Your PCI DSS Compliance Checklist for v4.0

Meeting new PCI DSS compliance standards may be difficult, but with the right solutions in play—and an efficient strategy—it is nowhere near too late. 

Many companies fail to realize that compliance with this latest Payment Card Industry Standard may mean “life or death” for many businesses. The difference between PCI DSS 4.0 compliance and adherence to any other data privacy mandate is that failure to comply means more than a slap on the wrist, a fine, or an arbitrary withholding of a certification. 

Failing to comply with PCI DSS version 4.0 revokes a company’s ability to accept card-based payments, a lion’s share of the revenue stream for most organizations today. And without the ability to accept payments, many enterprises will lack the resources to put the security policies in place that will help them comply in the future—or in time to keep from going under.  

Transitioning to PCI DSS 4.0 is vital for companies still in “good standing.” Doing so now may mean the difference between staying afloat for the long term and experiencing an end-of-the-year crisis. 

While the March 31, 2025 deadline has passed, it’s still not too late for organizations to catch up. This simple PCI DSS compliance checklist will show you how, taken from Fortra’s comprehensive guide: 5-Step PCI DSS 4.0 Transition Checklist.  

Step 1: Act Now 

The grace period is over. Officially retired on March 31, 2024, PCI DSS 3.2.1 left a one-year grace period for all payment card-accepting companies to comply with the new PCI DSS v4 standards. Now that the March 31, 2025 date has passed for adherence, companies need to move. 

Solidify your action plan, document it well, and show progress. While PCI DSS compliance is a “journey” more than a destination, auditors will want to see a well-organized, thoughtful approach with a phased implementation strategy.  

Step 2: Be Prepared to Expand Your Scope 

The old PCI DSS requirements drew protections around card-related data alone; the new version 4 standards add “account data” into the mix. 

What is this going to do to the scope of your current security controls? They may need to be expanded, and additional data classified and drawn in to meet the new requirements. Think about what this will mean for the cloud, databases, third-party information, and more.  

Step 3: Audit Your People and Processes 

Creating a new set of rules with a limited group of analysts in a security back room is not going to cut it. To meet PCI DSS 4.0 standards now and in the future, long-term processes will need to introduced to and adopted by the right stakeholders. 

Those stakeholders—department heads, key practitioners, the CEO—will be responsible for “backing” these practices in the future and making sure they are baked in to future rules. Doing this in a vacuum will not work. 

Teams need to define what security of the cardholder data environment (CDE) looks like holistically, who needs to be involved, and how they need to be trained to be “on board.” 

Step 4: Realize Security Configuration Management (SCM) Is Now on You 

Under Requirement 2 of the new PCI DSS guidelines, companies are now in charge of implementing their own security configuration management (SCM) program. This ensures that PCI-compliant networks, servers, firewalls, and more stay that way. 

Not only do the new SCM mandates secure all systems that store, handle, or transmit cardholder data, they provide a paper trail of setbacks and improvement over time that auditors will want to see. 

Step 5: Make Your Life Easier: Automate Compliance 

Once the rules have been solidified in new security controls, plans have been put into place, and stakeholders know their roles, the rest should be simple. 

With automation—solutions that put the key components of continuous compliance on autopilot—busy companies can come as close to “set it and forget it” as it is possible to do in a dynamic environment. There are some areas of PCI DSS compliance that may need manual oversight, but neither monitoring for configuration drift nor file integrity monitoring (FIM) are one of them.  

Let automated tools do this part for you, so all you have to worry about is hunting threats down—not spending cycles trying to find them. 

Conclusion 

Taking on a new compliance mandate at scale is challenging, no matter how robust your Governance, Risk, and Compliance (GRC) program is. The auditing, gap finding, gap filling, and introduction of new training and new solutions can put an undue burden on companies already struggling to meet the business demands of the day.  

Fortra’s PCI DSS compliance checklist helps take organizations from confusion to compliance when navigating the new Payment Card Industry rules, walking teams step-by-step through the process and helping them find the solutions that will give them a firm footing.  

Compliance with PCI DSS version 4.0 regulations is non-negotiable for companies that want to seamlessly keep accepting online payments, or even card-based payments in store or via mobile. With fully managed PCI DSS compliance services, Fortra is ready, willing, and capable of helping organizations of any size and type meet the requirements and never miss a beat.