Achieving and maintaining PCI compliance certification is a non-negotiable requirement for any organization that processes, stores, or transmits cardholder data. As digital transactions grow in volume and complexity, so do the demands of Payment Card Industry Data Security Standards (PCI DSS). While compliance ensures the protection of sensitive payment data, the path to certification is often riddled with technical, procedural, and organizational challenges.
This blog outlines the most common obstacles companies encounter during the certification process and how they can be addressed to ensure a smooth and effective compliance journey.
Understanding the Scope of PCI Requirements
1. Incomplete Scoping of Systems
A major initial obstacle in achieving PCI compliance certification is inaccurately identifying the complete boundaries of the cardholder data environment. Many organizations underestimate the systems, devices, and third-party connections that fall under PCI DSS requirements.
Without proper scoping, compliance efforts become misaligned, increasing the risk of audit failure and exposing the organization to security vulnerabilities.
2. Misinterpreting PCI DSS Controls
Another challenge is the incorrect interpretation of PCI requirements. Different controls may apply depending on business size, transaction volume, or network architecture. Misunderstanding which controls are applicable can lead to either overcomplication or insufficient security controls—both of which can delay or prevent successful certification.
3. Legacy Systems and Infrastructure Gaps
Older systems often lack the necessary logging, access control, or encryption capabilities required by current PCI DSS standards. Upgrading or replacing such infrastructure can be time-consuming and costly but is often essential for full compliance.
Failure to address these technical limitations in time can derail an entire audit process.
4. Inconsistent Logging and Monitoring
PCI DSS requires real-time logging and continuous monitoring of access to systems handling cardholder data. Many companies struggle with implementing centralized logging solutions or ensuring logs are retained and reviewed properly.
Insufficient logging presents serious vulnerabilities by limiting the organization’s capacity to quickly identify and act on potential security threats.
5. Lack of Formal Policies and Procedures
Documented security policies are a core component of PCI certifications, yet many organizations operate with informal or outdated procedures. PCI assessors expect to see clear, up-to-date documentation that outlines security responsibilities, incident response plans, and employee awareness programs.
Without this documentation, even a technically secure environment may fail to meet compliance standards.
6. Insufficient Employee Training
Mistakes made by individuals continue to rank among the leading contributors to data compromise incidents. Ensuring that employees—especially those handling payment data—are well-informed about security policies and PCI requirements is crucial. Lack of structured training and awareness initiatives can create significant gaps in compliance.
7. Unverified Third-Party Compliance
Many organizations depend on external providers to manage tasks such as data handling, cloud infrastructure, or application creation. If these vendors do not meet PCI standards, it can jeopardize the entire certification process.
A robust third-party management program is essential to ensure that all partners meet the required security controls and have validated PCI certifications themselves.
8. Poor Change Control Practices
Organizations that do not follow formal change management processes often introduce risk unknowingly. Untracked system changes, updates, or configuration modifications can cause non-compliance, especially if they bypass security checks or impact cardholder data pathways.
Maintaining detailed change logs and testing updates before implementation is vital to maintaining ongoing PCI alignment.
Conclusion
Achieving PCI compliance certification demands more than just technical controls; it requires coordinated planning, structured processes, and a deep understanding of the PCI DSS framework. From scoping issues and legacy systems to documentation lapses and third-party risks, the challenges are varied and often complex.
Panacea Infosec supports enterprises across these challenges with dedicated compliance advisory, technical validation, and security services. Their offerings include support from audit preparation to testing, as well as services like those offered by a wireless penetration testing company—ensuring a holistic approach to risk and compliance management.