Getting PCI DSS compliant is like preparing for a big exam. You cannot just walk into it blind, you first need to prepare, check your weak areas, next fix them, and then only face the audit. If you are here today for the roadmap, I assume you are preparing for an audit now or sometime in the future, and I hope this roadmap helps you as your preparation guide. So, let’s get started!
Step 1: List down everything in scope
The first mistake many companies make is they don’t know what is really in the PCI scope. So, start with an inventory.
- Applications: Your payment gateway (Stripe, Razorpay, PayPal, Adyen), POS software, billing apps like Zoho Billing, CRMs like Salesforce that store customer details, in-house payment apps.
- Databases: MySQL, Oracle, SQL Server, MongoDB that store PAN or related card data.
- Servers: Web servers (Apache, Nginx, IIS), application servers (Tomcat, Node.js), DB servers.
- Hardware: POS terminals, card readers, firewalls (Fortinet, Palo Alto, Checkpoint), routers, load balancers (F5).
- Cloud platforms: AWS (S3 buckets, RDS, EC2), Azure, GCP, SaaS apps that store or process card data.
- Third parties: Payment processors, outsourced call centers handling cards, hosting providers.
Write all this down in a spreadsheet. Mark which ones store, process, or transmit card data. This becomes your “scope map.”
Step 2: Do a gap check (compare with PCI DSS 4.0 requirements)
Now take the PCI DSS 4.0 standard and see what applies to you. Some basics:
- Firewalls – Do you have them configured properly or are they still at default rules?
- Passwords – Are your systems still using “welcome123” or weak defaults? PCI needs strong auth.
- Encryption – Is card data encrypted at rest (DB, disk) and in transit (TLS 1.2+)? If not, you may fail your PCI DSS compliance audit.
- Logging – Are you logging access to sensitive systems, and storing logs securely (like in Splunk, ELK, AWS CloudTrail)?
- Access control – Who has access to DB with card data? Is it limited on a need-to-know basis?
Example: If you’re running an e-commerce store on Magento and it connects to MySQL, check if your DB is encrypted and whether DB access logs are kept.
Step 3: Fix the weak spots (prioritize risks)
- If your POS terminals are outdated (like old Verifone models), replace or upgrade.
- If your AWS S3 buckets storing logs are public, fix them immediately.
- If employees are using personal laptops to process payments, enforce company-managed devices with endpoint security (like CrowdStrike, Microsoft Defender ATP).
- If your database with card data is open to all developers, restrict it to just DB admins.
Real story: A retailer I advised had their POS terminals still running Windows XP. They were shocked when I said PCI won’t even allow XP as it’s unsupported.
Step 4: Train your people
PCI DSS is not just about tech. If your staff doesn’t know, they’ll break controls.
- Train call center staff not to write card numbers on paper.
- Train IT admins to never copy card DBs to their laptops for “testing.”
- Train developers to follow secure coding (OWASP Top 10, no hard-coded keys). This not only helps with PCI but also complements SOC 2 compliance.
Example: A company using Zendesk for support had to train agents not to ask customers for card details over chat or email.
Step 5: Set up continuous monitoring
Auditors don’t just look for controls, they look for evidence.
- Centralize your logs in SIEM (Splunk, QRadar, ELK, Azure Sentinel).
- Set up alerts for failed logins, privilege escalations, or DB exports.
- Schedule vulnerability scans (Nessus, Qualys) monthly.
- Do penetration testing on your payment apps (internal and external).
Example: If you are using AWS, enable CloudTrail + GuardDuty to continuously monitor activity.
Step 6: Do a mock audit (internal readiness check)
Before the official audit, test yourself.
- Pick a PCI DSS requirement (like Requirement 8: Identify users and authenticate access). Check if you can prove strong passwords, MFA, and unique IDs.
- Review if your network diagrams, data flow diagrams, and inventories are up to date.
- Run a mock interview: ask your DB admin how they control access to the DB. If they can’t answer, it means you are not ready.
Example: I’ve seen companies that have everything in place but fail because their staff can’t explain what’s implemented.
Step 7: Engage your QSA (when you’re confident)
Finally, once you have covered all major gaps, bring in a QSA (like us at VISTA InfoSec). A QSA will validate and certify your compliance. But if you follow the above steps, the audit becomes smooth and you can avoid surprises.
We recently helped Vodafone Idea achieve PCI DSS 4.0 certification for their retail stores and payment channels. This was a large-scale environment, yet with the right roadmap (like the one above), compliance was achieved smoothly.
Remember, even the largest organizations can achieve PCI DSS 4.0 compliance if they start early, follow the roadmap step by step, and keep it practical.
Final Words: Don’t Wait Until the Audit
Most businesses panic only when the audit date gets close. But PCI DSS doesn’t work that way. If you wait till then, it’s already too late.
So, start now. Even small steps today (like training your staff or fixing one gap) move you closer to compliance.
Having trouble choosing a QSA? VISTA InfoSec is here for you!
For more than 20 years, we at VISTA InfoSec have been helping businesses across fintech, telecom, cloud service providers, retail, and payment gateways achieve and maintain PCI DSS compliance. Our team of Qualified Security Assessors (QSAs) and technical experts works with companies of every size, whether it’s a start-up launching its first payment app or a large enterprise.
So, don’t wait! Book a free PCI DSS strategy call today to discuss your roadmap. You may also book a free one-time consultation with our qualified QSA.
Narendra Sahoo (PCI QPA, PCI QSA, PCI SSF ASSESSOR, CISSP, CISA, CRISC, 27001 LA) is the Founder and Director of VISTA InfoSec, a global Information Security Consulting firm, based in the US, Singapore & India. Mr. Sahoo holds more than 25 years of experience in the IT Industry, with expertise in Information Risk Consulting, Assessment, & Compliance services. VISTA InfoSec specializes in Information Security audit, consulting and certification services which include GDPR, HIPAA, CCPA, NESA, MAS-TRM, PCI DSS Compliance & Audit, PCI PIN, SOC2 Compliance & Audit, PDPA, PDPB to name a few. The company has for years (since 2004) worked with organizations across the globe to address the Regulatory and Information Security challenges in their industry. VISTA InfoSec has been instrumental in helping top multinational companies achieve compliance and secure their IT infrastructure.
