Understanding Payment Brands

Understanding Payment Brands’ PCI DSS Compliance Requirements for Financial Institutions and Heavily regulated organisations


In the realm of financial transactions and electronic payments, security is of paramount importance. To ensure the protection of sensitive payment card account data and maintain the integrity of payment systems, Payment Brands have established strict standards known as the Payment Card Industry Data Security Standard (PCI DSS). 

Whilst PCI DSS compliance is commonly associated with Merchants and Service Providers, as depicted in figures 1 and 2, it is equally vital for financial institutions and heavily regulated organisations that have contractual agreements with the Payment Brands. 



Figure 2: Extract from Mastercard Rules

Within the PCI DSS, v4.0, it explicitly states to whom the standard is applicable to:

“PCI DSS Applicability Information PCI DSS is intended for all entities that store, process, or transmit payment card account data (CHD) and/or sensitive authentication data (SAD) or could impact the security of the payment card account data environment (CDE). This includes all entities involved in payment card account processing — including merchants, processors, acquirers, issuers, and other service providers. 

Whether any entity is required to comply with or validate their compliance to PCI DSS is at the discretion of those organizations that manage compliance programs (such as payment brands and acquirers).”

When you apply the ancillary regulatory lens (e.g., Information Commissioner’s Office (ICO), Financial Conduct Authority (FCA)), etc.), as depicted in figures 3 and 4, the importance of PCI DSS compliance, for non-Merchants and Service Providers, for Financial Institutions, is seen in a completely new light.

This blog post aims to shed light on the PCI DSS compliance requirements for such entities.




Figure 3: Extract from ICO Website

Figure 4: FCA Handbook Principles

Understanding the Scope:

Financial institutions and heavily regulated organisations that interact with payment card data must understand the scope of their involvement and how it impacts PCI DSS compliance. This includes identifying the systems, processes, and personnel that handle payment card account data or have access to payment card account data environments. Some of the measures that need to be applied to the identified and defined PCI DSS scope include:

Network Security:

Maintaining a secure network infrastructure is crucial for PCI DSS compliance. Financial institutions and heavily regulated organisations should deploy firewalls, regularly update security patches, and segment their networks to minimise the risk of unauthorised access or data breaches. Ongoing monitoring and testing of network security controls are essential to identify and address vulnerabilities promptly.

Systems Security:

Ensuring that all the supporting systems are securely hardened and all unnecessary services, ports, protocols, functions are disabled or removed, is an essential part of an effective PCI DSS compliance programme.

Data Minimisation, Tokenisation/Encryption and Security:

Protecting payment card account data is at the core of PCI DSS compliance. Consequently, Financial Institutions and heavily regulated organisations must ensure that the use of payment card account data is kept to an absolute minimum and that robust encryption methods to secure payment card account data both in transit and at rest. Encryption protocols, secure key management, and secure cryptographic processes should be implemented to ensure data integrity.

Access Control:

Proper access controls are vital in preventing unauthorised access to payment card account data. Financial institutions and heavily regulated organisations must implement strong user authentication mechanisms, limit access to sensitive information based on job roles, and regularly review and monitor user access privileges. Multi-factor authentication, unique user IDs, and stringent password policies contribute to a secure access control environment.


Incident Response and Monitoring:

Being prepared for security incidents is crucial. Financial institutions and heavily regulated organisations should have well-defined incident response procedures in place to promptly detect, report, and respond to security breaches or suspected compromises. Implementing robust monitoring and log management systems enables timely detection of any suspicious activities.

Compliance Validation:

Common validation methods for Merchants and Service Providers include:

  • Self-Assessment Questionnaires (SAQs), 
  • On-site Report On Compliance (ROC) assessments by Qualified Security Assessors (QSAs), 
  • Approved Scanning Vendor (ASV) external network & application layer vulnerability scans,
  • Internal network & application layer vulnerability scans,
  • Internal & External network penetration & segmentation testing.

However, Financial Institutions and heavily regulated organisations are granted a degree of autonomy to manage and validate their own PCI DSS Compliance programme, often incorporating this into their enterprise security measures and periodically validated through their internal audit activities. 

The issue arises when such an entity suffers a data breach and are unable to validate the effectiveness of any specific PCI DSS Requirements, at the time of the data breach. Suddenly, they are faced with a mad scrabble to collate together the available supporting evidence, to help mitigate any potential fines, and some awkward conversations with the Payment Brands and their Regulators.

Without undergoing the costly expense of having the PCI DSS Compliance independently validated, by a QSA, or having an internal resource complete a SAQ which will then be securely held for a period of 3 years and only dusted off and brought out in response to a data breach, what are your other options?

  • Spreadsheets?
  • Evidential folders?
  • Documents?
  • Locally created PCI DSS Status Metrics?

How about investing in a PCI DSS digital assessment and management system?


For financial institutions and heavily regulated organisations with contractual agreements with Payment Brands, adhering to PCI DSS compliance requirements is not only a necessity but also a critical step towards safeguarding payment card account data and maintaining trust in the payment ecosystem. By comprehending the scope, validating compliance, securing data, enforcing access controls, ensuring network security, and establishing incident response protocols, these entities can enhance their overall security posture.

Remember, PCI DSS compliance is an ongoing process. It is not a one-time endeavour but rather requires continuous monitoring, assessment, and improvement. Staying up to date with the evolving standards and best practices is crucial to maintain compliance and protect against emerging security threats.

Financial institutions and organisations should also consider partnering with qualified security professionals and PCI DSS assessors to ensure they meet all requirements and address any vulnerabilities effectively. Regular training and awareness programs for employees can further enhance the overall security culture within the organisation.

By prioritising PCI DSS compliance, financial institutions and organisations demonstrate their commitment to data security and the protection of payment card account data. This not only helps mitigate risks and potential financial liabilities but also fosters trust among customers, partners, and the broader payment industry.

In conclusion, compliance with Payment Brands’ PCI DSS requirements is essential for financial institutions and organisations with contractual agreements. By following the guidelines, securing payment card account data, implementing robust security measures, and remaining vigilant against potential threats, these entities can contribute to a safer and more secure payment environment for all stakeholders involved.

Remember, PCI DSS compliance is an ongoing journey, and staying proactive in maintaining security safeguards is paramount in the dynamic landscape of electronic payments.



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