Summary

Default vendor passwords and unnecessary services are common attack vectors. PCI DSS requires you to harden every system component before deployment. Requirement 6 now explicitly requires you to manage security risks from third-party software components, including open-source libraries. Implement software composition analysis (SCA) tools to identify vulnerable dependencies. For smaller companies using hosted payment solutions, compliance can be achieved in weeks. For larger organizations with complex CDEs, the process typically takes three to twelve months, depending on existing security maturity.

PCI DSS Requirements List for Software Companies: A Complete Compliance Guide

If your software company handles, processes, stores, or transmits cardholder data, PCI DSS compliance isn’t optional — it’s a contractual and legal obligation. Understanding the full PCI DSS requirements list helps you build secure systems from the ground up, avoid costly breaches, and maintain trust with customers and payment partners.

This guide breaks down every major PCI DSS requirement category, explains what it means for software companies specifically, and gives you actionable steps to achieve and maintain compliance.

What Is PCI DSS and Why Does It Matter for Software Companies?

The Payment Card Industry Data Security Standard (PCI DSS) is a global security framework developed by the PCI Security Standards Council (PCI SSC). It applies to any organization that accepts, processes, stores, or transmits credit or debit card data.

For software companies, this typically includes:

SaaS platforms that process subscription payments
E-commerce applications handling checkout flows
Payment gateway or fintech software providers
Companies building apps that integrate with payment processors
Software vendors whose products touch cardholder data environments (CDE)

The current version, PCI DSS v4.0, was released in 2022 and became the sole active standard in March 2024. It introduces more flexibility and a stronger emphasis on continuous security rather than point-in-time compliance.

The 12 PCI DSS Requirements: A Complete List

PCI DSS v4.0 organizes its controls into 12 core requirements, grouped under six overarching goals. Here’s what each means for your software company.

Goal 1: Build and Maintain a Secure Network and Systems

Requirement 1: Install and Maintain Network Security Controls

Your software infrastructure must use firewalls, network segmentation, and access control lists to protect the cardholder data environment. For cloud-hosted software companies, this means configuring security groups, VPCs, and network ACLs correctly in AWS, Azure, or GCP.

Key actions:

Document all network connections to and from the CDE
Restrict inbound and outbound traffic to only what’s necessary
Review firewall rules at least every six months

Requirement 2: Apply Secure Configurations to All System Components

Default vendor passwords and unnecessary services are common attack vectors. PCI DSS requires you to harden every system component before deployment.

Key actions:

Maintain a system configuration standard for all servers, containers, and endpoints
Disable all unnecessary services, ports, and protocols
Implement configuration management tools (Ansible, Terraform, Chef) to enforce standards consistently

Goal 2: Protect Account Data

Requirement 3: Protect Stored Account Data

If your software stores cardholder data, it must be encrypted, masked, or tokenized. PCI DSS strongly discourages storing sensitive authentication data (SAD) like CVV codes after authorization.

Key actions:

Implement strong encryption (AES-256) for any stored cardholder data
Use tokenization to replace card numbers with non-sensitive equivalents
Maintain a data retention and disposal policy

Requirement 4: Protect Cardholder Data with Strong Cryptography During Transmission

Any cardholder data transmitted over open, public networks must be encrypted using TLS 1.2 or higher. This applies to your APIs, web applications, and any data pipelines.

Key actions:

Enforce TLS 1.2+ across all endpoints
Disable older protocols (SSL, TLS 1.0, TLS 1.1)
Use strong cipher suites and certificate management practices

Goal 3: Maintain a Vulnerability Management Program

Requirement 5: Protect All Systems and Networks from Malicious Software

Anti-malware controls must cover all system components. For software companies, this extends to CI/CD pipelines and developer workstations.

Key actions:

Deploy endpoint detection and response (EDR) tools
Scan container images for malware and vulnerabilities before deployment
Keep anti-malware definitions updated automatically

Requirement 6: Develop and Maintain Secure Systems and Software

This requirement is especially relevant for software companies. You must integrate security into your software development lifecycle (SDLC).

Key actions:

Train developers on secure coding practices (OWASP Top 10)
Conduct code reviews and static application security testing (SAST)
Perform dynamic application security testing (DAST) before releases
Apply security patches within defined timeframes (critical patches within one month)
Maintain a formal vulnerability management process

Goal 4: Implement Strong Access Control Measures

Requirement 7: Restrict Access to System Components and Cardholder Data by Business Need to Know

Access to cardholder data must be limited to only those who genuinely need it. Implement role-based access control (RBAC) across your platform.

Requirement 8: Identify Users and Authenticate Access to System Components

Every user must have a unique ID. Shared accounts are prohibited in the CDE. Multi-factor authentication (MFA) is now required for all access into the CDE under PCI DSS v4.0.

Key actions:

Enforce MFA for all administrative and remote access
Implement strong password policies (minimum 12 characters under v4.0)
Review and revoke access promptly when employees leave

Requirement 9: Restrict Physical Access to Cardholder Data

If your software company has on-premises infrastructure or physical servers, you must control and monitor physical access. For fully cloud-based companies, your cloud provider’s physical security controls may satisfy this requirement — but you must document it.

Goal 5: Regularly Monitor and Test Networks

Requirement 10: Log and Monitor All Access to System Components and Cardholder Data

Comprehensive logging is non-negotiable. All access to the CDE must be logged, and logs must be protected from tampering.

Key actions:

Implement a SIEM solution to aggregate and analyze logs
Retain logs for at least 12 months (three months immediately available)
Set up alerts for suspicious activity

Requirement 11: Test Security of Systems and Networks Regularly

Regular testing validates that your controls actually work. This includes vulnerability scans, penetration testing, and file integrity monitoring.

Key actions:

Run internal and external vulnerability scans quarterly
Conduct penetration testing at least annually and after significant changes
Use file integrity monitoring (FIM) to detect unauthorized changes
Implement intrusion detection/prevention systems (IDS/IPS)

Goal 6: Maintain an Information Security Policy

Requirement 12: Support Information Security with Organizational Policies and Programs

You need a formal, documented information security policy that’s reviewed annually and communicated to all personnel.

Key actions:

Develop and maintain a comprehensive information security policy
Conduct annual security awareness training for all staff
Maintain an incident response plan and test it regularly
Manage third-party vendor risk with documented assessments

PCI DSS Compliance Levels for Software Companies

Your compliance level depends on transaction volume:

Level	Annual Transactions	Validation Method
Level 1	Over 6 million	On-site audit by QSA
Level 2	1–6 million	SAQ or QSA audit
Level 3	20,000–1 million	SAQ
Level 4	Under 20,000	SAQ

Most software companies start at Level 3 or 4 and complete a Self-Assessment Questionnaire (SAQ) rather than a full audit.

Special Considerations for Software Companies

Scope Reduction Through Tokenization and Outsourcing

One of the most effective strategies for software companies is reducing your CDE scope. By using a compliant payment processor (Stripe, Braintree, Adyen) and implementing tokenization, you can avoid storing raw card data entirely, dramatically simplifying your compliance obligations.

Secure Software Development Lifecycle (SSDLC)

PCI DSS v4.0 places greater emphasis on baking security into development processes. Software companies should adopt frameworks like DevSecOps, integrate SAST/DAST tools into CI/CD pipelines, and maintain a formal vulnerability disclosure program.

Third-Party and Open-Source Components

Requirement 6 now explicitly requires you to manage security risks from third-party software components, including open-source libraries. Implement software composition analysis (SCA) tools to identify vulnerable dependencies.

FAQ: PCI DSS Requirements for Software Companies

Does my software company need PCI DSS compliance if we use Stripe or another payment processor?

Yes, but your scope may be significantly reduced. If you use hosted payment pages or tokenization from a compliant processor, you may qualify for a simpler SAQ (like SAQ A). However, you still have obligations around how you handle redirects, iframes, and any cardholder data that touches your systems.

What is the difference between PCI DSS v3.2.1 and v4.0?

PCI DSS v4.0 introduces more flexibility (allowing customized approaches to meet requirements), stronger MFA requirements, updated password minimums, and greater focus on continuous security monitoring. v3.2.1 was retired in March 2024, so all companies must now comply with v4.0.

How long does it take a software company to achieve PCI DSS compliance?

For smaller companies using hosted payment solutions, compliance can be achieved in weeks. For larger organizations with complex CDEs, the process typically takes three to twelve months, depending on existing security maturity.

What happens if my software company fails a PCI DSS audit?

Non-compliance can result in fines from payment brands ($5,000–$100,000 per month), increased transaction fees, loss of the ability to process card payments, and significant reputational damage following a breach.

Do software companies need a Qualified Security Assessor (QSA)?

Level 1 merchants and service providers are required to use a QSA for their annual assessment. Levels 2–4 may self-assess using the appropriate SAQ, though many companies choose to work with a QSA for guidance even when not required.

Start Your PCI DSS Compliance Journey Today

Building PCI DSS compliance from scratch is time-consuming and complex — but it doesn’t have to be. Our ready-to-use PCI DSS compliance template bundle gives your software company everything you need to get compliant faster and with confidence.

Our templates include:

Information Security Policy (aligned to PCI DSS v4.0)
Incident Response Plan
Vendor Risk Management Policy
Vulnerability Management Procedure
Access Control and User Management Policy
Network Security Configuration Standards
Security Awareness Training Program outline
Pre-filled SAQ guidance documents

Stop spending weeks building compliance documentation from scratch. Download our PCI DSS template bundle today and give your team a professional, audit-ready foundation in hours — not months.

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