Picus Labs | 18 MIN READ

CREATED ON December 30, 2025

A Practical Guide to PCI DSS Compliance Using Picus

Executive Summary

PCI DSS v3.2.1 was retired on March 31, 2024, and PCI DSS v4.0 (v4.0.1) is now the baseline for all assessments.

The easiest way to respond to that shift is to treat it as another version bump followed by another audit sprint. A more effective approach is to understand what the updated language is actually pushing organizations toward: proof over paperwork.

Across PCI DSS v4.0, the emphasis shifts away from passive verification, where policies exist, and controls are deployed, toward active validation, where controls actually block, detect, and contain the attack paths that matter in your environment. This shift is intentional. The standard increasingly expects organizations to demonstrate that security controls work in practice, not just in design.

That is also why Targeted Risk Analysis (TRA) matters more than ever. When risk is used to justify control frequency or testing cadence, “annual testing” can no longer be treated as a safe default. Organizations need defensible, current data that shows testing frequency is aligned with real exposure, real attack paths, and real business impact.

This is where Picus fundamentally changes the compliance experience. The Picus Security Validation Platform continuously validates security controls using safe, production-friendly attack simulations, converting the results into objective, audit-ready evidence. Instead of collecting screenshots or point-in-time artifacts and hoping controls behave the same way next quarter, security teams can continuously demonstrate what their controls stop, what they miss, and what needs to be fixed first. That same evidence naturally supports a strong Targeted Risk Analysis, because it is grounded in observed outcomes rather than assumptions or static risk scores.

This shift becomes even more critical for organizations adopting the Customized Approach in PCI DSS v4.0. Unlike the prescriptive Defined Approach, the Customized Approach allows alternative security controls, as long as they meet the requirement’s stated objective. That flexibility also raises the bar for proof. Picus provides the objective evidence needed to show that custom or compensating controls genuinely meet the intent of the requirement, validating effectiveness rather than relying on theoretical equivalence.

The core compliance value is straightforward:

Generate controlled “stimulus” (safe attack simulations and emulations).
Observe whether controls block, detect, or allow the behaviour.
Produce reports and audit trails that show control effectiveness and drift over time.
Drive remediation with specific guidance, including vendor-specific prevention and detection improvements.

Summary Table: PCI DSS v4.0.1 Requirements to Picus Capabilities

PCI DSS requirement	Primary compliance goal	What Picus validates and the evidence it produces
1. Install and Maintain Network Security Controls	Protect the CDE with enforced network boundaries and segmentation	Validates inbound and outbound restrictions, segmentation isolation, lateral movement blocking, and control drift; produces network control validation reports, segmentation test evidence, and detection confirmation for network-based attack activity
2. Apply Secure Configurations to All System Components	Ensure hardened configurations are implemented and cannot be exploited	Tests default credentials, insecure protocols, isolation between tiers, and misconfiguration exploitability; produces proof of policy enforcement through attack outcomes, plus drift and remediation evidence over time
3. Protect Stored Account Data	Prevent unauthorized access to stored PAN and stop data movement and exfiltration	Simulates access and exfiltration attempts against data stores, validates DLP and egress controls, and proves whether attack paths can reach storage systems; produces exfiltration validation results, path evidence to data repositories, and monitoring readiness signals
4. Protect Cardholder Data During Transmission Over Open, Public Networks	Ensure PAN is protected in transit, and channels resist interception and downgrade	Simulates interception style scenarios and validates protocol and certificate enforcement; produces evidence that strong cryptography is consistently applied and that insecure downgrade conditions are not accepted
5. Protect All Systems and Networks from Malicious Software	Ensure malware protections are active and effective, including phishing resistance	Validates anti-malware efficacy with safe malware behaviours, tests phishing vectors, and maps ransomware blast radius through identity and lateral movement; produces block and detect outcomes, control health evidence, and prioritized hardening focus areas
6. Develop and Maintain Secure Systems and Software	Identify vulnerabilities, prioritize remediation, and validate web attack protections	Validates exploitability in the real environment, prioritizes fixes using threat signals plus control effectiveness, tests WAF protection against common web attacks, supports compensating control validation, produces exposure prioritisation outputs, exploitability evidence, WAF test results, and attack path driven remediation targets
7. Restrict Access by Business Need to Know	Enforce least privilege and prevent unauthorized movement toward the CDE	Simulates lateral movement from low-privilege footholds, tests privilege boundaries and escalation paths, and validates cloud IAM over permissioning; produces attack path evidence for least privilege gaps and detection readiness for access abuse
8. Identify Users and Authenticate Access to System Components	Enforce strong authentication, lockouts, and MFA for access to the CDE	Simulates brute force password cracking and checks password policy weaknesses
10. Log and Monitor All Access to System Components and Cardholder Data	Ensure logging, alerting, and monitoring actually work end-to-end	Uses controlled attack stimulus to validate log generation and alerting, and checks detection rule health and required log sources; produces proof that the monitoring layer sees what it should and highlights silent failures before an audit or incident
11. Test Security of Systems and Networks Regularly	Make testing continuous, including segmentation and intrusion detection validation	Automates frequent control tests, exploitability validation, segmentation checks, and IDS and IPS trigger testing; produces repeatable testing evidence, change impact validation, and current assurance that security testing is ongoing
12. Support Information Security with Organisational Policies and Programs	Use evidence to drive governance, risk decisions, and response readiness	Provides empirical outcomes for targeted risk analysis, supports incident response exercises using safe simulations, and strengthens evidence-based compliance reporting; produces data-driven metrics that link policy intent to technical reality

In the sections that follow, this guide provides a practical, requirement-by-requirement mapping of PCI DSS v4.0 to Picus capabilities, highlighting exactly which sub-requirements can be validated, what evidence is produced, and how that evidence supports both formal assessments and ongoing governance.

PCI DSS v4.0.1 Requirement Mapping to Picus Capabilities

This section maps each PCI DSS v4.0.1 requirement to the Picus Security Validation Platform modules that help you validate control effectiveness and produce defensible evidence for assessment. Picus integrates with SIEM, EDR, network security, vulnerability management, SOAR, and ticketing so that validation results can be verified end-to-end and operationalized into tracked remediation.

Picus products referenced in this mapping:

Security Control Validation (SCV): Breach and Attack Simulation that tests whether a specific control blocks or detects a particular technique, backed by an extensive threat library and vendor-specific mitigations.
Exposure Validation (EXV): Adversarial Exposure Validation that prioritizes exposure using severity, threat signals (EPSS, KEV), asset criticality, and control effectiveness data from SCV, including scanner integration and compensating control validation.
Attack Path Validation (APV): Automated penetration testing and attack path validation focused on lateral movement and privilege escalation, including choke point identification.
Attack Surface Validation (ASV): Unified asset inventory plus shadow IT discovery to validate scope and visibility.
Cloud Security Validation (CSV): Cloud control plane auditing plus IAM analysis and cloud native attack simulations.
Detection Rule Validation (DRV): Detection engineering validation, including silent rule failure detection and log source validation.

Requirement 1: Install and Maintain Network Security Controls

Picus coverage: SCV, APV, DRV, ASV, CSV

Mapping to PCI DSS v4.0.1

Prove policies are operational, not just documented, by producing outcome evidence that supports processes and roles expectations (1.1.1, 1.1.2).
Validate inbound controls into the CDE by simulating unauthorized access attempts and confirming deny by default behaviour (1.3.1).
Validate outbound controls from the CDE by simulating command and control and exfiltration style traffic to confirm only necessary egress is allowed (1.3.2).
Validate boundary placement and CDE isolation by proving NSCs exist between trusted and untrusted networks and that cardholder data systems are not directly accessible from untrusted networks (1.4.1, 1.4.4).
Support network change control verification by repeating the exact simulation after NSC changes to confirm changes cannot introduce insecure connectivity (1.2.2, 6.5.1).
Support NSC review and configuration integrity with repeatable validation that highlights drift and functional failures, supporting six-month review and configuration file consistency objectives (1.2.7, 1.2.8).
Validate dual-homed endpoint protections by continuously confirming security controls are active that connect to the internet and the CDE (1.5.1).

Requirement 2: Apply Secure Configurations to All System Components

Picus coverage: SCV, APV, ASV, CSV, EXV

Mapping to PCI DSS v4.0.1

Test vendor default exposure by attempting to authenticate with default accounts or by proving that default passwords have been changed (2.2.2).
Validate that only necessary services are enabled by simulating attacker techniques that depend on unnecessary services, protocols, daemons, and functions (2.2.4).
Validate compensating protections for insecure services by demonstrating that the added security features effectively reduce risk in practice (2.2.5).
Validate secure parameterization by testing misuse paths that depend on weak system security parameters (2.2.6).
Validate isolation between functions with different security levels by mapping and testing lateral movement (2.2.3).
Reduce scope blind spots by using ASV to identify unmanaged assets or systems missing sensors, which helps prevent out-of-standard configuration from going unnoticed.
Extend secure configuration into cloud control planes using Picus CSV audits against benchmarks, plus IAM analysis for over-permissive roles.

Requirement 3: Protect Stored Account Data

Picus coverage: SCV, APV, EXV, DRV, CSV

Mapping to PCI DSS v4.0.1

Support retention and disposal controls with exposure evidence by validating whether stored account data systems can be reached or abused via common attack paths (3.2.1).
Validate remote access controls that prevent copying PAN by testing whether technical controls like DLP stop the copying or relocation of PAN via remote access technologies (3.4.2).
Validate access restrictions to stored PAN by attempting unauthorized access paths into repositories and validating whether controls prevent retrieval outcomes (supports the intent of 3.5.1).
Prove no viable path to data stores by using Picus APV to identify whether a low privilege foothold can reach databases or file shares through lateral movement and privilege escalation.
Prioritize weaknesses impacting storage systems using Picus EXV risk scoring, which factors in control effectiveness, threat signals, and asset criticality, supporting defensible remediation ordering.
Strengthen detection around data access and movement with the log source validation feature of the Detection Analytics module in Picus SCV and the rule hygiene capability of Picus DRV, so the monitoring layer is not silently broken.
Cover cloud storage misconfiguration with Picus CSV findings, such as open storage, unencrypted databases, and disabled logging.

Note: Support Scope Reduction & Segmentation Checks. One of the most effective ways to lower PCI compliance costs is to reduce the scope of the scope of the Cardholder Data Environment (CDE). Use Picus APV to attempt lateral movement from non-CDE networks into the CDE. A 'blocked' result serves as definitive evidence that the networks are effectively isolated, validating your scope reduction claims and potentially removing those non-CDE assets from the assessment.

Requirement 4: Protect Cardholder Data with Strong Cryptography During Transmission Over Open, Public Networks

Picus coverage: SCV, DRV, CSV

Mapping to PCI DSS v4.0.1

Validate transmission security by simulating data exfiltration attempts over various protocols. This verifies that network controls and DLP systems effectively detect and block cleartext transmissions, ensuring that strong cryptography is strictly enforced for all data traversing public or untrusted networks. (4.2.1).
Extend validation to cloud network paths by utilizing Picus CSV auditing and cloud simulations to validate the configuration and detection posture that influence secure transmission and monitoring.

Requirement 5: Protect All Systems and Networks from Malicious Software

Picus coverage: SCV, APV, DRV, EXV

Mapping to PCI DSS v4.0.1

Validate anti-malware effectiveness by running safe malware behaviour and confirming controls detect and block or contain malware (5.2.2).
Support risk-based cadence decisions by providing outcome data that informs targeted risk analysis for periodic evaluations and scan frequency adjustments, as applicable (for example, 5.2.3.1, 5.3.2.1).
Validate phishing protections by simulating phishing vectors and confirming mechanisms that detect and protect personnel (5.4.1).
Model ransomware blast radius by using Picus APV to identify how far an intrusion can spread through credential and trust relationships, and which choke points reduce impact most.
Keep detections healthy with Picus DRV so malware and credential abuse detections do not silently fail due to broken rules or missing log sources.

Requirement 6: Develop and Maintain Secure Systems and Software

Picus coverage: EXV, SCV, APV, ASV, CSV, DRV

Mapping to PCI DSS v4.0.1

Validate exploitability in your environment using Picus APV to show which high-risk vulnerabilities are actually reachable and usable by an attacker (supports 6.3.1 risk ranking intent).
Prioritize patching with a defensible context using Picus EXV Exposure Score logic, which combines severity, threat signals, asset criticality, and control effectiveness to inform decisions. This logic can integrate with scanners to import and export prioritized lists.
Support patch timeline decisions by providing empirical validation outcomes to help organisations apply the one-month rule for critical vulnerabilities and justify timing for others through risk-based assessment (6.3.3).
Prove compensating controls when patching is constrained by validating that segmentation and IPS controls actually mitigate risk, producing audit-relevant evidence.
Validate public-facing web application protections by testing an automated technical solution in front of public-facing apps, including WAF tuning against common web attacks, and confirming logging and response behaviour (6.4.2).
Operationalize post-change verification by running the exact simulations with Picus SCV after significant changes and using results to confirm applicable PCI controls remain in place (6.5.2).
Eliminate unknown assets that undermine secure development assumptions using Picus ASV visibility and shadow IT detection, feeding better prioritization and scoping decisions.
Extend secure systems validation into the cloud via Picus CSV audits and cloud-native simulations.

Note: Validate Log Content & Fidelity. Use Picus SCV to generate controlled security events and verify integration with your SIEM. This goes beyond checking if an alert fired; it validates that the specific log fields required by Requirement 10.2.2 (e.g., user ID, type of event, success/failure indication, origin) are correctly parsed, indexed, and searchable, thereby preventing 'blind' alerts that fail during forensic analysis.

Example Scenario for Validating Compensating Controls for Legacy Systems: When patching is not feasible (e.g., legacy CDE systems), use Picus SCV to prove the effectiveness of compensating controls.

Scenario: A critical server cannot be patched for CVE-202X-XXXX.
Validation: Configure Picus to simulate attacks exploiting this specific CVE across the segment boundary.
Evidence: Produce a report showing that the Network IPS or NGFW successfully blocked the exploit payload, providing the auditor with empirical proof that the compensating control mitigates the risk effectively (Requirements 6.3.3, 12.3.1)."

Requirement 7: Restrict Access to System Components and Cardholder Data by Business Need to Know

Picus coverage: APV, SCV, DRV, CSV

Mapping to PCI DSS v4.0.1

Validate least privilege design in practice by using Picus APV to test how access and trust relationships behave under assumed breach conditions, aligning with access control model expectations (7.2.1, 7.2.2).
Expose privilege escalation choke points so remediation can collapse multiple attack paths rather than just fixing symptoms.
Validate detection coverage for access abuse using the Detection Analytics module of Picus SCV to confirm rules and log sources exist for privilege escalation, suspicious access, and lateral movement behaviours.
Cover cloud least privilege gaps using Picus CSV IAM analysis to identify overly permissive roles and potential escalation opportunities.

Requirement 8: Identify Users and Authenticate Access to System Components

Picus coverage: APV, SCV, DRV, CSV

Mapping to PCI DSS v4.0.1

Validate credential-based attack paths using Picus APV techniques, such as pass-the-hash, pass-the-ticket, Kerberoasting, password cracking, and SMB relay, to determine whether compromised credentials can access CDE assets (8.3.6).
Validate detection readiness for identity abuse with Picus DRV rule health checks and log source validation, ensuring authentication monitoring does not degrade silently.

Requirement 10: Log and Monitor All Access to System Components and Cardholder Data

Picus coverage: DRV, SCV, EXV

Mapping to PCI DSS v4.0.1

Generate controlled security events using Picus SCV so you can verify that audit logs contain the required fields for auditable events (10.2.2).
Validate log review mechanisms by producing known signals that should be detected during review workflows, including automated review mechanisms where used (10.4.2, 10.4.2.1, 10.4.1.1).
Validate failure detection expectations by using successful simulations as a high signal indicator that a critical control may be failing, supporting prompt detection and response to control failures (10.7.2).
Validate detection engineering health with Picus DRV rule hygiene analysis and log source validation to prevent silent failures where alerts appear enabled but never fire.
Close detection gaps fast by pushing validated detection content into the SIEM when required, and verifying the pipeline from technique to analyst alert.

Requirement 11: Test Security of Systems and Networks Regularly

Picus coverage: SCV, APV, EXV, DRV, ASV, CSV

Mapping to PCI DSS v4.0.1

Support internal scanning programmes with exploitability context by using validation outcomes to focus remediation on what is practical and reachable, and to support risk-based handling of lower-ranked vulnerabilities via targeted risk analysis (11.3.1.1, 12.3.1).
Support scan discipline after a significant change by using validation and confirming post-change control posture (11.3.1.3, 11.3.2.1).
Complement Approved Scanning Vendor (ASV) required external scans by using Picus EXV and Picus SCV to prioritize remediation and validate compensating controls, while Approved Scanning Vendor itself remains the needed programme requirement (11.3.2).
Enable internal penetration testing and repeatable validation by utilizing Picus APV's automated penetration testing behaviors, which align with the standard’s internal penetration testing expectations (11.4.1, 11.4.2).
Validate segmentation continuously by demonstrating that it remains effective through technical testing, including after changes (11.4.5).
Validate intrusion detection and prevention placement by generating traffic that exercises IDS and IPS coverage and validating whether controls detect or prevent covert channels and malicious behaviours where applicable (11.5.1.1).
Reduce blind spots that invalidate testing results by using Picus ASV to identify unmanaged assets and missing sensors, ensuring the testing scope accurately reflects reality.
Extend testing into cloud environments with Picus CSV audit and cloud simulation coverage.

Note: For Requirement 11.4.1 (Internal Penetration Testing), a standard vulnerability scan is insufficient. You can present the Picus Attack Path Validation (APV) report as evidence. This report explicitly documents the 'attack methodology' required by the standard, outlining distinct simulation steps for lateral movement, privilege escalation, and the exploitation of trust relationships, thereby fulfilling the requirement for a methodology-based internal test.

Requirement 12: Support Information Security with Organizational Policies and Programs

Picus coverage: EXV, SCV, APV, DRV, ASV, CSV

Mapping to PCI DSS v4.0.1

Provide defensible inputs for targeted risk analysis by supplying empirical outcomes that show what succeeds, what fails, and what is most exposed, supporting the requirement to define a process for targeted risk analyses (12.3.1).
Support incident response readiness by running safe attack exercises that validate detection, escalation, and response against documented plans, supporting incident response testing expectations (12.10.1, 12.10.2).
Support security awareness measurement by validating phishing resilience through controlled phishing style simulations that complement the training programme requirements (12.6.3, 5.4.1).
Convert validation findings into governed remediation work by leveraging integrations that create tickets, trigger SOAR actions, and document closure, thereby reducing audit scramble and improving continuous readiness.
Support continuous evidence-based compliance by maintaining proof over time that controls are operating, helping shift compliance from periodic collection to continuous validation.

Practical TRA Example: "To support Requirement 12.3.1 (Targeted Risk Analysis), replace 'annual' assumptions with data-driven frequency:

Step 1: Use Picus Exposure Validation (EXV) to quantify the threat level of a specific CDE segment.
Step 2: If EXV reveals high 'Exploitability' due to unpatchable legacy systems, increase testing cadence in Picus products.
Step 3: Use the Picus historical trend report as evidence to the QSA that your testing frequency is dynamically aligned with actual risk exposure, not just a calendar date.

Conclusion: Turn PCI DSS Into Evidence

PCI DSS v4.0 raises the bar on what “compliant” means in practice. It is no longer enough to merely show that policies exist, tools are deployed, and reviews are conducted on a calendar. Assessors are looking for proof that controls are operating as intended, that weaknesses are identified and addressed based on real risk, and that testing stays current as environments change.

That is precisely where the Picus Security Validation Platform creates leverage. Picus helps security and compliance teams move from periodic, manual evidence collection to continuous, outcome-based assurance. Across the standard, this approach enhances your ability to meet requirements that demand ongoing testing, segmentation assurance, malware protection, authentication enforcement, monitoring effectiveness, and a risk-justified cadence through Targeted Risk Analysis. Instead of preparing for PCI DSS annually, you maintain a living evidence set that reflects your true security posture.

Ultimately, Picus helps organizations achieve something PCI DSS v4 is clearly aiming for: compliance that is resilient by design. Not compliant on audit day, but verifiably protected every day.

Get your demo and turn PCI DSS requirements into audit-ready evidence.