7 Ways to Reduce Your PCI DSS Compliance Scope

For businesses handling payment card transactions, achieving and maintaining PCI DSS (Payment Card Industry Data Security Standard) compliance is essential. However, the journey to compliance can often be expensive and complex. One of the most effective ways to reduce both the financial and operational burden is by reducing the scope of your PCI DSS environment. By narrowing the scope, you simplify security management, lower compliance costs, and reduce overall risk.

This guide outlines seven strategies to help you reduce your PCI DSS compliance scope while maintaining strong security measures.

1. Implement Network Segmentation

Why It Helps:

Network segmentation isolates systems that process, store, or transmit cardholder data (CHD) from non-payment-related systems. By segmenting your network, only systems that require compliance with PCI DSS will be in scope, thereby reducing your overall compliance requirements.

How to Do It:

1. Use Firewalls to Segment Networks: Deploy firewalls to separate the Cardholder Data Environment (CDE) from other network zones, allowing only necessary communication between them.
2. Create Dedicated VLANs for PCI Systems: Utilize Virtual Local Area Networks (VLANs) to separate payment processing systems logically. Restrict VLAN access to authorized personnel and systems only.
3. Conduct a Segmentation Validation Test: Run penetration testing (PCI DSS Requirement 11.4.5) to confirm the effectiveness of segmentation, ensuring non-PCI systems cannot access the CDE.
4. Implement Role-Based Access: Restrict access to PCI networks to users and applications that need it, with multi-factor authentication (MFA) for accessing PCI systems.

Results:

• Reduces the number of in-scope systems, lowering compliance complexity and costs.
• Limits potential attack surfaces, improving security.

2. Outsource Payment Processing

Why It Helps:

Outsourcing payment processing to a PCI DSS-compliant third party reduces the number of systems and personnel that handle sensitive cardholder data, significantly shrinking your PCI scope.

How to Do It:

1. Choose a PCI-Compliant Payment Processor: Ensure your provider maintains an Attestation of Compliance (AOC) and follows PCI DSS encryption and transaction security protocols.
2. Implement Hosted Payment Pages or Secure Redirects: Use a hosted payment page where the payment processor handles all transactions. Ensure the redirection process prevents man-in-the-middle attacks by using HTTPS and verifying the authenticity of sources.
3. Utilize a Payment Gateway API That Limits Exposure: Ensure that the payment gateway API never allows CHD to be stored or transmitted within your environment.
4. Regularly Review Third-Party Compliance: Continuously monitor and audit your payment processor’s compliance, as your organization remains responsible for ensuring their adherence to PCI DSS requirements.

Results:

• Eliminates the need for storing or processing payment data, drastically reducing PCI scope.
• Reduces internal infrastructure and security risks.

3. Use Tokenization

Why It Helps:

Tokenization replaces cardholder data with an irreversible token that has no exploitable value. This reduces PCI scope because systems that store tokens instead of actual cardholder data fall outside of PCI DSS requirements.

How to Do It:

1. Adopt a PCI-Compliant Tokenization Solution: Utilize a trusted provider that ensures tokenization adheres to PCI DSS standards and never allows the original Primary Account Number (PAN) to enter your systems.
2. Replace Stored PANs with Tokens: Migrate systems storing PANs to tokenized values (e.g., replace "4111 1111 1111 1111" with "TK983749203").
3. Ensure Tokens Cannot Be Reversed: Use a well-designed tokenization system that prevents even hackers from retrieving the original PAN.

Results:

• Eliminates stored cardholder data, reducing PCI DSS scope and security risks.
• Simplifies compliance by avoiding higher-level assessments (SAQ D).

4. Encrypt Cardholder Data

Why It Helps:

Encryption protects CHD by converting it into an unreadable format. If encryption keys are managed securely, systems that store encrypted CHD may fall out of scope.

How to Do It:

1. Encrypt Data at Rest and in Transit:
   • Use AES-256 encryption for stored data.
   • Use TLS 1.2 or higher for data transmission.
   • Use FIPS 140-2 or FIPS 140-3 validated encryption for additional security.
2. Implement Strong Key Management Practices:
   • Store encryption keys separately from encrypted data.
   • Use hardware security modules (HSMs) to manage encryption keys.
   • Ensure encryption keys are rotated periodically, and that key access is audited.
3. Use Point-to-Point Encryption (P2PE): P2PE encrypts card data immediately at the point of sale, preventing it from entering your network in an unencrypted state.

Results:

• Proper encryption can remove systems from the PCI scope.
• Reduces the risk of a data breach impacting unprotected payment data.

5. Eliminate Unnecessary Cardholder Data Storage

Why It Helps:

PCI DSS strictly prohibits storing sensitive authentication data (track data, CVV, PIN, etc.) unless the entity is an Issuer or supports issuing services. Many organizations unintentionally store CHD, expanding their PCI scope.

How to Do It:

1. Conduct a Cardholder Data Discovery Scan: Use PCI data discovery tools to find hidden CHD in databases, logs, and backups.
2. Implement Data Retention Policies: Define retention periods for CHD and regularly purge data that is no longer needed.
3. Ensure Proper Disposal of CHD: Establish, define, and use secure deletion techniques that prevent data from being recovered.

Results:

• Eliminates compliance requirements related to stored CHD.
• Reduces liability in case of a breach.

6. Adopt a PCI-Validated P2PE Solution

Why It Helps:

A Point-to-Point Encryption (P2PE) solution encrypts payment card data at the point of entry, meaning your network never processes raw CHD, which significantly reduces PCI scope.

How to Do It:

1. Deploy PCI-Approved P2PE Payment Terminals: Ensure your payment solution and terminals are PCI-validated by checking the PCI Security Standards Council’s list of approved solutions.
2. Ensure No Decryption Happens in Your Environment: Keep encryption keys secure and ensure they are managed by the payment processor rather than your organization.

Results:

• Reduces the number of requirements for your environment, shifting from SAQ D (300+ requirements) to SAQ P2PE (21 requirements).
• Greatly reduces compliance complexity.

7. Restrict Access and Use Least Privilege Principles

Why It Helps:

By limiting who and what can access CHD, you reduce the number of people and systems in scope.

How to Do It:

1. Implement Role-Based Access Control (RBAC): Ensure that only authorized personnel can access PCI systems and enforce MFA for system access.
2. Monitor and Log All Access to CHD: Utilize Security Information and Event Management (SIEM) solutions to monitor user access and identify unauthorized activity.
3. Regularly Audit User Access: Conduct quarterly access reviews and remove unnecessary privileges to ensure that access is appropriately restricted and controlled.

Results:

• Reduces the number of in-scope employees and systems.
• Strengthens security against insider threats.

Final Thoughts

Reducing PCI DSS scope requires a strategic combination of segmentation, outsourcing, encryption, and process improvements. By implementing these strategies, businesses can significantly decrease compliance costs, simplify audits, and strengthen data security. Whether you are a small business seeking to streamline compliance or a large enterprise managing complex payment environments, focusing on scope reduction is a prudent approach to enhancing security while minimizing operational burden.

Achieving PCI DSS compliance can be a daunting task, but you do not have to navigate it alone. Compass IT Compliance specializes in helping organizations assess, manage, and reduce their PCI scope through expert guidance and tailored security solutions. Our Qualified Security Assessors (QSAs) work closely with businesses to implement effective segmentation strategies, optimize encryption and tokenization solutions, and ensure compliance with the latest PCI DSS requirements. Whether you need a gap assessment, a comprehensive compliance audit, or strategic consulting to minimize your PCI footprint, Compass IT Compliance is your trusted partner in securing your payment environment while alleviating the burden of compliance.

Contact us today to learn how we can help your organization streamline its PCI DSS compliance process.