PCI Mobile Madness: Council Clarifications Not Helping

Written by Evan Schuman
February 10th, 2011

The intersection of PCI and mobile—an admittedly murky place—is getting more complicated. The PCI Council has pledged that it won’t validate any more mobile applications for quite some time, at least not until it can determine what the best criteria are. Questions have now cropped up about the handful of mobile applications that had already been PCI validated.

The Council is in a very difficult position (between a ROC and a hard token place?), especially because it must give as much attention to political issues as it does to technological ones. In this case, the politics are not of the Washington, D.C., sort, but of the industry.

Specifically, how to deal with the concerns of the many mobile application developers whose apps now cannot even be considered for PCI validation, especially when they complain of their rivals, who happened to have slipped in before PCI closed the evaluation door.

Should the few already approved applications be delisted, so that all mobile applications can be evaluated at the same time, using the exact same criteria? Is that the fair approach? And what about the applications that were on that approved list? What’s the reason for delisting them, given that no specific security hole has been discovered?

It’s hard to tell a vendor, “We need to take you off the approved list because we’ve decided that didn’t know what we were doing when we approved you.” It’s actually closer to “We thought we knew. But upon reflection and industry changes, we’ve concluded that we need to re-evaluate everything.”

This situation gets worse. What’s the impact on retailers? As for the delisting situation, what should a merchant who used one of those listed apps do?

If it’s delisted for the reasons stated above (as opposed to the discovery of a critical security hole), would chains risk PCI compliance by not immediately removing an app?

And if those apps are not delisted, can retailers use them with confidence, knowing that PCI is going to completely rewrite its mobile rules? From a different perspective, in the months before PCI makes up its mobile mind, will retailers have to choose from the handful of already listed mobile apps (we counted three) because they are the only ones approved?


4 Comments | Read PCI Mobile Madness: Council Clarifications Not Helping

  1. Emma Jenkins Says:

    A ROC and a hard place. Evan, you crack me up!


  2. Ernie Says:

    It shouldn’t come as a surprise to anyone that the mobile evolution is causing strain on current standards. It didn’t really exist when the standards were contemplated. Now we’re playing catch up. But the evolution and adoption isn’t going to slow, because PCI isn’t ready for mobile. We might see some Level 1 and 2 merchants delay programs until PCI sorts out their thoughts. Others will run the risk hoping for a competitive advantage. That should make for interesting conversation with their QSA, if they choose to disclose it.

    The Level 4 merchants don’t know this debate is happening. Mobile apps are start popping up all over as small entrepreneurs look for a competitive edge. That trend will only increase. PCI could petition the app platform companies to disallow payment applications from being available for download to consumer devices, but that seems like a stretch.

    The longer PCI takes to get its position in place, the higher the likelihood that the requirements get ignored or marginalized.

  3. Chris Says:

    If I’m not mistaken, I believe the PCI SSC has already addressed approved applications being delisted in its statement from January 25, 2011: “Until it has completed a comprehensive examination of the mobile communications device and mobile payment application landscape, the Council will not approve *or list* (my emphasis) mobile payment applications used by merchants to accept and process payment for goods and services as validated PA-DSS applications unless all PA-DSS requirements can be satisfied as stated and the underlying mobile communications device supports the merchant’s PCI DSS compliance.”

    It appears this statement indicates that it is only a matter of time until the approved applications are delisted.

  4. Evan Schuman Says:

    We saw that, too, but it’s still subject to interpretation.


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