Generating an audit trail is not just good practice but is also integral to achieving PCI compliance, which stands for Payment Card Industry Data Security Standard (PCI DSS). This standard is what retailers and banks rely on to safeguard consumers’ sensitive credit card information.

In particular, when striving for PCI compliance, audit logs, log management, and log retention become crucial components, as stipulated in PCI DSS requirement 10.7. This requirement mandates that audit logs must be retained for at least one year. Additionally, for immediate analysis, companies must maintain the last ninety days of PCI audit logs readily accessible.

So, how can a company meet these demanding compliance requirements while addressing the need to be PCI compliant?  This article is here to provide the answers you seek, starting with the fundamental steps to ensure PCI compliance.

What Is PCI DSS?

The Payment Card Industry Data Security Standard (PCI DSS) is a widely recognized (and used) standard to safeguard the personal information of payment card users and to improve the security of transactions using credit, debit, and cash cards. The four major credit card issuers – Visa, MasterCard, Discover, and American Express – jointly developed and launched PCI DSS in 2004.

The standard has six primary goals.

  1. Companies must maintain a secure network. This criterion calls for deploying reliable firewalls without putting consumers or merchants through unnecessary hardship.
  2. Cardholder data must be secure. You should store vital information such as birth dates, names, Social Security numbers, phone numbers, and postal addresses in databases that are safe against hacking. The data should be encrypted before being sent over public networks.
  3. Use regularly updated antivirus software, anti-spyware tools, and other anti-malware solutions to protect against attackers. Every application should be protected against flaws and security holes that might allow hackers to steal or modify cardholder data.
  4. Limit and manage access to system information and processes. Cardholders should only be required to provide data companies need to know to complete a transaction. Each computer user must be given a unique and private identifying name or number.
  5. Networks must be continuously monitored and tested to ensure all security procedures and measures are in place, maintained, and working effectively.
  6. Companies should create, maintain, and abide by a documented information security policy to ensure that security and information protection follow a rigorous, thoughtful process that reflects the company’s risks.

What Is a PCI Audit?

The PCI DSS Standard requires that merchants who accept credit card transactions must undergo a routine audit to assure and maintain compliance. Sometimes, you may also need additional audits in response to a specific breach or other security failure.

These audits are conducted by auditors specially qualified to assess PCI compliance. They evaluate whether the company’s internal processes adhere to standards by looking at point-of-sale systems and other components of the company’s IT infrastructure. Companies also receive risk assessments from the assessment outlining their PCI level of compliance.

7 Steps of a PCI Audit

     1. Gap Analysis

          Evaluate compliance against PCI-DSS requirements to reveal any vulnerabilities or non-compliant areas in security policies, cardholder data handling, access controls, etc.

     2. Remediate Findings 

         Strengthen security based on gap analysis results. Update firewall rules, encryption protocols, account access procedures, physical security, and other controls to fulfill PCI requirements.

     3. Define Audit Scope

         Work with your Qualified Security Assessor (QSA) to determine which systems, facilities, payment channels, and data sets the audit will assess.

     4. Gather Documentation

         Compile detailed records demonstrating PCI compliance, including risk analyses, security procedures, vulnerability scan reports, access logs, and other audit evidence to provide the QSA.

     5. Onsite Inspection

         Escort the QSA during the inspection of facilities and observation of compliance processes. Ensure transparency in all audit areas.

     6. Resolve Outstanding Issues 

         Fix any remaining vulnerabilities or policy gaps identified during the audit with guidance from the QSA.

     7. Achieve Certification

         Upon successful remediation, the QSA issues the organization an Attestation of Compliance for displaying adequate security controls and fulfilling PCI requirements.

Following these steps helps streamline the audit process. Maintaining diligence between audits is critical for sustaining robust protection of cardholder data.

What triggers a PCI audit?

A PCI audit can be triggered by various factors, including:

  • Compliance Requirements: Routine audits, as part of a PCI DSS assessment, are often mandated by the Payment Card Industry Data Security Standard (PCI DSS) to ensure ongoing adherence to security standards, compliance levels, and the comprehensive Report on Compliance (ROC).
  • Security Incidents: Data breaches or security incidents can trigger audits, necessitating a thorough incident response and potential penetration testing to assess the extent of the breach and identify vulnerabilities.
  • Merchant Classification: Businesses may be selected for audits based on their merchant classification, history, payment card data, transaction volume, and the need for network segmentation and enhanced authentication.
  • Random Selection: Some audits are conducted randomly as part of PCI compliance monitoring, requiring businesses to maintain a constant state of readiness.
  • Customer Requests: Card-issuing banks, payment processors, and acquiring banks may request audits from merchants in specific cases. This may involve engagement with an Approved Scanning Vendor (ASV) and a compliance checklist to ensure the security posture and protection of sensitive data.

The specific trigger for a PCI compliance audit may vary. Still, continuous PCI DSS compliance and adherence to security standards and software development practices are vital to avoiding unexpected audits and maintaining a solid security posture.

How often are PCI audits required?

The PCI DSS has become a crucial framework for any business that processes, stores, or transmits credit card data. But how often do you need to undergo PCI-DSS audits to remain compliant?

Unfortunately, there is no one-size-fits-all answer. The major card brands like Visa, Mastercard, and American Express each set their requirements for audit frequency that businesses must follow. However, there are some general guidelines:

  • Level 1 merchants (over 6 million annual transactions) must complete an onsite audit with a Qualified Security Assessor (QSA) annually.
  • Companies that experience a confirmed data breach must complete a PCI audit before continuing payment processing successfully.
  • Smaller merchants may only need to complete Self-Assessment Questionnaires (SAQ) or Attestations of Compliance (AOC) once every two years.
  • Service providers like payment gateways often undergo audits multiple times per year.

The PCI Security Standards Council determines the core components of an audit, including checking firewalls, access controls, data encryption, and other security measures that comprise the PCI DSS. Whether onsite or virtual, audits aim to confirm cardholder data environments comply with all requirements.

While not overly frequent for small businesses, verifying PCI compliance is crucial. Audits not only help avoid costly non-compliance fines and damage from breaches, but they assure customers that your business takes payment security seriously. Investing in continuous PCI DSS audit readiness ensures you are protecting sensitive cardholder data.

What are the consequences of not complying with PCI DSS?

Failing to comply with the Payment Card Industry Data Security Standard (PCI DSS) can have far-reaching implications for businesses. From financial penalties to the erosion of trust and reputation damage, non-compliance poses many challenges. 

Financial Penalties and Increased Fees

Non-compliance with PCI DSS can lead to significant financial penalties and higher transaction fees. The fines vary depending on the violation’s severity and the number of affected cards, putting a financial strain on businesses.

Loss of Trust and Legal Actions

Data breaches and non-compliance can erode trust among customers and partners, resulting in reduced sales and potential legal actions. Businesses may face customer lawsuits and regulatory penalties, incurring substantial legal costs.

Reputation Damage and Additional Costs

Non-compliance harms a company’s reputation, making it challenging to rebuild customer trust. This negative publicity has lasting effects. Addressing non-compliance requires increased security investments and mandated security improvements, escalating costs. 

What Is a SIEM?

The SIEM acronym stands for Security Information and Event Management System. It is a system that integrates multiple cybersecurity disciplines such as file integrity monitoring, intrusion detection systems, user activity, data breach detection, and Syslog aggregation.

The SIEM consumes log server data and provides log analysis to establish an audit trail history. In addition, a proper SIEM has alerting configured to help information security professionals find the operating system and user account compromises that may lead to credit card and card data compromise.

An organization’s IT and security infrastructure, including host systems, networks, firewalls, and antivirus security devices, are all sources of event data that a SIEM gathers and aggregates. The program allows security teams to learn more about attackers’ Tactics, Techniques, and Procedures (TTPs), using threat rules generated from knowledge of known Indications Of Compromise (IOCs) and prior TTPs.

Since SIEMs are crucial to generating audit trails for cybersecurity analysis and risk management, and audit trails are a requirement of PCI DSS compliance, a company can’t achieve and maintain its PCI compliance without using some SIEM system.

What are the SIEM PCI Compliance Requirements?

As we mentioned earlier, PCI DSS has six broad goals. Within those six overall goals are 12 more specific requirements.

Goal 1: Creating and keeping a secure network


  • Upkeep of firewall configuration
  • Verify that all system passwords are distinct and original

Goal 2: Safeguard cardholder data


  • Defend stored cardholder information
  • Transmit cardholder information across public networks securely

Goal 3: Keep a vulnerability management program going


  • Use and update antivirus software.
  • Create secure systems and apps

Goal 4: Implement adequate access control procedures


  • Limit cardholder information to those who need to know it.
  • Give each employee with access to the company’s computers a unique ID
  • Limit physical access to cardholder information

Goal 5: Monitor and test networks


  • Keep an eye on and record access to cardholder information and appropriate network resources
  • Test security procedures and systems regularly

Goal 6: Maintain an information security policy


  • Establish an information security policy and implement it within the company.

An organization should take the following three actions to comply with the PCI DSS:

  • Identification of cardholder data, inventorying technology, business procedures, and vulnerability analysis are all parts of the assessment.
  • Fix the vulnerabilities as soon as you find them, and avoid storing unneeded cardholder data.
  • Report, record, and deliver compliance and remediation validation reports to banks and card brands.

Automate PCI Compliance Effortlessly with RiskOptics ROAR

Regardless of your compliance issues, it helps you incorporate data security into your operations. Our state-of-the-art governance, risk, and compliance management system provides the most accurate PCI assessment tool. ROAR continuously scans your networks and methods to assess where you stand concerning PCI DSS compliance requirements and where you (and your vendors) fall short.

Your business can use ROAR compliance management, risk management, and workflow management features as a single solution. ROAR interfaces to a variety of tools with ease, moving data for you and associating controls with all of your compliance requirements, including the Payment Card Industry (PCI), Health Insurance Portability and Accountability Act (HIPAA), Security Operations Center (SOC), and others.

Additionally, it performs internal audits with a few clicks as frequently as you wish while looking at the controls surrounding your Cardholder Data Environment (CDE).

Schedule a demo to learn how RiskOptics can help you automate, simplify, and manage your compliance needs.