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Windows XP End-of-Life Could Cripple PCI Compliance

Written by Walter Conway
February 6th, 2013

A 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.

PCI DSS has two sunsets coming up. The first is the well-documented end of PA-DSS v1.2 this October. The second, and equally significant, sunset is Windows XP’s end-of-life just a few months later, and this event may have an even more direct impact on retailers.

The demise of Windows XP will challenge retailers with POS or other payment applications running in that environment. These retailers will fall into one of three scenarios, described below. How they choose to address the situation will affect their PCI compliance and, more importantly, their security. There may even be a little fallout for the PCI Security Standards Council (PCI SSC) itself.

On April 8, 2014, about 14 short months from now, Windows XP will reach the end of its life as an operating system. That means that starting on April 9, 2014, Microsoft (NASDAQ:MSFT) will no longer market, support or provide regular security patches for that operating system. Retailers with POS or other payment systems running on Windows XP after this date will, therefore, no longer be PCI compliant.

Retailers running POS applications on Windows XP must act without delay. According to Microsoft: “If your organization has not started the migration to a modern desktop, you are late.”

Why does an end-of-life operating system cause a retailer to be noncompliant? After all, the term “end-of-life” appears nowhere in the PCI DSS. A search of the FAQ on the PCI SSC’s Web site also turns up nothing.

Merchants cannot continue to use a payment application based on an end-of-life operating system, because that end-of-life condition runs up against PCI DSS Requirement 6.1. This requirement states merchants must: “Ensure that all system components and software are protected from known vulnerabilities by having the latest vendor-supplied security patches installed. Install critical security patches within one month of release.” Once an operating system (or an application) goes past its end-of-life, the vendor does not keep an eye out for new vulnerabilities or release any new security patches.

In addition, and aside from PCI DSS compliance issues, retailers with end-of-life operating systems put themselves squarely in every hacker’s cardholder data breach bulls-eye. The bad guys scan merchants’ networks for weaknesses, and an end-of-life operating system may be an open invitation for them to do their worst—particularly when unpatched vulnerabilities are spotted.

Retailers with Windows XP POS or payment applications likely will fall into one of the following scenarios.

Scenario 1: “We are OK; we can migrate to my vendor’s PA-DSS validated versions for, say, Windows 7 or Windows 8.” To confirm this situation, retailers must check the PCI SSC’s list of PA-DSS validated applications. Look under the “Tested Platforms/Operating Systems” part of the table to see what options are available.

A quick check of the PA-DSS list showed many applications that run on Windows XP also have alternate validated versions available. Some questions for retailers in this scenario are: How difficult will it be to change operating systems? What other systems in the payment environment are affected? How long will it take? Do we have the internal resources and expertise for a seamless migration? What will upgrading the application cost?

Scenario 2: “We think we’ll be OK; my vendor said they will have new version in time.” It is true that some applications can simply be installed and run on a newer operating system, but the ability to function in another operating system is not enough. Each application’s PA-DSS validation must include testing for every platform. This means a vendor that had its application tested only on Windows XP needs a new assessment to test that application on, say, Windows 7.

My check of the PA-DSS list uncovered a number of validated applications with only Windows XP versions listed under Tested Platforms/Operating Systems. Therefore, although it may sound reassuring to hear that your old Windows XP POS can (possibly) run on Windows 7 or Windows 8, that fact alone is no guarantee that the version is or will be PA-DSS validated. Some questions for retailers in this scenario are: What are the vendor’s plans for PA-DSS validation? Can we see something in writing? Is the PA-QSA engaged or scheduled yet? How soon can we see the Implementation Guide, so we know what we are in for? How much will this cost?

Scenario 3: “We don’t know the impact yet, because we have a complicated POS environment.”


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9 Comments | Read Windows XP End-of-Life Could Cripple PCI Compliance

  1. Seth Says:

    Another possible solution – POSReady 2009, which we are currently investigating. Mainstream support will end April 2014, but extended support will continue to April 2019. Nothing like putting off the inevitable, but a few more years will certainly help.

  2. Lyal Collins Says:

    This is an interesting issue, pivoting largely on the interpretation of PCI 6.1. One could argue – no new vendor patches means no missing patches therefore compliant. The truth is probably in the middle – vulnerability management, mitigating controls, and possibly the messy compensating control path.

  3. Walt Conway Says:

    Thanks for the comments, Seth and Lyal.

    @Seth, I’m not too familiar with POSReady 2009, but a possible short-term stay of execution might come from XP Embedded, which is not end-of-life until 2016. That option may appear to buy you two years, but check that the application is validated for that specific operating system — either POSReady 2009 or XP Embedded — first.

    @Lyal, You raise an interesting point, but I still don’t think your solution will fly. In the case of XP, saying no new patches are available means that nobody is looking for new vulnerabilities and nobody is fixing the system. It seems pretty hard to twist that to imply no patches are available so no patching is needed. Windows 2000, anybody?

    While you mention a compensating control, and I tried to address that path in the column because it may technically be possible, actually I was doing my best to dissuade anybody from going there. I cannot see any comp control being effective.

    Beyond PCI DSS Requirement 6.1, another factor condemning Windows XP after April 2014 is contained in the ASV Program Guide. One of my colleagues pointed out to me that when you look on page 15, you’ll see it says:

    “The ASV scanning solution must also be able to determine the version of the operating system and whether it is an older version no longer supported by the vendor, in which case it must be marked as an automatic failure by the ASV.”

    That means your Windows XP earns you an automatic FAIL on the next external scan, so once again, you are not PCI compliant. I can’t imagine an ASV treating an end-of-life operating system as a false positive.

    I keep going back to Microsoft’s advice which I quoted: “If your organization has not started the migration to a modern desktop, you are late.”

    Walt

  4. John Says:

    POSready 2009 is based of the Windows XP SP3 codebase. It’s the successor of Windows Embedded POS with was initially launched based on XP Embedded.

    Windows Embedded Standard 2009 (“standard” is the new name for the toolkit version of embedded, in this case based of XP Embedded SP3).

    Both solutions will add many years to your devices without any changes on you side.

  5. Helen Sybil Says:

    We have no plans to move off XP after April 2014. Later Windows products do not meet our requirements.

  6. Lyal Collins Says:

    @Walt – Windows XP (i.e. workstations) scannable by a ASV?
    I think that has bigger issues that just being EOL – logging and firewall/Modem NAT issues to start with.

    On a related note, I have a client where the ASV scan regularly detects several servers as the incorrect version. The “record as a false positive” option for this ASV service is too hard to do every 3 months, so the finding gets ignored, once QSA validation of the actual environment takes place.

  7. Bill Says:

    First, Windows XP is still around because people like it! I wonder if anyone has considered Ubuntu Linx? The OS is straight forward and works extremely well and it’s FREE! Well, except for the profesional online support but $250 per year no bad.

  8. Mark Says:

    What about placing the XP POS terminals on an intranet network without any comunication or connection to internet by IPS, NAT, Firewall, etc.? They would only communicate with the main server on the intranet (running Windows 7 or 8) and only allow the main server communication to internet for needed functions like Credit Card transactions or like EDI to other main servers.

  9. Mark Says:

    You may want to look at this article:
    http://storefrontbacktalk.com/securityfraud/out-of-date-os-causes-pci-violation-no-but-why-let-facts-trip-up-a-marketing-letter/

    It is older but completely contradictory of this article. Change of opinion or interpretation? Either way PCI compliance doesn’t clearly state one way or another.

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