You Missed the PCI DSS 4.0.1 Compliance Deadline. Now What?

As the e-commerce market continues to grow, retailers increasingly find themselves in the crosshairs of cybercriminals. In fact, nearly a quarter (24 percent) of all cyberattacks now target retailers.
As the threats continue to mount, so too does the pressure on industry players to meet ever-stricter security and compliance requirements. For retailers, one of the most important frameworks to adhere to is the Payment Card Industry Data Security Standard (PCI DSS).
As technical and policy controls that govern how payment card data is handled, PCI DSS is designed to protect customers by keeping transactions secure while helping retailers to avoid costly legal or financial fallouts.
For any retailer that accepts credit or debit cards, compliance with PCI DSS is mandatory. However, the specific requirements within this have evolved over time.
Generally speaking, PCI DSS centers around several core principles, including building and maintaining a secure network, implementing strong access control measures, and protecting cardholder data. However, the standards are regularly updated as risks emerge and technologies advance, with the current iteration being PCI DSS v4.0.1.
As of March 31, any organization that handles payment card data is now required to comply with this latest version of the standard.
While PCI DSS v4.0.1 is a limited revision that doesn’t stray too far from the guidance provided in v4.0, it has introduced several important refinements, particularly around client-side payment security and payment page protection.
Critically, these updates are designed to help organizations defend against key threats such as website skimming and malicious code injections, both of which are increasingly being aimed at online retailers.
A summary of some of the key alterations in v4.0.1 includes:
- Enhanced emphasis on security as an ongoing process.
- Multifactor authentication and zero-trust architecture requirements for service providers.
- Updated software development requirements, including secure coding practices, automated vulnerability scanning, and penetration testing.
- Stricter password management rules, including using passphrases and banning certain weak passwords.
- Promotion of systematic and effective encryption, including support for quantum-safe cryptography.
It's vital that those retailers that missed the compliance deadline catch up as quickly as possible.
Not only does noncompliance with PCI DSS potentially jeopardize the security of customer payment data, but it also exposes retailers to severe ramifications such as hefty fines from regulatory bodies. Fines are on a sliding scale, starting at $5,000/month and, ultimately, going up to $100,000/month, with the retailer on the hook to pay.
Beyond the immediate financial impacts, noncompliance may also lead to halted payment processing, reputational damages, a loss of customer trust, and increased vulnerability to data breaches — all of which can have long-lasting impacts.
So, how can retailers that missed the deadline quickly get back on track and ensure they become compliant with v4.0.1 as soon as possible?
First, it’s important to identify your compliance level. Indeed, PCI DSS compliance varies based on annual card transaction volume, from Level 1 (over 6 million annual credit card transactions) to Level 4 (under 20,000). Identifying which level is relevant for your business is key to defining the scope of your compliance obligations.
From here, the next step is to compare your current security posture to PCI DSS’s requirements. With any gaps identified, your organization can begin to bridge them with the required controls. This may include configuring firewalls, encrypting data transmissions, setting up robust access controls, and putting in place the key client-side security measures emphasized in PCI DSS v4.0.1.
Finally, it’s essential to establish robust governance practices to prevent future compliance lapses. Compliance should be viewed as an ongoing process of monitoring, testing and improving your security posture over time, enabling you to respond to issues quickly and address assessments more easily.
Get all this right and you’ll be better positioned to achieve compliance with key standards, both now and in the future.
Sam Peters is the chief product officer at ISMS.online, an auditor-approved compliance platform.
Related story: E-Commerce Growth Intensifies Cyber Threats: Are Retailers Compliance-Ready?

Sam Peters has a diverse work experience starting from 2003 to present. They are currently serving as the Chief Product Officer at ISMS.online since May 2021. Previously, they worked at Alliantist for 8 years, from January 2013 to May 2021, in the role of Head of Products and Services. Before that, they held the position of Product and Support Manager at WPM Education from June 2011 to January 2013. Prior to that, they worked at East Sussex County Council as a Schools ICT Applications Manager from September 2009 to June 2011. They also worked as a General Manager at DB Education Services from April 2008 to September 2009. Their earliest professional experience was at Digitalbrain PLC, where they served as a Service Delivery Manager from November 2003 to April 2008.
Sam Peters attended Cardiff University/Prifysgol Caerdydd from 1997 to 2000, where they obtained a BA (Hons) degree in Politics Social Philosophy and Applied Ethics. Additionally, they have certifications as a Certified SCRUM Product Owner from Roman Pichler Consulting and an ITIL (V3) Foundation Certificate from EXIN.