Is the Customized Approach in PCI DSS 4.0 right for me?
Blog post from Basis Theory
PCI DSS v4 introduces a customized approach that lets eligible organizations replace prescribed defined controls with alternative controls that meet the same security objective, unlike compensating controls, which supplement an unsuccessfully implemented required control. This flexibility can support tailored architectures and newer technologies, such as passwordless multi-factor authentication in place of password-specific measures, but it is intended for organizations with mature risk-based security programs rather than as an easier compliance route. Each customized control requires documented risk analysis, executive approval, a controls matrix, ongoing effectiveness monitoring, and independent assessment by a Qualified Security Assessor (QSA). Because customized approaches are available only to organizations completing a QSA-led Report on Compliance rather than a Self-Assessment Questionnaire, they can increase audit time, cost, and operational overhead. Organizations should therefore consider them when the security, operational, or technological benefits clearly justify the extra expertise, documentation, implementation, and maintenance required.
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