Evan Schuman's StorefrontBacktalk

This increased rigor is good, and it should benefit merchants. It may also result in validation logjams involving software vendors and their PA-QSAs if there are delays beginning their revalidations, and then further logjams if a pile of ROVs all show up on the PCI SSC’s doorstep in mid-October.

Memo to application vendors: You may want to think about scheduling your PA-QSA’s time now (if you have not already), and be sure to allow adequate time for the PCI SSC review process in your planning, too. Vendors need to remember they won’t be the only one in the PCI SSC’s queue. I know that PA-QSA firms will be gearing up for the expected rush in ROV renewals, and I’m pretty sure they also hope the application vendors will similarly plan ahead.

As the PCI SSC notes, vendors should anticipate changes in “pricing and process” that can affect the timing and, possibly, the cost of their new ROV. Your PA-QSA will be aware of the October deadline. I am sure they, too, have read the part of the FAQ that states: “Assessors are expected to perform a fresh assessment each time, as the results from previous assessments are not necessarily relevant for a current assessment.”

The message for merchants is to stay on top of developments with your payment application vendor. If you have a payment application with a PA-DSS expiry of October, contact your vendor and find out when you can expect the updated version. Visa and MasterCard have not changed their mandates that merchants use PA-DSS validated applications. That means merchants also must budget the time and resources to upgrade their payment applications this summer (if you are lucky) or autumn.

What if a merchant’s payment application vendor is late and misses the Oct. 28, 2013, expiry or the merchant cannot install the application in time? If merchants have a properly installed (per the vendor’s PA-DSS Implementation Guide) and validated application, they should still be in compliance with the Visa and MasterCard mandates—at least for now. However, those merchants could end up with an application that is no longer maintained by the vendor or that will no longer receive security patches or updates and, therefore, may increase their vulnerability to a data breach with each passing day.

Although the October 28 sunset for PA-DSS primarily affects payment application vendors, merchants will also be impacted. Merchants must plan now for a summer/autumn payment application upgrade. Otherwise, they will need to plan on supporting an expired application that—although possibly still secure—is approaching its end-of-life. Spinning through the list of PA-DSS validated applications, quite a number appear to be facing the October 28 validation deadline. I suggest merchants check their own applications on the PCI SSC’s list and assess their upgrade strategy.

What do you think? I’d like to hear your thoughts. Either leave a comment or E-mail me.