Compliance Briefing — March 31, 2025
PCI DSS 4.0 future-dated requirements become mandatory on 31 March 2025, ending the transition period from v3.2.1 and adding new authentication, logging, and risk management controls for cardholder data environments.
Executive briefing: The PCI Security Standards Council confirms as the end of the v3.2.1 transition. All entities that store, process, or transmit cardholder data must implement PCI DSS 4.0 requirements, including stronger authentication, targeted risk analyses, expanded logging, and e-commerce script integrity monitoring. QSAs will assess against 4.0 for ROC/SAQ submissions after the deadline.
Key risk themes
- Authentication strength. Multi-factor authentication now applies to all access into the CDE, closing legacy console gaps.
- Visibility and tamper detection. Script inventory and integrity checks for payment pages are required to address skimming attacks.
- Risk tailoring. Targeted risk analyses per requirement can expose control deviations; missing documentation will trigger assessor findings.
Operational priorities
- Gap closure. Re-run readiness assessments against 4.0, focusing on MFA scope, centralized logging, and service provider attestation updates.
- Evidence readiness. Stage screenshots, configs, and risk analyses for QSA fieldwork; update SAQ templates for merchants.
- Third-party assurance. Confirm service providers’ Attestation of Compliance (AOC) coverage for 4.0 requirements, especially remote access and monitoring.
Enablement moves
- Notify business owners of the March 2025 cutoff and planned maintenance windows for control changes.
- Update payment page CSP and subresource integrity checks to satisfy 6.4.3/11.6.1 requirements.
- Train operations teams on ongoing targeted risk analysis cadence to prevent documentation drift.
Sources
Zeph Tech prepares payment environments for PCI DSS 4.0 by closing authentication, logging, and script integrity gaps ahead of Q2 2025 assessments.
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