Over the course of my time as a Qualified Security Assessor (QSA), I’ve supported numerous organizations through PCI Self-Assessment Questionnaires and Reports on Compliance. One consistent takeaway I’ve noticed: a handful of practical, often straightforward strategies can significantly reduce the complexity and burden of a PCI assessment.
Outlined below are five best practices that consistently help organizations simplify their PCI process—resulting in faster, more efficient, and less stressful assessments.
1. Manage the PCI Assessment as a Formal Project
Even the most straightforward PCI engagements require coordination, clear timelines, and defined deliverables. Applying formal project management methodologies, such as those from the Project Management Institute (PMI), can help ensure the process remains structured and on track.
Key elements of effective PCI Assessment project oversight:
- Executive Sponsorship: Senior leadership involvement helps prioritize the project, drive accountability, and accelerate decision-making.
- Dedicated Project Owner: Assigning a single internal point of contact improves coordination and communication across teams and with your QSA.
- Consistent Stakeholder Meetings: Regular check-ins keep the assessment aligned with project timelines and allow for early identification of risks or bottlenecks.
- Defined Accountability: PCI requires input from multiple stakeholders. Ensuring each participant understands their responsibilities—and is held accountable—can prevent delays caused by missing documentation or unavailability.
2. Minimize the Cardholder Data Environment (CDE)
The size and complexity of your CDE directly affect the scope of your PCI assessment. Reducing the CDE—and, by extension, your organization’s exposure to cardholder data—can streamline compliance efforts significantly.
Common techniques to reduce scope:
- Network Segmentation: Operate by the simple rule of thumb – “Systems that can communicate with the CDE are part of the CDE.” Isolating the CDE to a secure, segmented environment minimizes the number of systems subject to PCI requirements.
- PCI-Validated Solutions: Implementing validated solutions—such as Point-to-Point Encryption (P2PE)—reduces scope, provided implementation aligns with associated Secure Installation Guides.
- Outsourcing to PCI-Compliant Third Parties: Partnering with third-party service providers (TPSPs) that handle CHD-related functions can shift a significant portion of the compliance burden. Organizations must, however, actively monitor their TPSPs’ compliance status, as this is a PCI requirement in itself.
3. Maintain Comprehensive and Accurate Documentation
Incomplete or outdated documentation is one of the most common causes of assessment delays. Ensuring your records are current and aligned with the defined scope is essential to avoiding late-stage complications.
Critical documentation to keep updated:
- Network and Data Flow Diagrams (1.2): These foundational documents must clearly depict all relevant system components and data flows within the CDE.
- Hardware and Software Inventory (12.5.1): All system components in scope should be accurately reflected, including version numbers.
- Point of Interaction (POI) Listings (9.5): Merchants with card-present transactions must maintain an up-to-date inventory of POI devices.
- Third-Party Service Provider Inventory (12.8.1): All TPSPs that access or could impact the security of the CDE must be documented and monitored for compliance.
- Payment Page Script Inventory (6.4.3): As of April 1, 2025, organizations are required to maintain an inventory of payment page scripts, including written justification for each.
4. Set Reminders for Time-Sensitive Controls
While many PCI sub-requirements can be addressed during the assessment window, certain controls must be executed on a strict timeline. Failure to meet those deadlines can have serious implications for compliance.
Recommended cadence for control reminders:
- Quarterly:
- Internal vulnerability scans (CDE)
- ASV scans
- Rogue wireless access point scans
- Confirmation of security control effectiveness
- Semi-Annual:
- Network segmentation testing
- NSC ruleset reviews
- Annual:
- Scope validation (merchants)
- Penetration testing
- Security policy updates
- Information security and secure development training
- Third-party compliance reviews
- Incident response testing
I recommend utilizing calendar-based reminders to ensure these requirements are completed in accordance with PCI timelines.
5. Engage a Qualified Security Assessor (QSA)
Although the PCI Council offers extensive documentation, interpreting nuanced requirements and applying them to a specific environment can be challenging. An experienced QSA provides clarity, identifies risk areas, and recommends practical solutions tailored to your organization.
QSAs are certified by the PCI Council and must maintain their credentials through annual training, continuing professional education (CPE), and re-examination. In addition to ensuring accurate interpretation of requirements, a knowledgeable QSA can often help identify the most efficient path to compliance.
Final Thoughts on PCI Assessment Best Practices
PCI compliance can be complex, but with proper planning, the right tools, and expert guidance, it becomes significantly more manageable. By formalizing the assessment process, reducing scope, maintaining accurate documentation, meeting key control deadlines, and working with a skilled QSA, your organization will be well-positioned for a successful PCI assessment.
Contact Us for PCI Compliance Support
For expert guidance and assistance with your PCI compliance efforts, don't hesitate to reach out to Justin Bonk with Freed Maxick Risk Advisory Services at justin.bonk@freedmaxick.com or via the form below. Secure your organization's future by ensuring adherence to PCI standards and safeguarding sensitive data.