Frequently Asked Questions

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How does PCI DSS Requirement 11.3.4.1 impact timing of penetration tests for service providers?

FAQ Response

Requirement 11.3.4.1 was added to PCI DSS v3.2, and requires service providers to perform penetration testing on segmentation controls at least every six months. Prior to v3.2, service providers were required to test these controls at least annually. This requirement for greater frequency of penetration testing is a best practice until January 31, 2018, after which it becomes a requirement.

This means that, as of February 1, 2018, service providers must have a process in place to perform penetration tests of their segmentation controls at least every six months. It is not required that service providers have a penetration test of segmentation controls within the six months prior to February 1st, 2018.

The exact schedule of testing will vary for each service provider; however, all service providers will need to complete a penetration test of their segmentation controls within six months of the requirement becoming effective – that is, between February 1, 2018 and August 1, 2018.  Additionally, service providers will need to ensure that no more than 12 months passes between penetration tests during the transition from annual to six-monthly testing.

In summary, service providers should ensure that: 

  • A penetration test of their segmentation controls is performed within the 12 months prior to February 1, 2018.
  • As of February 1, 2018, they have a process in place to perform penetration tests every six months.
  • As of August 1, 2018, at least one six-monthly penetration test has occurred.
  • Penetration tests continue to be performed at least once every six months thereafter.

For PCI DSS assessments performed on or after February 1, 2018, the assessor will need to verify the above.

April 2017
Article Number 1447