PCI 2.0 Or 1.2—The Choice Is Yours, For Now

Written by Walter Conway
November 4th, 2010

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

Which version of PCI should you use to validate your compliance? Although Version 2.0 was recently released, it is not effective until Jan. 1, 2011, after which time it will exist in parallel with the current version—1.2. That means for all of 2011 retailers will have the option of using either version to validate their compliance.

On the surface, the differences between the two versions do not appear significant. So why would you not want to validate using the latest and greatest? Looking deeper, however, shows that one change in Version 2.0 could have an impact on your decision. That change is the new guidance on scoping.

For retailers and processors with a fourth quarter revalidation date, there is not much of a choice: You will use Version 1.2. Although a retailer could decide to validate using 2.0 now, I’d suggest talking to your acquirer before taking that step. Waiting until January, however, means you will miss your renewal anniversary and go out of compliance, if only for a few weeks.

You don’t want to make a decision in haste because QSAs, like everyone else, are still digesting the new version. They will need to update reporting processes (including QA) and templates to reflect the changes. As such, a decision to use Version 2.0 now means that you would not have (and could not submit) your Report on Compliance (ROC) until sometime in January, at the earliest, which is well after your 2010 renewal date. Another tip: Check to make sure you don’t end up with a fine or other penalty because of this decision.

For these “fourth quarter” retailers I suggest you at least consider using 1.2 now and then starting the revalidation process using 2.0 in the first or second quarter of the new year. That approach means you will be current with the latest version a bit ahead of the game while giving yourself more time to implement the new version.

Validating early (nobody said you could not validate earlier than 12 months from your anniversary date) may also get you off the fourth quarter treadmill.

Level 2 retailers who are doing their first assessment should start debating their decision soon. They could start with Version 1.2.1 and migrate to 2.0 in a year, or they could jump right in with Version 2.0. If these retailers choose the latter course, they should not wait too long to start the validation process. A first time assessment combined with a new version of the DSS could take longer than expected.

Why would retailers, regardless of merchant level, need extra time? At least one reason is the new emphasis on accurately determining your PCI scope under 2.0.

Version 2.0 requires you to identify all locations and flows of cardholder data and to ensure they are included in your PCI DSS scope. (I guess I could point out that you should have been doing this all along. In any event, it is now required by PCI DSS.) Every merchant and processor needs to do this identification prior to their annual assessment, but at least annually.


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