Everything you need to know about PCI DSS penetration testing

Visual of ethical hacking in lines of code

Oro provides content designed to educate and help audiences on their compliance journey.

If you’re going to beat a hacker, you have to learn to think like a hacker. PCI DSS penetration testing, or “pentesting” involves just that: It simulates real-world attacks to identify security weaknesses within an organization’s systems. 

These tests enable companies to gain valuable insights into their security posture and address any vulnerabilities before hackers have a chance to exploit them. One crucial aspect of this process is internal penetration testing, which focuses on identifying vulnerabilities within the organization’s internal network. By conducting a thorough pentest, organizations can ensure the security of their internal network.

With a proper penetration testing methodology in place, organizations can maintain PCI DSS compliance and ensure the security of their cardholder data environment.

Key takeaways

  • PCI DSS requires organizations to perform penetration testing for compliance and data protection
  • Different types of tests, such as black-box, white-box, and grey-box, are available to choose from
  • Testing frequency should be at least once a year, with best practices like continuous monitoring implemented for ongoing PCI DSS compliance

What is PCI DSS?

PCI DSS is a global security standard for organizations handling payment card data, aiming to protect cardholder information and reduce fraud. 

The standard comprises 12 requirements outlining the controls needed to secure cardholder data for merchants, service providers, and vendors, including the protection of critical systems. Adherence to PCI DSS requirements demonstrates an organization’s commitment to maintaining a secure environment and safeguarding sensitive data.

Resource: Penetration Test Guidance Special Interest Group – PCI Security Standards Council

Why is PCI penetration testing crucial for compliance?

PCI DSS penetration testing plays a pivotal role in achieving PCI DSS compliance by helping organizations identify and remediate security vulnerabilities in their internal and external network and systems. 

The penetration test process goes beyond vulnerability scanning, which focuses on identifying potential security weaknesses by actively exploiting security controls to bypass them. To ensure impartiality and technical expertise, the penetration tester is ideally an external resource with no involvement in building or managing the systems of the cardholder data environment.

Regular penetration tests offer several benefits for organizations:

  • They help organizations stay compliant with PCI DSS requirements
  • They provide valuable insights into the organization’s security posture
  • They enable organizations to address potential vulnerabilities before they can be exploited by malicious actors

Pentesting versus vulnerability scanning

It’s important to recognize that penetration testing is a separate activity from a vulnerability scan. Both are essential components of a comprehensive security strategy, but they serve different purposes and offer unique insights into an organization’s security posture.

As we’ve discussed, penetration testing is a proactive approach to identifying vulnerabilities within an organization’s systems. It simulates real-world attacks to reveal potential weaknesses in the system. It’s a hands-on, in-depth process that aims to exploit vulnerabilities to determine their potential impact on the system if they were exploited by a malicious actor. It’s a crucial component for PCI DSS compliance and is typically performed by external security experts.

On the other hand, vulnerability scanning (including external vulnerability scans) is a more automated process that systematically checks systems for known vulnerabilities. It is less hands-on than penetration testing and does not involve the actual exploitation of vulnerabilities. Instead, it identifies, ranks, and reports vulnerabilities that automated tools can detect. While it doesn’t replace the need for penetration testing, it is a valuable tool for maintaining ongoing security awareness within an organization.

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The PCI penetration test process

A comprehensive PCI DSS penetration test consists of several key components, including scoping, methodology, and reporting. Scoping involves defining the boundaries and limitations of the test, focusing on systems within the cardholder data environment.

The methodology refers to the approach and techniques used during the test, following industry best practices and PCI DSS requirements. Lastly, reporting entails documenting the findings of the test, including vulnerabilities, potential impacts, and remediation recommendations.

Together, these components ensure a thorough and effective assessment of an organization’s security posture.


“The scope of a penetration test, as defined in PCI DSS Requirement 11.3, must include the entire CDE perimeter and any critical systems that may impact the security of the CDE as well as the environment in scope for PCI DSS. This includes both the external perimeter (public-facing attack surfaces) and the internal perimeter of the CDE (LAN-LAN attack surfaces).”

PCI Security Standards Council

In the scoping phase of PCI DSS penetration testing, organizations must determine the boundaries and limitations of the test, focusing on systems within the cardholder data environment (CDE) and any structures that could impact CDE security. Penetration testing does not include systems that are not connected to the cardholder data environment. Such systems are considered out of scope.

A clearly defined test scope ensures all relevant systems and components are assessed for potential vulnerabilities, enabling organizations to prioritize their security efforts and maintain PCI DSS compliance.


The methodology used in PCI DSS penetration testing should follow industry best practices and adhere to the specific requirements set forth by the PCI DSS standard. A thorough methodology is required to ensure all potential vulnerabilities within the organization’s systems are identified and addressed.  This includes:

  • Pre-engagement
    • Scoping
    • Documentation
    • Rules of engagement
    • Third-party hosted / cloud environments
    • Success criteria
    • Review of past threats and vulnerabilities
  • Engagement: Penetration testing
    • Application layer
    • Network layer
    • Segmentation
    • What to do when cardholder data is encountered
    • Post-exploitation
  • Post-engagement
    • Remediation best practices
    • Retesting identified vulnerabilities
    • Cleaning up the environment

Penetration testing may involve a combination of manual and automated techniques, as well as various testing methodologies, such as black-box, white-box, and grey-box testing (discussed in more detail in a later section).

Multiple industry-accepted methodologies may provide additional guidance on penetration testing activities, including but not limited to:


“The purpose of the report is to assist the organization in its efforts to improve its security posture by identifying areas of potential risk that may need to be remediated. Merely reporting lists of vulnerabilities is not helpful in this endeavor and does not meet the intent of the penetration test. The report should be structured in a way to clearly communicate what was tested, how it was tested, and the results of the testing.”

PCI Security Standards Council

Reporting is a critical component of PCI DSS penetration testing, as it documents the findings of the test, including identified vulnerabilities, potential impacts, and recommended remediation measures. A clear and concise report enables organizations to prioritize their security efforts, implement measures to address identified vulnerabilities, and maintain PCI DSS compliance.

Different types of PCI DSS penetration tests

PCI DSS penetration tests can be conducted using various methodologies, each with its advantages and limitations. Understanding the differences between these testing methodologies can help organizations choose the most suitable approach for their specific needs and ensure a thorough and effective assessment of their systems.

Black-box testing

Black-box testing simulates an external attacker’s perspective, with limited knowledge of the target system. This approach enables penetration testers to assess the system’s security as an outsider would, identifying vulnerabilities that may not be apparent from an internal perspective.

While black-box testing can provide valuable insights into an organization’s security posture, it can also be time-consuming and resource-intensive, as testers must rely on trial and error to discover potential weaknesses. Despite these challenges, black-box testing remains a valuable tool in identifying vulnerabilities and ensuring the security of an organization’s systems.

White-box testing

White-box testing provides the tester with full knowledge of the target system, including access to source code, allowing for a more in-depth assessment of the organization’s security. This approach enables penetration testers to identify vulnerabilities that may be hidden within the system’s code or configuration settings, as well as potential weaknesses that may not be apparent from an external perspective.

By leveraging their knowledge of the system’s inner workings, white-box testers can more effectively identify and address security vulnerabilities, ensuring a comprehensive assessment of the organization’s security posture.

Grey-box testing

Grey-box testing combines elements of both black-box and white-box testing, providing partial knowledge of the target system to the penetration tester. This approach enables testers to:

  • Simulate real-world scenarios
  • Assess the system’s security from a more informed perspective
  • Maintain the element of uncertainty present in black-box testing

Grey-box testing can help uncover potential vulnerabilities that may be missed by either black-box or white-box testing alone, providing a more thorough assessment of an organization’s security posture. By incorporating elements of both testing methodologies, grey-box testing offers a balanced approach to penetration testing and ensures a comprehensive evaluation of an organization’s systems.

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Choosing the right penetration testing provider for PCI DSS compliance

Selecting the right penetration testing provider for PCI DSS compliance is critical to ensuring a thorough and effective assessment of your organization’s security posture.

Assessing qualifications and experience

When choosing a penetration testing provider for PCI DSS compliance, assess their qualifications and experience, including certifications, industry expertise, and a proven track record in PCI DSS penetration testing. Look for providers with certifications such as:  

  • Council of Registered Ethical Security Testers (CREST)
  • Offensive Security Certified Professional (OSCP)
  • Offensive Security Certified Expert (OSCE) 
  • Certified Information Systems Security Professional (CISSP)
  • Certified Ethical Hacker (CEH) 
  • GIAC Systems and Network Auditor (GSNA)

Also consider the provider’s experience with your industry and type of organization, as well as their history of successful PCI DSS penetration testing implementations.

Evaluating service offerings

It’s also important to evaluate the provider’s service offerings to ensure a comprehensive approach to security. Look for providers that offer remediation assistance, continuous scanning, and service-level agreements to help maintain ongoing compliance with PCI DSS requirements.

Consider the range of services offered by the provider, including:

  • Network penetration testing
  • Web application penetration testing
  • Mobile application penetration testing
  • Social engineering testing
  • Wireless penetration testing
  • Cloud penetration testing

PCI DSS penetration testing frequency

Regardless of the compliance level, the frequency of penetration testing is defined by requirements 11.3.1 and 11.3.2 of the PCI DSS document. External penetration testing should be conducted at least once a year for most organizations that store, process, or transmit payment card data.

In addition to these requirements, organizations should also conduct penetration testing after any significant changes to their systems, such as infrastructure upgrades, new application releases, or major system updates. Conducting regular penetration tests enables organizations to stay ahead of potential threats and maintain ongoing compliance with PCI DSS requirements.

Other best practices for ongoing compliance

To maintain ongoing PCI DSS compliance, organizations should also follow best practices, such as:

  • Continuous monitoring: Enables organizations to stay on top of potential security issues and address them quickly
  • Vulnerability management: Focuses on identifying and remediating security holes within the system
  • Employee training: Security awareness training ensures that all staff members are aware of security protocols and best practices

By implementing these practices, organizations can ensure that they are consistently meeting the requirements of PCI DSS and protecting sensitive customer data.

Resources and support for PCI DSS compliance

To learn more about PCI DSS compliance, check out these useful posts:

FAQs about penetration testing

Yes, PCI DSS requires penetration testing according to requirement 11.4, which states that “External and internal penetration testing is regularly performed.”

A PCI DSS penetration test is a security assessment designed to identify, exploit, and address vulnerabilities from both inside and outside an organization’s network environment. It looks for incorrectly configured software, firewalls, and operating systems that can result in security issues.

PCI DSS recommends annual penetration testing, as well as after any significant upgrade or modification.

PCI DSS penetration testing includes scoping, methodology, and reporting to thoroughly assess an organization’s security.

There are three main types of PCI DSS penetration tests: black-box, white-box, and grey-box. Each type has its own advantages and limitations for ensuring the security of credit card data.

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