A PCI DSS gap assessment (sometimes called a PCI gap analysis) examines a company’s cardholder data environment (CDE) to determine compliance with the Payment Card Industry Data Security Standard (PCI DSS). A qualified security assessor (QSA) performs the assessment.

An information security framework, the PCI DSS aims to help merchants and service providers protect credit and debit card transactions from data breaches. However, PCI DSS isn’t a law or regulation but rather an industry mandate that applies to all organizations that store, process, and/or transmit cardholder data.

A PCI gap assessment helps companies spot any technology, process, and administrative gaps in their cybersecurity programs, particularly regarding their procedures and controls for handling customers’ card data. The PCI DSS gap analysis also helps organizations ensure that they are meeting their PCI compliance requirements.

Benefits of a PCI DSS Gap Analysis

Identifying Security Weaknesses: A PCI DSS gap analysis systematically reviews your current security posture against the stringent requirements of the PCI DSS. It helps identify areas where your security measures are lacking, allowing you to understand where improvements are needed to protect sensitive cardholder data effectively.

Prioritizing Compliance Efforts: By pinpointing specific areas of non-compliance, a gap analysis allows you to prioritize remediation efforts based on the severity and risk associated with each gap. This ensures that the most critical vulnerabilities are addressed first, optimizing resource allocation and effort.

Minimizing Risk of Data Breach: By proactively identifying and addressing gaps, you significantly reduce the risk of data breaches and the associated financial and reputational damage. A gap analysis is a proactive measure to safeguard against potential security incidents.

Streamlining Compliance Process: Understanding exactly where you stand makes the path to full compliance more straightforward. A gap analysis provides a clear roadmap of the steps needed to achieve and maintain compliance, making the process more efficient and manageable.

Avoiding Fines and Penalties: By ensuring that all PCI DSS requirements are met, a gap analysis helps avoid costly fines and penalties associated with non-compliance. It’s an investment in your business’s financial and reputational well-being.

PCI DSS Gap Analysis vs. Readiness Assessment

PCI DSS Gap Analysis: This is a detailed and technical review of your current security controls against the specific requirements of the PCI DSS. The primary focus is on identifying the “gaps” between your current practices and the standard’s requirements. It’s a more granular approach that provides specific insights into deficiencies and required improvements.

Readiness Assessment: This is often a broader and more strategic evaluation of your preparedness to undertake the PCI DSS certification process. It assesses not just your current compliance status but also your organizational readiness, including staff awareness, resource allocation, and overall capability to implement necessary changes.

While both are critical in the journey towards PCI DSS compliance, a gap analysis is more detailed and focused on the specifics of the standard, while a readiness assessment is broader and considers organizational readiness and strategic planning.

When Should an Organization Complete a PCI DSS Gap Analysis?

Before Initial Certification: If you’re pursuing PCI DSS certification for the first time, conducting a gap analysis early in the process is crucial. It sets a clear baseline of your current compliance status and what needs to be done.

After Significant Changes: If your organization undergoes significant changes, such as introducing new payment systems, merging with another company, or changing operational processes, a new gap analysis can help ensure these changes haven’t introduced new compliance gaps.

Regularly as a Best Practice: Even if there haven’t been significant changes, regularly conducting a gap analysis (annually or bi-annually) is a best practice. It ensures ongoing compliance and keeps up with any updates to the PCI DSS requirements.

The Three Fundamental Components of a Gap Analysis

Current State Analysis: A detailed examination of your existing security controls, processes, and technologies. This includes reviewing current policies, procedures, and technical safeguards in place.

Future State Definition: A comprehensive understanding of the PCI DSS requirements and what needs to be in place to achieve full compliance. This involves interpreting the standard’s requirements in the context of your specific operational environment.

Gap Identification: The core component where you identify the discrepancies between the current state and the required future state. This involves listing each area where your practices do not meet the standards set by PCI DSS and understanding the implications of these gaps.

Requirements for Completing the PCI Gap Analysis Process

In-depth Knowledge of PCI DSS: Understanding the intricacies of all 12 requirements and their sub-requirements is crucial. Often, organizations enlist the help of a Qualified Security Assessor (QSA) for their expertise in this area.

Detailed Documentation: Having comprehensive documentation of your current processes, data flows, and security measures is essential. This will serve as the basis for the current state analysis.

Access to Key Personnel: The process will involve discussions and interviews with various stakeholders, including IT staff, security officers, and department heads. Their cooperation and input are vital.

A Methodical Approach: A structured methodology to conduct the analysis is necessary to ensure no aspect is overlooked. This typically involves checklists, interviews, system inspections, and process reviews.

Remediation Plan: Post-analysis, you’ll need to develop a remediation plan to address the identified gaps. This should include timelines, responsibilities, and resource allocations.

Conducting a PCI DSS gap analysis is a crucial step in understanding and enhancing your organization’s security posture. It’s not just about compliance; it’s about protecting your customers, your reputation, and your business.

The Gap Analysis

The gap analysis should focus on the 12 PCI DSS requirements:

  1. Install and maintain a firewall configuration to protect cardholder data.
  2. Do not use vendor-supplied defaults for system passwords and other security parameters.
  3. Protect stored cardholder data.
  4. Encrypt transmission of cardholder data across open, public networks.
  5. Protect all systems against malware and regularly update anti-virus software or programs.  
  6. Develop and maintain secure systems and applications.
  7. Restrict access to cardholder data by business need-to-know.
  8. Identify and authenticate access to system components
  9. Restrict physical access to cardholder data.
  10. Track and monitor all access to network resources and cardholder data.
  11. Regularly test security systems and processes (such as with penetration testing).
  12. Maintain a policy that addresses information security for all personnel. 

A PCI Data Security Standard gap assessment sets the foundation for a PCI DSS compliance program. It helps a merchant or service provider determine its compliance status and improve security by spotlighting areas that need immediate attention

A PCI gap assessment helps a company understand its PCI environment at the control level. It’s used to help a company understand how ready it is for its PCI audit or self-assessment questionnaire (SAQ) and to identify any inadequate controls that impact the organization’s PCI DSS compliance.

Steps in the PCI Gap Assessment

A company should begin its PCI gap assessment by determining its scope, i.e., decide what area(s) to focus on, where it needs to improve, along with collecting the necessary information to create a good remediation plan. Many organizations hire external quality security assessors (QSAs) to help with their PCI gap assessments. 

After determining the scope of the PCI gap assessment, the company should accurately define its goals and describe the services, areas, and equipment that it plans to assess. It also makes sense to decide how long the gap analysis will take and communicate that information to team members.

Next, it’s time for the organization to identify the areas it needs to improve or change and then work out a plan to remediate those areas.

Finally, the company has to resolve or remediate the gaps it found during the PCI gap assessment.

If a company hires a QSA to conduct the PCI gap assessment, the QSA will write up a final report that contains a summary of their findings and information about the status of the company’s controls. The QSA will also recommend ways to remediate any issues.

Find PCI Gaps Automatically

A PCI DSS gap assessment or gap analysis can take a long time and much work to complete. A good governance, risk management, and compliance solution can make the job much easier, however.

ZenGRC’s unlimited self-audits help you find and stay on top of PCI compliance gaps.  The prioritizing and workflow tracking features help you feel confident that, come audit time, you’ll attain that coveted Report on Compliance (RoC) with ease.

Worry-free PCI DSS compliance is the Zen way. Contact us now for a free consultation, and find out why many of the world’s leading companies rely on ZenGRC.

Schedule a demo to learn how we can help guide your organization to confidence in infosec risk and compliance.