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PCI DSS 11.3: Penetration Testing Requirements Clarified

There’s a lot of talk about section 11.3 of the Payment Card Industry Data Security Standard (PCI DSS), requiring organizations to conduct penetration tests.  The language in this section of the standard reads:

11.3 Perform penetration testing at least once a year and after any significant infrastructure or
application upgrade or modification (such as an operating system upgrade, a sub-network added
to the environment, or a web server added to the environment). These penetration tests must
include the following:
11.3.1 Network-layer penetration tests
11.3.2 Application-layer penetration tests

When the standard first came out, the vagueness of this requirement caused quite a bit of confusion among compliance professionals attempting to understand how they’ll be held accountable by their merchant banks.

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