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PCI DSS 3.2: 3 Things You Need to Know by Steve Zurier
Apr 28, 2016

PCI DSS 3.2: 3 Things You Need to Know The latest round of upgrades are incremental yet necessary.

The PCI Security Standards Council has outlined the main requirements for the PCI DSS 3.2 upgrade and as always, there’s plenty of time for businesses to prepare for the changes.

Troy Leach, chief technology officer of the council, underscores that the whole point is to give organizations enough time to work with the new requirements.

“In some cases, such as migrating away from SSL and early TLS, organizations have more than two years to transition to the new requirements as long as they demonstrate a strategy for migration,” he explains.

Julie Conroy, research director for the retail banking practice at the Aite Group, says PCI DSS 3.2 comes on the heels of PCI DSS 3.1, which was only released a year ago.

“While the PCI Council is still discussing with members whether it will move to more frequent, smaller releases instead of a release every two years, I think it shows that they are trying to respond as criminals innovate and create new threat vectors,” Conroy explains. “While this is a good thing, of course it puts the burden on the people who have to comply.”

Here’s a thumbnail of the most important changes in PCI DSS 3.2:

Additional multi-factor authentication. Verizon’s 2016 Data Breach Investigations Report found that 63 percent of confirmed breaches involved weak, default or stolen passwords. The report goes on to recommend that company’s avoid single-factor authentication. PCI’s Leach says the trend outlined in the Verizon report is why PCI DSS 3.2 requires that system administrators working internally who access a Cardholder Data Environment (CDE) must utilize multi-factor authentication. He says with the threat landscape as dangerous as it is today, single-factor authentication for local access to a CDE is no longer acceptable. Leach adds that multi-factor authentication for remote access to a CDE has been a part of the PCI DSS standard from the outset. Organizations have until February 1, 2018 to comply with this new requirement.

Added requirements for service providers. PCI DSS 3.2 will incorporate some of the Designated Entities Supplemental Validation (DESV) criteria for service providers. Among the requirements: service providers must demonstrate that they have a detection mechanism in place to respond to a failure with critical security controls; they must conduct penetration tests on the segmentation of the network at least twice a year; run quarterly checks to ensure that their personnel are following security policies and procedures; and top executives at service providers must demonstrate an understanding of PCI DSS compliance.

Extended migration dates for SSL/early TLS. When it became clear that there were serious vulnerabilities in SSL and early TLS, the PCI Council removed SSL as an example of strong encryption from the PCI Data Security Standard, requiring migration from SSL and TLS 1.0 to a secure version of TLS (currently v1.1 or higher) by July 1, 2016. Leach says this caused some concern in the marketplace because companies depends so heavily on other entities that use SSL. To ease the transition, the PCI Council has pushed back the migration deadline to July 1, 2018. PCI DSS 3.2 also includes a migration appendix to help companies make the transition in a logical manner.

While PCI DSS 3.2 will be the major news coming out of the PCI Council in 2016, Leach adds that there are numerous other initiatives forthcoming later this year. For starters, the council will issue payment security guidance for SMBs this summer, and will also offer training programs for qualified installers to SMBs, and PCI DSS training geared towards merchant banks.

“We are really making a strong effort to reach the SMB community,” Leach says. “The program for merchant banks is also important because they have a very challenging time interfacing with all their merchants and the role of PCI compliance plays to better secure payment environments.”

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