PCI DSS v4.0.1, the challenge of continuous assurance and the rise of AI
21st January 2026 • Park Plaza Victoria, London, UK
Meeting the demands of 4.0.1 is hard and non-stop technology innovation isn’t helping. What are the best organisations doing?
Tougher than you thought? How organisations have responded to PCI DSS v4.0.1
Early adopters of PCI DSS v4.0.1 have reported that the journey has been harder and more resource-intensive than expected. Many organisations underestimated how broad their cardholder data environments (CDEs) are, and how many connected systems — from backup servers to monitoring tools — fall within scope. Discovering these dependencies late in the process has led to costly remediation.
Technical complexity is high. Stronger authentication requirements, stricter cryptography, more comprehensive logging, and expanded monitoring have required major upgrades.
The “Customized Approach” has caused some confusion. PCI DSS v4.0.1 allows organisations to propose alternative controls that meet the intent of requirements, rather than follow the exact “Directed Approach.” While flexible, this option has been difficult to operationalise.
Future-dated requirements are a double-edged sword. Those who delayed action are now facing resource bottlenecks.
Third-party and vendor risk is a critical weak spot. Payment data often passes through vendors, processors, or cloud providers. Many contracts do not yet bind these third parties to PCI DSS v4.0.1-level obligations. Service providers with older systems often cannot support the required controls without significant investment.
Documentation and evidence demands have grown. Under v4.0.1, compliance chiefs must maintain logs, configuration records, change histories, and detailed evidence of testing.
Organisations that treated compliance as an annual “checkbox” exercise have had to rethink their entire documentation approach.
E-commerce merchants have faced new requirements to control third-party scripts. Without monitoring for script tampering, merchants risk data skimming attacks. Those who implemented script inventories, integrity checks, and content security policies have both met the new standard and improved customer security.
Across sectors, compliance chiefs have reported similar pain points: vendor contract weaknesses, underestimation of scope, confusion over customized controls, and the heavy lift of continuous monitoring.
In parallel with PCI DSS v4.0.1, the PCI SSC has begun addressing the impact of artificial intelligence on compliance and payment security. The core message is simple: AI can help, but it cannot replace human accountability. In assessments and in payment environments, the Council makes clear that human accountability, traceability, and resilience planning are non-negotiable.
For solution providers, the opportunity is clear. Compliance chiefs are actively searching for tools and partners who can:
- Automate compliance evidence collection and reporting.
- Deliver robust access control, encryption, and monitoring aligned with v4.0.
- Provide script monitoring and integrity solutions for e-commerce.
- Integrate AI safely into assessments and payment ecosystems.
- Help manage vendor and third-party risks.
PCI London will continue our look at PCI DSS 4.01 and the progress compliance teams are making.
Join our real-life case studies and in-depth technical sessions from the PCI compliance leaders at a broad cross-section of organisations and sectors.
