Top 7 Challenges Businesses Face with PCI DSS 4.0

The Payment Card Industry Data Security Standard (PCI DSS) 4.0 represents one of the most significant updates in payment security requirements in recent years. Its goal is to strengthen data protection, promote continuous compliance, and encourage flexibility in how businesses achieve security objectives.

While the intentions behind PCI DSS 4.0 are positive, the implementation journey is far from easy. Many organisations are struggling to understand and meet the new requirements, especially with limited resources and evolving technology infrastructures. Below are the top seven challenges businesses are facing with PCI DSS 4.0 and practical steps to overcome them.

1. Defining the Correct Scope of Compliance

One of the biggest hurdles with PCI DSS 4.0 is defining the correct scope of compliance. Modern payment systems involve multiple third-party integrations, cloud environments, APIs, and complex data flows. This makes it difficult to identify which systems, applications, and networks are part of the Cardholder Data Environment (CDE).

If the scope is too broad, it increases costs and workload. If it is too narrow, you risk non-compliance and potential data exposure. To overcome this, conduct a detailed scoping exercise, map every point where cardholder data is stored, processed, or transmitted, and implement proper network segmentation. A well-defined scope helps you focus compliance efforts where they matter most.

2. Adapting to the New “Customized Approach” Controls

PCI DSS 4.0 introduces a new concept known as the “Customized Approach.” Unlike earlier versions where requirements were rigid, this approach allows businesses to design their own controls as long as they meet the security objective.

While this flexibility can be beneficial, it also brings complexity. Organizations now need to provide solid documentation explaining how their custom controls meet PCI objectives. Assessors will ask for proof, testing methods, and continuous validation reports. Many companies are not yet prepared for this level of documentation and justification.

To manage this, create internal templates for documenting customized controls. Include the control objective, risk assessment, validation method, and evidence of effectiveness. This not only helps auditors but also strengthens your internal governance.

3. Limited Resources and Expertise

Many small and medium-sized businesses are finding it difficult to keep up with the new demands of PCI DSS 4.0 due to limited technical expertise and manpower. The updated version requires a deeper understanding of continuous monitoring, encryption, risk assessment, and evidence collection.

Building or maintaining a dedicated PCI compliance team can be costly. To address this, consider training internal IT staff in PCI DSS fundamentals, partnering with a Qualified Security Assessor (QSA), or outsourcing parts of compliance to managed security service providers (MSSPs). Investing in the right expertise early on helps avoid costly rework or audit failures later.

4. Meeting Continuous Compliance Requirements

Unlike previous versions that focused on point-in-time assessments, PCI DSS 4.0 emphasizes continuous compliance. Organizations must now demonstrate that their security controls are effective all year round, not just during the audit period.

This means maintaining detailed logs, conducting regular vulnerability scans, monitoring access, and generating consistent reports. Many companies are realizing their existing tools are not equipped for this level of monitoring.

Automation can help significantly. Use centralized logging and Security Information and Event Management (SIEM) tools to gather evidence and detect anomalies in real time. Set reminders for periodic internal audits and retain records for the required duration. The goal is to make compliance an ongoing habit rather than an annual activity.

5. Managing Cloud and Third-Party Dependencies

With most payment systems now operating in hybrid or cloud environments, businesses are finding it difficult to manage shared responsibilities under PCI DSS 4.0. Cloud providers often handle parts of the infrastructure, but the business still remains responsible for data security and compliance validation.

The challenge is ensuring every vendor or partner complies with PCI standards. Lack of transparency from vendors can create hidden vulnerabilities.

To handle this, establish a strong third-party risk management process. Request PCI Attestation of Compliance (AOC) or SOC reports from your vendors. Clearly define roles and responsibilities in contracts and verify that all service providers handling cardholder data maintain ongoing compliance.

6. Implementing Stronger Authentication and Encryption

PCI DSS 4.0 significantly strengthens requirements around authentication and encryption. Multi-factor authentication (MFA) is now mandatory for all access into the CDE, not just for administrators. Additionally, encryption methods must meet modern cryptographic standards to protect data in transit and at rest.

Many organizations are struggling to upgrade legacy systems that do not support modern encryption or MFA. Rolling out new authentication mechanisms across distributed teams and vendors is also challenging.

To overcome this, start with a detailed inventory of systems and access points. Prioritize high-risk areas such as remote access, privileged accounts, and internet-facing applications. Deploy MFA using secure authentication apps or hardware tokens and gradually phase out weak encryption algorithms. Make sure to update security policies to reflect these changes.

7. Improving Documentation and Audit Readiness

PCI DSS 4.0 requires far more documentation than previous versions. Businesses must now provide detailed records showing why and how each control was implemented, how it is tested, and how ongoing compliance is maintained.

Many organizations underestimate the amount of documentation auditors will expect. Inadequate record-keeping often leads to delays or even audit failures.

Create a central repository where all PCI-related documentation is stored, including policies, risk assessments, control testing results, and evidence logs. Assign clear ownership for maintaining each document and establish version control. Proper documentation not only makes audits smoother but also provides a clear roadmap for future improvements.

How to Stay Ahead of PCI DSS 4.0 Compliance

Transitioning to PCI DSS 4.0 should not be treated as a one-time project. It requires a continuous improvement mindset. Here are a few practical tips to stay ahead:

1. Conduct a thorough gap assessment between PCI DSS 3.2.1 and 4.0 requirements.
2. Engage your IT, compliance, and business teams early in planning and testing.
3. Automate evidence collection and reporting wherever possible.
4. Maintain open communication with QSAs and external partners.
5. Educate employees about data security best practices and responsibilities.

By taking proactive steps, businesses can turn PCI DSS 4.0 from a compliance headache into an opportunity to strengthen trust and improve overall cybersecurity posture.

Conclusion

PCI DSS 4.0 raises the bar for payment security by focusing on outcomes, flexibility, and continuous protection. However, this evolution also brings challenges such as defining scope, managing third parties, and ensuring consistent documentation.

Businesses that approach PCI DSS 4.0 strategically, with a mix of automation, collaboration, and expert guidance — will find the transition smoother and more rewarding. Ultimately, compliance is not just about meeting regulations but about protecting customer trust and securing the future of digital transactions.