Compliance

PCI DSS Penetration Testing

Unlike most frameworks, PCI DSS explicitly requires penetration testing. We test to Requirement 11.4 and document it the way assessors expect.

In plain English

What PCI DSS expects from security testing

PCI DSS is one of the few security standards that explicitly requires penetration testing. Requirement 11.4 sets out what the test must cover, how often it must run and what happens to the findings.

In short: you need a documented methodology, internal and external tests at least once every 12 months and after significant changes, correction and retesting of exploitable findings, and, if you use segmentation to reduce scope, proof that the segmentation works. Service providers must test segmentation every six months.

The current version is PCI DSS v4.0.1, published in June 2024 as a limited revision of v4.0. Version 4.0 was retired at the end of 2024. Your assessor makes the final call on whether your testing meets the requirement.

Evidence

How our report supports it

  • A documented methodology that addresses the elements Requirement 11.4.1 asks for
  • Separate internal and external testing results, mapped to 11.4.2 and 11.4.3
  • Segmentation test results showing whether out-of-scope networks are isolated from the CDE
  • Retest evidence that exploitable findings were corrected, as 11.4.4 requires
  • Dates, scope and tester independence stated clearly for your QSA or self-assessment

Scope

Recommended scope

Every environment is different. This is where we usually start, and we'll confirm it on a scoping call.

Timing

When to test

  1. Schedule testing well before your assessment date, with time for fixes and a retest.

  2. Retest after significant changes, not just annually. Requirements 11.4.2 and 11.4.3 call for both.

  3. Service providers using segmentation need segmentation tests every six months. Put both dates in the calendar.

  4. Confirm your CDE boundary and segmentation design before testing, so the scope matches what your assessor will review.

FAQ

PCI DSS testing questions

Which version of PCI DSS do you test against?

PCI DSS v4.0.1, the current version. It replaced v4.0, which was retired on 31 December 2024. v4.0.1 was a limited revision, so penetration testing requirements are the same as in v4.0.

Do we need both internal and external testing?

Yes. Requirements 11.4.2 and 11.4.3 cover internal and external testing separately, each at least every 12 months and after significant changes.

What is segmentation testing?

If you use network segmentation to keep systems out of PCI scope, you have to prove it works. We test from out-of-scope networks to confirm they can't reach the cardholder data environment.

Does the tester need to be independent?

PCI DSS requires testing by a qualified internal resource or a qualified external third party, with organisational independence from the systems being tested. An external firm such as ours meets the independence point by default.

Does a penetration test make us PCI DSS compliant?

No. Compliance is validated through your PCI DSS assessment, by a Qualified Security Assessor, an internal assessor or a self-assessment questionnaire. Our penetration test reports are evidence for that assessment.

Need a pentest for an audit, a customer, or peace of mind?

Tell us what you need tested. You’ll get a fixed-fee proposal with tester-days and timeline stated, usually within a few days of the scoping call.