How to Store Credit Cards: Building a CDE In-house
Blog post from Basis Theory
Building an in-house cardholder data environment (CDE) offers direct control over payment data, processor routing, integrations, latency, and vendor dependence, but requires substantial investment in PCI DSS compliance, security operations, and ongoing maintenance. Organizations that store cardholder data themselves must implement and assess all relevant infrastructure, policies, training, access controls, network protections, scans, penetration tests, and documentation, with initial setup commonly estimated at $125,000 to $300,000 and three to seven months. Compliance requirements can include the extensive SAQ D, regular security testing, or formal audits by Qualified or Internal Security Assessors for organizations processing more than six million annual transactions. Maintaining compliance is a continuous responsibility, particularly as security threats and PCI standards evolve, including the additional controls introduced in PCI DSS v4.0. Tokenization and developer-oriented platforms can reduce exposure and help enforce compliant practices, while many benefits of owning card data may also be available through specialized service providers. As a result, companies most likely to build their own CDE are large retailers and payment service providers with high transaction volumes or specialized operational needs, whereas others may find third-party solutions more economical and faster to deploy.
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