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Missed the PCI DSS v4.0.1 compliance deadline? How retailers can catch up quickly

By Sam Peters, Chief Product Officer, ISMS.online

Retailers have long been at the cutting-edge of payment innovation.

From cloud computing and smart devices to advanced POS systems, new technologies are enabling industry players to continually enhance the customer experience and streamline operations.

However, there is a less desirable side to this ecommerce evolution.

Retailers are no longer just selling products. They’ve become the custodians of treasure troves of sensitive data and proprietary software that have turned them into prime targets for threat actors.

Indeed, cybercriminals are more determined than ever to steal credit card details, intellectual property, and retail data that can be used to fingerprint customers, their digital footprints, and their behaviours. The statistics are alarming. Nearly one in four cyberattacks are now aimed at the retail sector. Further, £1.7 million is lost to card fraud each month in the UK alone, with hackers increasingly exploiting website vulnerabilities to try and intercept customer data before it reaches secure payment gateways.

PCI DSS can help protect both retailers and consumers

The threats facing retailers are ramping up – but thankfully, so too are security requirements.

Today, any retailer or merchant that accepts credit or debit cards must comply with the Payment Card Industry Data Security Standard (PCI DSS).

In simple terms these controls govern how payment card data is handled, with the aim of protecting customers and keeping transaction data secure. By helping to minimise data breaches, fraud and identity theft, these standards also help retailers to avoid costly legal and financial fallouts.

To achieve this, the standard has been built on several core principles that advise retailers and merchants to take key steps such as building and maintaining a secure network, implementing strong access control measures, and protecting cardholder data. However, given that PCI DSS was first introduced in 2006, those principles have naturally had to shift and evolve over time.

We saw this in March 2024 when the fourth iteration of PCI DSS, v.4.0, came into effect. Critically, this introduced 60 new requirements, with a much greater focus on flexibility and allowing businesses to achieve compliance in a manner tailored to their specific circumstances. More recently, however, we’ve seen the introduction of PCI DSS v.4.0.1.

As a limited revision, v4.0.1 hasn’t added any entirely new requirements beyond what was already outlined in v4.0. What it does include is guidance refinements relating to client-side payment security and payment page protection with the goal of ensuring more effective implementation.

However, crucially, the mandatory compliance deadline for this v4.0.1 passed on 31 March 2025.

For any retailer that missed this deadline, it is vital to catch up and achieve compliance as a quickly as possible. Not only does non-compliance with PCI DSS put customer payment data security under threat, but it can also expose retailers to severe ramifications such as hefty fines from regulatory bodies.

Beyond these immediate financial impacts, non-compliance can also lead to halted payment processing, reputational damages, a loss of customer trust, and an increased vulnerability to data breaches – all of which can have long-lasting impacts.

So, how exactly can retailers that missed the 31 March deadline respond, rectifying their compliance at speed?

Steps to comply with v4.0.1

Before anything else, any retailer will need to understand their compliance level.

PCI DSS compliance isn’t a blanket, one-size-fits-all set of rules. Instead, requirements vary based on annual transaction card volumes, ranging from under 20,000 (Level 4) to over six million (Level 1).

Once you have identified which level applies to your business, you will be able to define the scope of your compliance obligations and then begin to compare your current security posture to those requirements.

Here, you can identify any gaps that may need to be bridged with new or updated policies and controls. That may include configuring firewalls, encrypting data transmissions, setting up robust access controls, and putting in place the key client-side security measures, many of which were particularly emphasised in the latest iteration of PCI DSS v4.0.1.

Once that has been done, and compliance has been achieved, it is important not to forget about PCI DSS altogether. With this security standard continuing to evolve among others, it is crucially important for retailers to establish robust governance practices to ensure future compliance deadlines aren’t missed.

In a fast-moving retail landscape, compliance should be seen as a means of monitoring, testing and improving your security posture over time. By embracing relevant best practices, you will be well placed to address issues quickly and effectively, and meet assessment demands in a timelier manner.

Put the building blocks in place now, and you’ll reap the rewards – be it in relation to PCI DSS or otherwise – on a continuous basis moving forward.

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