Stop doing PCI DSS the old way

---

Organizations that handle payment card data know the stakes are high—and the scrutiny is only increasing. Yet many are still managing Payment Card Industry Data Security Standard (PCI DSS) compliance as if it’s 2016. With PCI DSS v4.0 in full effect and future-dated requirements coming in 2025, clinging to outdated processes puts your business at risk of delays, remediation costs, and missed revenue opportunities.

Why it matters: PCI DSS is not a one-time checkbox. It's a continuously evolving framework requiring year-round engagement, up-to-date expertise, and modern tools. If you're still treating it as an annual fire drill, it's time to rethink your approach.

How PCI DSS has been done historically

For years, PCI DSS compliance followed a predictable pattern: annual manual prep, document collection sprints, and a one-time assessment to “get the AOC.” The process was offline, labor-intensive, and designed for a static environment.

SAQs and annual audits defined the rhythm. Smaller merchants were eligible to complete Self-Assessment Questionnaires (SAQs), while larger organizations—typically Level 1 merchants and most service providers—had to undergo on-site reviews by a Qualified Security Assessor (QSA). This produced a Report on Compliance (ROC) and then an Attestation of Compliance (AOC).

Evidence gathering was manual and fragmented. Teams relied heavily on spreadsheets, screenshots, and shared drives to assemble the evidence package. Collecting network diagrams, access controls, and system configs often involved chasing down stakeholders who hadn’t thought about PCI since the last audit cycle.

Certificates were misunderstood as compliance proof. Many organizations issued or received “PCI compliance certificates” from vendors, unaware that the PCI Security Standards Council does not recognize them. Only official PCI SSC documents like the ROC or AOC are acceptable validation.

The result? Slow, costly, and error-prone assessments more focused on passing the test than securing the environment.

Common PCI DSS challenges

As PCI DSS matured and environments became more complex, the old way of doing things started revealing its cracks.

Scoping mistakes derail the audit early. One of the most common assessment failures stems from improperly defining the cardholder data environment (CDE). Weak network segmentation or unclear data flows can lead to scope creep, delaying the assessment and requiring extensive remediation work.

E-commerce requirements cause confusion. PCI DSS v4.0 introduced enhanced controls around web-based payment pages. Organizations that rely on third-party scripts or redirect flows often misinterpret their obligations or eligibility for certain SAQs.

Third-party oversight is inconsistent. Whether it's your payment processor or a cloud service provider, obtaining sufficient evidence of their PCI compliance is essential. But organizations often rely on outdated AOCs, missing ROC sections, or misinterpreted shared responsibility models.

Using non-PCI templates disqualifies evidence. The PCI SSC requires use of specific reporting templates (SAQ, ROC, AOC). Producing a “compliance summary” or reusing SOC 2 content won’t cut it—any assessor who approves that is not aligned with PCI expectations.

Evidence gathering isn’t audit-ready. Screenshots without timestamps, outdated config data, or logs that can’t be tied to testing dates can render otherwise sufficient controls invalid for assessment purposes.

These challenges aren’t just technical—they have business impact. Missed deadlines, failed assessments, or incomplete third-party compliance evidence can delay product launches, DPS certifications, or merchant bank approvals.

What the future of PCI DSS looks like in 2026

The writing is on the wall: PCI DSS is moving toward continuous compliance. Not just annual validation, but ongoing confirmation that your controls are effective, your scoping is accurate, and your environment aligns with evolving security expectations.

Future-dated requirements go into effect March 31, 2025. These include controls around phishing resistance, script management for ecommerce, and periodic access reviews, all requiring updated documentation and systemic automation.

Assessment methods demand better evidence. PCI DSS v4.0 emphasizes outcome-based testing—what’s implemented, tested, and working, not just what’s documented. That shift means point-in-time evidence is no longer enough; data needs to align with control effectiveness and audit timelines.

Assessors will expect sampling strategies rooted in risk. Instead of testing every server or application individually, assessors can use representative sampling. But the sample must reflect risk tiers, implementation coverage, and adequate testing depth. If your evidence isn’t automatically mapped and dated, sampling won't save time—it’ll increase audit risk.

Visibility across frameworks becomes critical. PCI isn’t the only compliance requirement your business faces. SOC 2, ISO 27001, HIPAA, and others share overlapping controls. Organizations will need mappings that show how each control satisfies multiple frameworks without duplicating effort.

Platform-driven governance is the norm. The PCI SSC encourages “business-as-usual” compliance practices—ongoing monitoring, automated evidence collection, and always-current documentation. The expectation for 2026 is not just being compliant on paper, but being able to prove it consistently, quickly, and accurately.

Why it’s time to modernize your PCI program

Compliance shouldn’t slow you down. To meet today’s security expectations and tomorrow’s compliance deadlines, your business needs a modern PCI program—one built for automation, scale, and audit-readiness from day one.

Automation reduces scope and audit fatigue. Thoropass automatically collects evidence from over 100 integrations with cloud platforms, identity providers, ticketing systems, and logging tools. That means less time chasing screenshots and more time hardening systems.

Map once, comply many. Shared controls are mapped across PCI DSS and your other frameworks in a unified platform. That consolidates your effort and gives stakeholders visibility into overall compliance health—not just PCI status.

Embedded QSAs ensure audit readiness. Our PCI DSS assessments are performed by Thoropass QSAs—not outside contractors—so we align process, evidence, and expectations from kickoff through final ROC and AOC delivery. We’re a PCI SSC Qualified Security Assessor Company, so everything stays in one pane of glass.

ASV scans and pen tests, fully integrated. With Thoropass as your Approved Scanning Vendor (ASV), you don't need another vendor to meet scanning requirements. We coordinate ASV scans and penetration testing alongside the rest of your assessment workstream.

No more waiting months for results. Our platform provides real-time progress tracking, centralized communication, and compliance insights every step of the way. You’ll know what’s done, what still needs attention, and how to prioritize remediation.

Thoropass transforms the PCI experience

The path to PCI DSS compliance is more complex than ever—but it doesn’t have to be a burden. Thoropass replaces outdated, manual processes with a modern, end-to-end solution built specifically for audit-readiness, efficiency, and peace of mind.

You get a dedicated team of PCI DSS experts, a QSA-led assessment with no outsourcing, and automated evidence collection across your tech stack. Whether you're submitting an SAQ or undergoing a full ROC assessment, Thoropass brings everything into one streamlined platform.

Continuous monitoring.

Clear documentation.

Fewer surprises.

More time to focus on what matters—serving your customers and scaling securely.

Stop doing PCI DSS the old way. Schedule a discovery session today and see how Thoropass can transform your compliance program.