Payment Application Data Security Standard:: Frequently Asked Questions
Payment Application Data Security Standard:: Frequently Asked Questions
Q. Why did the PCI Security Standards Council (PCI SSC) assume responsibility for the Payment
Application Best Practices (PABP), now called the Payment Application Data Security
Standard (PA-DSS)?
A. The PABP program was created and overseen by Visa. Now, through PCI SSC, the five major
global payment brands (American Express, Discover Financial Services, JCB International,
MasterCard Worldwide and Visa Inc.) will support the PA-DSS, allowing even greater opportunity
to standardize security requirements, Qualified Security Assessor testing and lab methodologies,
and approval processes for payment applications.
It is a strategic priority for PCI SSC to continue streamlining security standards and the validation
of secure payment applications. Common requirements mean more consistent security measures
and cost effective market deployment. Common requirements benefit all stakeholders in the
payments value chain and are intended to improve the overall security for customer-entered data.
Q. What types of payment applications are NOT subject to the PA-DSS requirements?
A. Payment applications that are developed for and sold to only one customer are NOT subject to
the PA-DSS requirements; however, they must be covered by the customer’s PCI DSS
assessment. Payment applications that are developed in-house by merchants or service
providers and are not sold to a third party are NOT subject to the PA-DSS requirements,
however, they must be covered by the merchants’ or service providers’ PCI DSS assessment.
Payment applications that are resident in standalone point-of-sale terminals (also called dumb
terminals) are NOT subject to the PA-DSS requirements provided that (1) the terminals have no
connection to any of the merchant’s systems or networks, (2) the terminals connect only to the
merchant’s acquirer or processor via a private line, (3) the payment application vendor provides
secure remote updates, troubleshooting, access and maintenance, and (4) sensitive
authentication data is never stored after authorization.
Q. Will the PCI SSC accept applications that have been previously validated under the existing
Visa PABP program?
A. PCI SSC will recognize PABP validated payment applications and list them with the appropriate
PABP version that they were validated against. For payment applications validated against pre-
PABP version 1.3, they must undergo a PA-DSS assessment within twelve (12) months after the
initial publication of the PCI SSC list otherwise they will expire and will no longer be accepted for
new deployments. For payment applications validated against PABP version 1.3, they must
undergo a PA-DSS assessment within eighteen (18) months after the initial publication of the PCI
SSC list. For payment applications validated against PABP version 1.4, they must undergo a PA-
DSS assessment within twenty-four (24) months after the initial publication of the PCI SSC list.
Please refer to the table in the Grandfathering PABP Applications section of the PA-DSS
Program Guide for more details.
Q How will the migration to PA-DSS impact vendors previously validated under PABP?
A Vendors with applications validated under PABP will have three options as follows:
1. PCI SSC will recognize applications validated under PABP and included on Visa’s list as
answered above, depending on whether the application was reviewed per PABP version
1.3 or 1.4, or per a PABP version prior to 1.3. Please refer to answer above as well as
the table in the Grandfathering PABP Applications section of the PA-DSS Program Guide
for more details.
2. For applications that are under PABP review at the time of the transition, if the review is
completed and accepted by Visa prior to October 15, 2008, the application will be
“grandfathered” in accordance with Step 1 above. For reviews that are not completed
Q. How much will it cost for a vendor to have their products validated to PA-DSS by a PA-QSA?
A. The prices and fees charged by PA-QSAs are not set by PCI SSC; these fees are negotiated
between the PA-QSA and their customer, and paid directly to the PA-QSA. Before deciding on a
PA-QSA, it is recommended that entities talk to several PA-QSA firms.
Q. How can I be assured that PA-QSAs operate on an even playing field? What assurances can
the Council give me regarding the quality of organizations assessing and remediating my
systems for PA-DSS compliance?
A. The Council will maintain the list of approved PA-QSAs and has incorporated a PA-DSS quality
assurance program to ensure that services provided are of an appropriate level. PA-QSAs that
do not meet the quality criteria set forth by the Council will be subject to adverse action including,
but not limited to, probation, penalty fees and/or revocation.
Q. Will PCI SSC continue to recognize PA-QSAs previously recognized by Visa for PABP
assessments?
A. If a company that was previously recognized by Visa for PABP assessments is interested in
performing PA-DSS assessments, PCI SSC requires those companies to enroll and qualify as a
new PA-QSA. In accordance with the PA-QSA Validation Requirements, PA-QSAs must submit
the appropriate documentation and their employees must undergo training=.
Traditional PCI DSS compliance may not apply to payment application vendors since most
vendors do not store, process, or transmit cardholder data. However, because these payment
applications are used by customers to store, process, and transmit cardholder data, and
customers are required to be PCI DSS compliant, payment applications should facilitate, and not
prevent, customers' PCI DSS compliance. A few of the ways payment applications can prevent a
customer's compliance are: 1) storage of magnetic stripe data in the customer's network after
authorization; 2) applications that require customers to disable other features required by PCI
DSS, such as anti-virus software or firewalls, and; 3) vendors that use unsecured methods to
connect to the application to provide support to the customer.