PCI DSS 4.0MigrationRisk Assessment
Leading PCI DSS 4.0 Migration Across Multiple Entities
Challenge
PCI DSS 4.0 introduced significant changes to the compliance standard: new requirements around authentication, encryption, and continuous monitoring, along with a shift toward customized validation approaches. The organization needed to assess the gap across multiple entities while maintaining existing Level 1 compliance.
Approach
- Conducted a comprehensive gap analysis mapping every 4.0 requirement change against existing controls
- Developed a prioritized remediation roadmap with timeline, resource allocation, and risk ranking
- Coordinated with engineering, IT, and executive leadership to align remediation with operational capacity
- Maintained communication with QSA throughout the transition to validate approach and avoid surprises during audit
- Managed the transition across multiple entities simultaneously, each with different control maturity levels
Outcome
- Gap assessment completed and remediation roadmap delivered to executive leadership
- Remediation executing on schedule with clear ownership and tracking
- No disruption to existing PCI DSS Level 1 certification during transition
- QSA relationship strengthened through proactive engagement on 4.0 readiness