PCI-DSS Compliance in Australia: Requirements, Process, and Best Practices

Payment card fraud and data breaches remain persistent threats to Australian organisations that process, store, or transmit cardholder data. In 2024, the average cost of a data breach in Australia reached $4.2 million, with payment card data among the most targeted information types (IBM Security, 2024). PCI-DSS compliance provides a structured framework to protect cardholder data, reduce breach risk, and maintain trust with customers and payment brands.

This guide explains PCI DSS compliance requirements, the certification process, and practical strategies for Australian organisations across retail, hospitality, financial services, and e-commerce. Furthermore, we outline how CyberPulse’s PCI DSS Compliance Services support organisations in achieving and maintaining compliance efficiently.

What Is PCI-DSS Compliance?

The Payment Card Industry Data Security Standard (PCI DSS) is a global information security standard that the PCI Security Standards Council established in 2004. The council comprises major payment card brands including Visa, Mastercard, American Express, Discover, and JCB. PCI DSS applies to all organisations that accept, process, store, or transmit payment card data, regardless of size or transaction volume.

Compliance represents both a contractual obligation and a critical risk management practice. Organisations that fail to meet PCI DSS requirements face financial penalties, increased transaction fees, loss of payment processing privileges, and potential liability in the event of a breach. In Australia, non-compliance can also trigger obligations under the Office of the Australian Information Commissioner’s (OAIC) Notifiable Data Breaches scheme, which requires organisations to notify affected individuals and the regulator following eligible data breaches (OAIC, 2023).

PCI DSS compliance is not a one-time certification. Instead, it requires continuous monitoring, quarterly vulnerability scanning, and annual reassessment to maintain validated status. Organisations must adapt their security controls as their payment infrastructure evolves, new threats emerge, and the standard itself updates. Consequently, many organisations engage compliance specialists to manage this ongoing responsibility.

Understanding the 12 PCI DSS Compliance Requirements

PCI DSS structures itself around 12 high-level requirements organised into six control objectives. These requirements address network security, data protection, vulnerability management, access control, monitoring, and governance.

Requirement 1: Install and maintain network security controls

Organisations must deploy firewalls and routers to protect the cardholder data environment (CDE) from untrusted networks. Network segmentation isolates payment systems from other business networks. Firewall rules require documentation, regular review, and configuration to deny all traffic by default except for explicitly authorised connections.

Requirement 2: Apply secure configurations to all system components

Organisations must remove or disable default passwords, unnecessary services, and insecure protocols. System configurations require hardening according to industry standards such as the Center for Internet Security (CIS) benchmarks. Additionally, organisations must maintain and verify configuration baselines periodically to detect unauthorised changes.

Requirement 3: Protect stored cardholder data

Organisations must never store sensitive authentication data, including full magnetic stripe data, card verification codes (CVV2), and PINs after authorisation. Encryption, truncation, tokenisation, or hashing renders primary account numbers (PANs) unreadable. Data retention policies must limit storage duration to business necessity only.

Requirement 4: Protect cardholder data with strong cryptography during transmission over open, public networks

Strong cryptography such as TLS 1.2 or higher encrypts cardholder data transmitted across public networks. Wireless networks transmitting cardholder data require WPA2 or WPA3 encryption. Moreover, organisations must manage encryption keys securely with strict access controls and rotation policies.

Requirement 5: Protect all systems and networks from malicious software

Organisations must deploy anti-malware solutions on all systems commonly affected by malware. Regular updates maintain definitions, and monitoring logs captures detection events. Organisations must evaluate systems not commonly affected by malware periodically to determine if malware protection becomes necessary.

Requirement 6: Develop and maintain secure systems and software

Vulnerability scanning and penetration testing identify security vulnerabilities. Organisations must apply critical patches within one month of release. Secure development practices, including code reviews and security testing, integrate into the software development lifecycle. Therefore, organisations must maintain an inventory of system components and track patch status continuously.

Requirement 7: Restrict access to system components and cardholder data by business need to know

Organisations must limit access to cardholder data to personnel whose job function requires it. Role-based access controls (RBAC) enforce these restrictions, and quarterly reviews verify access rights. Organisations must replace default “allow all” privileges with “deny all” configurations that include explicit exceptions.

Requirement 8: Identify users and authenticate access to system components

All users need unique IDs before accessing the CDE. Multi-factor authentication (MFA) applies to all CDE access, including administrative access and remote access. Password policies enforce complexity, length, and expiration requirements. Furthermore, organisations must disable inactive accounts within 90 days.

Requirement 9: Restrict physical access to cardholder data

Badge systems, locks, or surveillance restrict physical access to systems that store, process, or transmit cardholder data. Organisations must log and escort visitors. Media containing cardholder data requires inventory management, secure storage, and destruction when no longer needed.

Requirement 10: Log and monitor all access to system components and cardholder data

Organisations must enable audit logs for all access to cardholder data and system components. Logs must include user identification, event type, date and time, success or failure, origination, and affected resources. Daily log reviews verify security, and organisations must retain logs for at least one year.

Requirement 11: Test security of systems and networks regularly

Organisations must conduct internal and external vulnerability scans at least quarterly and after significant changes. An Approved Scanning Vendor (ASV) performs external scans. Annual penetration testing occurs after significant infrastructure changes. Intrusion detection and prevention systems monitor network traffic for suspicious activity.

Requirement 12: Support information security with organisational policies and programs

Organisations must establish, publish, and maintain a comprehensive information security policy. Annual security awareness training reaches all personnel upon hire. Documented incident response procedures require testing and maintenance. Risk assessment methodologies need definition and annual application. In addition, organisations must conduct due diligence assessments on service providers to verify their PCI DSS compliance status.

PCI DSS Merchant and Service Provider Levels

PCI DSS defines merchant and service provider levels based on annual transaction volume. These levels determine validation requirements, including whether organisations need a self-assessment or an on-site audit by a Qualified Security Assessor (QSA).

Merchant Levels:

• Level 1 organisations process over 6 million transactions annually and require an annual Report on Compliance (ROC) by a QSA or internal auditor plus quarterly ASV scans.
• Level 2 organisations process 1 million to 6 million transactions annually and require an annual Self-Assessment Questionnaire (SAQ) plus quarterly ASV scans.
• Level 3 organisations process 20,000 to 1 million e-commerce transactions annually and require an annual SAQ plus quarterly ASV scans.
• Level 4 organisations process fewer than 20,000 e-commerce or fewer than 1 million total transactions annually and require an annual SAQ plus quarterly ASV scans, though requirements vary by payment brand.

Service Provider Level 1 organisations process over 300,000 transactions annually and require an annual ROC by QSA plus quarterly ASV scans.

Service Provider Level 2 organisations process fewer than 300,000 transactions annually and require an annual SAQ plus quarterly ASV scans.

Payment brands may impose stricter requirements based on risk assessments or breach history. Consequently, organisations should confirm their specific obligations with their acquiring bank or payment brand.

Self-Assessment Questionnaires (SAQs) Explained

Self-Assessment Questionnaires (SAQs) serve as validation tools for merchants and service providers that do not require an on-site audit. The PCI Security Standards Council publishes nine SAQ types, each tailored to specific payment processing environments.

SAQ A

SAQ A applies to card-not-present merchants that have fully outsourced payment processing to PCI DSS-compliant third parties with no electronic cardholder data storage, processing, or transmission on merchant systems. This shortest SAQ contains approximately 22 questions.

SAQ A-EP

SAQ A-EP applies to e-commerce merchants that outsource payment processing but whose websites directly impact the security of the payment transaction. This includes merchants with payment pages hosted on their domain or that use iframes. This SAQ contains approximately 181 questions.

SAQ B

SAQ B applies to merchants using standalone, dial-out terminals that connect to no other systems or networks with no electronic cardholder data storage. This SAQ contains approximately 41 questions.

SAQ B-IP

SAQ B-IP applies to merchants using standalone, IP-connected point-of-sale (POS) terminals with no electronic cardholder data storage. This SAQ contains approximately 82 questions.

SAQ C

SAQ C applies to merchants with payment application systems connected to the internet but without electronic cardholder data storage. This SAQ contains approximately 160 questions.

SAQ C-VT

SAQ C-VT applies to merchants manually entering cardholder data into internet-based virtual terminals that PCI DSS-compliant third parties provide with no electronic cardholder data storage. This SAQ contains approximately 73 questions.

SAQ D (Merchant)

SAQ D (Merchant) applies to all merchants not included in the other SAQ categories. This most comprehensive SAQ covers all 12 PCI DSS requirements with approximately 329 questions.

SAQ D (Service Provider)

SAQ D (Service Provider) applies to all service providers not eligible for other SAQ types. This SAQ mirrors the full PCI DSS requirements and organisations use it when a Report on Compliance is not required.

SAQ P2PE

SAQ P2PE applies to merchants using validated point-to-point encryption solutions where cardholder data encrypts at the point of interaction and decrypts only at a secure environment that a PCI DSS-compliant service provider manages. This SAQ contains approximately 32 questions.

Selecting the correct SAQ requires careful scoping of the cardholder data environment. Misclassification can result in inadequate security controls or unnecessary compliance burden. Therefore, organisations often engage compliance advisors to validate their SAQ selection.

The PCI DSS Compliance Process

Achieving PCI DSS compliance follows a structured process that spans scoping, assessment, remediation, validation, and maintenance. The timeline varies from three to twelve months depending on organisational maturity, infrastructure complexity, and resource availability.

Identification and Scope

The first step identifies all systems, networks, and processes that store, process, or transmit cardholder data. This includes payment terminals, payment gateways, databases, application servers, network devices, and administrative workstations. Organisations must also include systems that connect to the CDE in scope unless network segmentation demonstrates isolation. Scoping determines the boundary of PCI DSS requirements. Reducing scope through segmentation, tokenisation, or outsourcing can significantly lower compliance costs and complexity.

Gap Analysis

Once organisations define the CDE, a gap analysis compares current security controls against PCI DSS requirements. This assessment identifies areas of non-compliance, prioritises remediation activities, and estimates project timelines and costs. Risk assessments further evaluate the likelihood and impact of potential vulnerabilities. Internal audit teams, compliance consultants, or QSAs typically conduct gap analyses. Additionally, organisations may choose to align PCI DSS remediation with other compliance initiatives such as ISO 27001 Audit Services or SOC 2 Audit Services to maximise efficiency.

Remediation

Remediation implements security controls to address identified gaps. Common remediation activities include network segmentation, firewall rule updates, encryption implementation, access control configuration, patch management, logging and monitoring deployment, and policy development. Remediation timelines vary based on technical complexity, vendor dependencies, and budget availability. Furthermore, organisations must document remediation with evidence such as configuration screenshots, policy documents, and test results for subsequent validation.

Vulnerability Scanning (ASV) & Penetration Testing

PCI DSS requires both internal and external vulnerability scans, as well as penetration testing. An Approved Scanning Vendor (ASV) must perform external vulnerability scans at least quarterly and after significant changes. Qualified internal staff or third-party vendors may perform internal scans. Organisations must conduct penetration testing annually and after significant changes to the CDE. Testing must include network-layer penetration tests and application-layer penetration tests. Testing also verifies segmentation controls to confirm isolation between the CDE and other networks. CyberPulse provides comprehensive Penetration Testing Services to meet these requirements.

Evidence Preparation

PCI DSS compliance requires extensive documentation to demonstrate that organisations implement controls and that they operate effectively. Evidence includes policies and procedures, network diagrams, data flow diagrams, configuration files, access control lists, log samples, vulnerability scan reports, penetration test reports, training records, and vendor compliance attestations. Organisations must organise, version-control, and make evidence readily accessible for auditors or payment brands.

Attestation of Compliance (AOC) and Report on Compliance (ROC)

The final step completes the Attestation of Compliance (AOC) and, if applicable, the Report on Compliance (ROC). The AOC represents a formal declaration that an authorised representative signs to confirm compliance with PCI DSS. Merchants eligible for self-assessment complete an SAQ and AOC. Merchants and service providers requiring a QSA audit receive a ROC in addition to the AOC. Organisations submit the AOC and supporting documentation to the acquiring bank or payment brand as evidence of compliance.

PCI DSS v4.0: Key Changes for 2025

The PCI Security Standards Council released PCI DSS v4.0 in March 2022, with a transition period extending until March 31, 2025. After this date, v3.2.1 retires, and all organisations must comply with v4.0 requirements. Version 4.0 introduces significant changes that address evolving threats, enhance flexibility, and promote continuous security.

Customised Implementation

PCI DSS v4.0 introduces the concept of customised implementation, which allows organisations to tailor controls to their unique environments through documented risk analysis. This approach recognises that prescriptive controls may not prove effective or practical in all scenarios. However, customised implementations require rigorous documentation and justification to demonstrate equivalent or greater security outcomes. Organisations now need targeted risk analysis for specific controls, such as password rotation frequency and multi-factor authentication implementation.

Multi-Factor Authentication Manadated

PCI DSS v4.0 mandates multi-factor authentication for all access into the CDE, including administrative access, remote access, and access from untrusted networks. Previous versions only required MFA for remote access. This change reflects the increased risk of insider threats and credential compromise. Furthermore, v4.0 prohibits organisations from using static passwords as the sole authentication factor.

The standard updates password complexity and rotation requirements to align with modern authentication standards. Passwords must reach at least 12 characters in length, or at least eight characters if the system does not support 12 characters. Password rotation only occurs if organisations suspect compromise, rather than on a fixed schedule.

Payment Page Script Management

Requirement 6.4.3 introduces controls for managing scripts on payment pages, addressing the risk of Magecart-style attacks that inject malicious code into e-commerce checkout pages. Organisations must implement mechanisms to detect unauthorised changes to payment page scripts and prevent their execution. This may include Content Security Policy (CSP), Subresource Integrity (SRI), or third-party script monitoring solutions.

Additional Obligations

Service providers face additional obligations under v4.0, including annual confirmation that personnel understand their PCI DSS responsibilities and documented evidence of security awareness. Service providers must also implement automated mechanisms to detect failures in critical security controls and respond appropriately.

PCI DSS Compliance and Australian Regulatory Context

PCI DSS compliance does not exist in isolation. Australian organisations must also consider local privacy regulations, industry standards, and government guidance when designing payment security programs.

The Office of the Australian Information Commissioner (OAIC) administers the Privacy Act 1988, which includes the Notifiable Data Breaches (NDB) scheme. The NDB scheme requires organisations to notify affected individuals and the OAIC when a data breach will likely result in serious harm. Payment card data breaches frequently meet this threshold. Between January and June 2024, the OAIC received over 500 data breach notifications, with payment card information among the most commonly compromised data types (OAIC, 2024).

The Australian Payments Network (AusPayNet) serves as the self-regulatory body for the Australian payments industry. While AusPayNet does not enforce PCI DSS compliance directly, it publishes guidance on payment security and encourages adoption of PCI DSS and other security standards.

The Australian Signals Directorate (ASD) publishes the Essential Eight framework, a prioritised set of mitigation strategies that organisations use to protect themselves from cyber threats. While the Essential Eight does not focus specifically on payment card security, several controls align closely with PCI DSS requirements, including application control, patch management, multi-factor authentication, and daily backups. Organisations pursuing PCI DSS compliance can leverage their Essential Eight implementation to satisfy overlapping requirements.

Many Australian organisations pursue ISO 27001 certification or SOC 2 attestation alongside PCI DSS compliance. Integrated compliance programs reduce duplication, streamline audits, and provide a unified view of organisational risk. Organisations can map PCI DSS controls to ISO 27001 Annex A controls and SOC 2 criteria, which allows them to satisfy multiple frameworks with a single evidence base. CyberPulse offers Compliance Audit & Advisory Services to support integrated compliance initiatives.

Reducing PCI-DSS Compliance Scope: Tokenisation and Segmentation

One of the most effective strategies for simplifying PCI DSS compliance involves reducing the scope of the cardholder data environment. Smaller CDEs require fewer resources to secure, monitor, and validate. Three primary methods for scope reduction include network segmentation, tokenisation, and outsourcing.

Network segmentation isolates the CDE from other networks using firewalls, VLANs, or other access control mechanisms. Properly segmented networks prevent lateral movement of attackers and limit the systems subject to PCI DSS requirements. Annual penetration testing must validate segmentation to confirm that isolation controls work effectively.

Tokenisation replaces sensitive cardholder data with non-sensitive tokens that organisations cannot reverse-engineer. A tokenisation service generates tokens that organisations store in the merchant’s systems, while the tokenisation provider securely stores the actual cardholder data. Because tokens do not constitute cardholder data, systems that only store tokens remain out of scope for most PCI DSS requirements. PCI DSS-compliant vendors must provide tokenisation services, and organisations must validate their vendors’ compliance annually. CyberPulse assists clients with Third Party Risk Management to ensure vendor security.

Point-to-point encryption encrypts cardholder data at the point of interaction, such as a payment terminal, and decrypts it only at the payment processor’s secure environment. The PCI Security Standards Council must validate P2PE solutions. Merchants using validated P2PE solutions qualify for SAQ P2PE, which significantly reduces the number of applicable requirements.

Outsourcing payment processing to a PCI DSS-compliant third-party provider removes cardholder data from the merchant’s environment entirely. For example, hosted payment pages redirect customers to the payment processor’s website to enter card details. The processor handles authorisation and returns a transaction result to the merchant without exposing cardholder data.

Maintaining Continuous PCI-DSS Compliance

PCI DSS compliance does not represent a one-time achievement. Organisations must maintain compliance continuously through ongoing monitoring, testing, and reassessment. Failure to maintain compliance can result in loss of validated status, increased transaction fees, or suspension of payment processing privileges.

Approved Scanning Vendor (ASV) engagement

An Approved Scanning Vendor (ASV) must perform external vulnerability scans at least quarterly and after significant changes. Scans identify exploitable vulnerabilities in internet-facing systems, such as web servers, payment gateways, and firewalls. Organisations must also perform internal vulnerability scans quarterly and after significant changes.

Annual Assessment

Merchants and service providers must complete an annual PCI DSS assessment, either through a self-assessment questionnaire (SAQ) or an on-site audit by a Qualified Security Assessor (QSA). The assessment validates that organisations meet all applicable requirements and that controls operate effectively.

Change Management Process & Configuration Baselines

A formal change management process must manage changes to systems within the CDE, such as software updates, configuration changes, or network modifications. Organisations must test, document, and approve changes before implementation. Regular verification maintains configuration baselines and detects unauthorised changes.

GRC Platforms for PCI-DSS Compliance

Many organisations deploy governance, risk, and compliance (GRC) platforms to automate compliance monitoring and evidence management. These platforms track control effectiveness, automate evidence collection, generate audit reports, and provide dashboards for executive visibility. CyberPulse offers Managed Compliance Services that include continuous compliance monitoring, evidence management, and coordination with QSAs and payment brands.

Security Awareness Education

All personnel with access to the CDE must receive PCI DSS awareness training annually and upon hire. Training should cover PCI DSS requirements, acceptable use policies, incident reporting procedures, and consequences of non-compliance. Security awareness programs reduce the risk of human error, which causes many data breaches.

How CyberPulse Supports PCI DSS Compliance

CyberPulse delivers end-to-end PCI DSS compliance programs that operationalise compliance, strengthen security posture, and reduce risk across complex payment environments. Experienced CISOs, compliance leaders, and security specialists with deep expertise in Australian regulatory requirements and payment card security deliver our services.

We provide comprehensive PCI DSS compliance programs that cover scoping, gap analysis, remediation, validation, and continuous monitoring. Our fixed-cost engagements provide transparency and predictability, which eliminates the risk of budget overruns. We tailor our approach to your organisation’s size, industry, and transaction volume to maximise efficiency and minimise disruption.

CyberPulse partners with Qualified Security Assessors (QSAs) to provide audit coordination, evidence preparation, and remediation support. We prepare your organisation for QSA audits by conducting pre-audit assessments, organising evidence, and addressing identified gaps.

Our gap analysis services compare your current security posture against PCI DSS requirements and identify areas of non-compliance. We prioritise remediation activities based on risk, cost, and business impact. Our project management team coordinates remediation across IT, security, and business units, which ensures on-time and on-budget delivery.

To begin your PCI DSS compliance journey, contact CyberPulse for a consultation.

Frequently Asked PCI-DSS Compliance Questions

What is PCI DSS compliance?

PCI DSS compliance refers to adherence to the Payment Card Industry Data Security Standard, a set of security requirements that protect cardholder data. All organisations that accept, process, store, or transmit payment card information must achieve compliance.

Who needs to be PCI DSS compliant?

Any organisation that handles payment card data, including merchants, payment processors, service providers, and financial institutions, must comply with PCI DSS. Compliance requirements vary based on transaction volume and business model.

What are the 12 requirements of PCI DSS?

The 12 PCI DSS requirements cover network security, data protection, vulnerability management, access control, monitoring, and governance. They include installing firewalls, encrypting cardholder data, restricting access, monitoring networks, and maintaining security policies.

How much does PCI DSS compliance cost in Australia?

PCI DSS compliance costs vary widely depending on organisation size, transaction volume, existing security maturity, and scope complexity. Costs typically range from $15,000 to $150,000 annually, including consulting, technology, QSA audits, and penetration testing.

What is the difference between SAQ A and SAQ D?

SAQ A applies to merchants that have fully outsourced payment processing with no cardholder data on their systems and requires approximately 22 questions. SAQ D applies to all other merchants and covers all 12 PCI DSS requirements with approximately 329 questions.

Do I need a QSA for PCI DSS compliance?

Qualified Security Assessor (QSA) audits apply to Level 1 merchants (over 6 million transactions annually) and Level 1 service providers (over 300,000 transactions annually). Smaller organisations may complete self-assessment questionnaires, although engaging a QSA or compliance consultant helps ensure accuracy.

What happens if I fail a PCI DSS audit?

Failing a PCI DSS audit results in non-compliant status, which may lead to increased transaction fees, fines from payment brands, or suspension of payment processing privileges. Organisations must remediate identified gaps and undergo reassessment to restore compliant status.

How long does PCI DSS compliance take?

PCI DSS compliance timelines range from three to twelve months depending on organisational maturity, scope complexity, and resource availability. Organisations with mature security programs and limited scope may achieve compliance more quickly, while those requiring significant remediation may need longer timelines.

Useful Links

• 10 Reasons it’s time for a Managed Compliance Service
• Guide to Audit Readiness Services in Cybersecurity Compliance
• Case Study Overview: CyberPulse PCI-DSS Compliance Assessment

Related Services

• PCI DSS Compliance Services
• Penetration Testing Services
• ISO 27001 Audit Services
• SOC 2 Audit Services
• Third Party Risk Management
• Managed Compliance Services

External Resources

• PCI Security Standards Council
• Office of the Australian Information Commissioner
• Australian Payments Network
• NIST Cybersecurity Framework
• Verizon Data Breach Investigations Report