Why PCI 1.2 Ignoring Virtualization Won’t Matter

Written by Evan Schuman
August 21st, 2008

GuestView Columnist David Taylor is the Founder of the PCI Knowledge Base, Research Director of the PCI Alliance and a former E-Commerce and Security analyst with Gartner.

Based on the PCI Standards Committee’s official "hint" about what will be in the 1.2 release, it appears that clarifying when and how virtualized servers can be PCI compliant didn’t make the cut. But before the server and security geeks start lighting their torches and getting all "vigilante" on the card brands, let me tell you why I don’t think this will matter.

Virtualization saves money. As a technology, virtualization—particularly server virtualization—is saving retailers money on hardware and IT management. In a down economy, cost reduction trumps compliance. Where virtualized servers and PCI compliance come to blows is PCI DSS 2.2.1, which says only one primary function per server. Because some merchants, assessors and acquirers think "physical server" when they read this standard, some merchants have limited the deployment of server virtualization to the dev/test environment.

Other merchants are making sure not to deploy server virtualization in the cardholder environment. Still others are deploying virtualized servers for applications with credit card, SSN and other confidential data, but they are careful not to put applications with different "trust levels" for different levels of access controls on the same physical server. The point is that if you want to use virtualization to reduce your IT costs, you just need to be careful about what applications you put on what types of servers.

Proof that virtualization is secure. We recently did a Webinar on the topic of how to prove that virtualized servers are secure enough to pass PCI assessments. Based on interviews with more than a dozen PCI assessors for the PCI Knowledge Base, it’s clear that in more than 75 percent of the cases we’ve reviewed, the retailers can prove that their virtualization is sufficiently secure to also be compliant. What is lacking in some cases is the documentation of their procedures.

In other cases, the merchants will need to upgrade their other controls, such as their intrusion detection systems and their audit and logging tools. But we’re not talking about wholesale security upgrades. The bottom line is that you can prove that virtualization is secure enough to pass PCI audits. But is it worth the money to do so?

The cost of secure virtualization. One of the issues with virtualization of servers is that many applications and management software tools have not yet been "upgraded" to work with virtualized environments.

Although security software is the issue for PCI compliance, the actual problem is even broader. Despite how long virtualization has been around, we’re finding that some retailers are being told by their application software vendors that they will not warrant the security and certain functionality of their products in virtualized environments.

The issue is more than just PCI compliance. It’s about reliability, performance and data integrity. The point is that deciding whether to deploy virtualized servers broadly throughout the enterprise should not hinge on PCI compliance. Once the larger application and management issues are addressed to the satisfaction of the head of IT infrastructure, and the controls documentation is put in place, then PCI compliance becomes a minor issue by comparison.

Don’t wait for the standards committee. The fact is, technology always changes faster than standards can be developed and updated. Does anyone remember the seven-layer ISO model? I do. As a Gartner analyst in the 1980’s and 90’s I still remember how many companies put off making networking changes to keep their internal networks secure because they wanted to stay in line with the standards. At the same time, the companies that embraced the Internet’s technology "one-upmanship" approach won the day. Focus on providing a reliable, cost-effective IT infrastructure and document your controls, and PCI compliance can be achieved, regardless of what the current version of the standard says.

By the way, if you’re a retailer, we want to get you involved in the best practices study we’re doing for the National Retail Federation. If you’d like to participate, send me an E-mail at


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