities and technology stack considerations

Modern PCI implementation leverages automation to maintain continuous compliance and reduce manual effort. Compliance platforms provide automated log collection and analysis, while vulnerability scanning tools enable continuous security assessment. Configuration management tools ensure consistent security settings across all systems, and identity management platforms automate user access provisioning and deprovisioning.

Cloud-native organizations benefit from security tools that integrate with existing DevOps pipelines, enabling security controls to be implemented as code. This approach ensures that security requirements are automatically applied to new systems and applications as they are deployed.

Audit preparation and evidence management strategies

Effective evidence management begins during the design phase of control implementation. Organizations should establish documentation standards that automatically capture the evidence required for PCI assessments. Centralized evidence repositories enable efficient audit preparation and support multiple compliance frameworks simultaneously.

Regular internal assessments validate control effectiveness and identify potential gaps before formal audits. These assessments should mirror the external audit process, ensuring that all required evidence is available and properly documented.

What are the most common PCI implementation mistakes?

Understanding common implementation failures enables organizations to avoid costly mistakes and build more effective security programs from the beginning.

Why manual processes fail at scale

Manual compliance processes become increasingly unreliable as organizations grow and systems become more complex. 

  • Manual log review cannot keep pace with the volume of security events generated by larger-scale environments, while manual configuration management creates inconsistencies that lead to security gaps. 
  • Human error rates increase dramatically when compliance tasks are performed manually across large numbers of systems.

Organizations that rely on manual processes often discover that their compliance status is unclear between formal assessments, creating uncertainty about their actual security posture and potential exposure to regulatory penalties.

The business impact of effective PCI implementation extends beyond compliance checkboxes. ‘SOC 2 is for sales, and PCI is for partnerships. They unlock different things for us. Without SOC 2 compliance, we would not have our largest enterprise customer today,’ notes Rob Gormisky, Information Security Lead at Forage, highlighting how strategic compliance implementation directly enables revenue growth.”

The hidden costs of audit loops and remediation cycles

Ineffective initial implementations often result in repeated audit cycles that significantly increase compliance costs. Each audit finding requires remediation efforts that consume internal resources and extend project timelines. Organizations may find themselves in continuous audit loops, never achieving stable compliance status.

These cycles often result from inadequate initial scoping, insufficient attention to evidence management, or failure to integrate PCI requirements with existing business processes. The cumulative cost of repeated audits and remediation efforts often exceeds the investment required for effective initial implementation.

Building sustainable, adaptable control frameworks

Sustainable PCI compliance requires controls that adapt to changing business requirements and evolving threat landscapes. Rigid implementations that cannot accommodate new technologies or business processes inevitably require costly redesign efforts.

Effective frameworks incorporate flexibility through standardized processes that can be applied to new systems and applications. These frameworks emphasize automation and integration with existing operational processes, ensuring that compliance becomes a natural part of business operations rather than a separate overhead activity.

Why choose Thoropass for PCI DSS compliance?

Thoropass transforms PCI compliance from a painful audit exercise into a streamlined, continuous process that delivers measurable business value. Our purpose-built platform eliminates the endless audit loops that plague traditional compliance approaches, providing clear visibility into compliance status and automating evidence collection across multiple frameworks.

Organizations working with Thoropass typically reduce their compliance timeline by 75% while achieving more robust security postures than manual approaches deliver. Our experienced compliance experts guide implementation efforts, ensuring that PCI controls integrate effectively with existing security infrastructure and support broader business objectives.

The Thoropass platform enables multi-framework compliance strategies that leverage shared evidence and processes across PCI DSS, SOC 2, ISO 27001, and other standards. This integrated approach reduces overall compliance costs while creating comprehensive security programs that adapt to evolving business requirements.

Ready to learn more about how Thoropass can help your org bring audit and compliance into the same platform? Request a demo and talk to one of our experts

More FAQs

What is PCI control?

A PCI control is a specific security measure designed to protect cardholder data throughout its lifecycle. PCI controls encompass technical safeguards such as encryption and access restrictions, as well as operational procedures, including monitoring and testing requirements. These controls work together to create comprehensive protection for payment card information.

What does PCI stand for?

PCI stands for Payment Card Industry. The Payment Card Industry Data Security Standard (PCI DSS) was developed by major payment card brands, including Visa, Mastercard, American Express, Discover, and JCB, to establish consistent security requirements for organizations that process payment card transactions.

H3: What are the 12 PCI compliance requirements?

The 12 PCI compliance requirements are organized under six control objectives: 

  1. Install and maintain firewalls
  2. Change vendor-supplied defaults
  3. Protect stored cardholder data
  4. Encrypt data transmission
  5. Use anti-virus software
  6. Develop secure systems
  7. Restrict data access
  8. Assign unique IDs
  9. Restrict physical access
  10. Track access to data
  11. Test security systems
  12. Maintain security policies

H3: How long does PCI DSS implementation take?

PCI DSS implementation timelines vary significantly based on organizational complexity, existing security infrastructure, and chosen implementation approach. Organizations with mature security programs may achieve compliance within 3-6 months, while those requiring substantial infrastructure changes may need 12-18 months. Automated compliance platforms can reduce these timelines significantly compared to manual approaches.

What’s the difference between PCI controls and requirements?

PCI controls are the broader security objectives that protect cardholder data, while requirements are the specific technical and operational measures that implement these controls. The six PCI controls provide strategic direction, while the 12 requ

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