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PCI DSS Compliance

PCI DSS Penetration Testing

Pentests mapped to PCI DSS 4.0 Requirement 11.4. External testing of your CDE after changes and between your annual pentests. It does not replace the annual pentest by a qualified internal or external tester.

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Why PCI DSS pentesting matters now

PCI DSS 4.0 went into full enforcement on 31 March 2025, with new testing requirements that make annual-only testing risky. Requirement 11.4.1 mandates penetration testing methodology documentation; 11.4.3 requires external pentests at least annually and after significant change; 11.4.6 requires segmentation-control testing for merchants. Acquirers are asking for quarterly evidence during the transition — and card brands are increasing enforcement.

PCI DSS clause-by-clause coverage

Every Matproof finding is mapped to the specific PCI DSS clause it informs. Your auditor sees the control, the evidence, and the remediation in one report.

Requirement 11.4.1

Penetration testing methodology must be defined, documented, and implemented

Requirement: A penetration testing methodology is defined, documented, and implemented by the entity, and includes industry-accepted approaches (e.g., NIST SP 800-115, OSSTMM, OWASP).

How Matproof covers it: Matproof's scan methodology aligns with OWASP Testing Guide v4 and NIST SP 800-115 — exported as a PDF methodology document alongside every report.

Requirement 11.4.2

Internal penetration testing

Requirement: Internal penetration testing is performed at least once every 12 months and after any significant infrastructure or application upgrade or change.

How Matproof covers it: Matproof does not run internal network pentests. A qualified internal or external tester covers 11.4.2. Matproof can add authenticated, read-only tests of your web apps and APIs.

Requirement 11.4.3

External penetration testing

Requirement: External penetration testing is performed at least once every 12 months and after any significant infrastructure or application upgrade or change.

How Matproof covers it: Black-box external tests target internet-facing CDE surfaces at your chosen cadence. They give evidence between pentests. They do not replace the annual pentest by a qualified tester.

Requirement 11.4.4

Exploitable vulnerabilities must be corrected

Requirement: Exploitable vulnerabilities and security weaknesses found during penetration testing are corrected and testing is repeated to verify the corrections.

How Matproof covers it: Matproof re-tests fixed findings automatically, producing the verification artefact Requirement 11.4.4 specifies. No manual retest coordination required.

Requirement 11.4.5

Segmentation controls must be penetration tested

Requirement: If segmentation is used to isolate the CDE from other networks, penetration tests are performed on segmentation controls to verify they are operational and effective.

How Matproof covers it: Matproof does not test network segmentation. A qualified internal or external tester covers 11.4.5.

Requirement 11.4.6 (Service providers)

Service-provider segmentation testing

Requirement: Additional requirement for service providers only: segmentation controls are tested at least every 6 months.

How Matproof covers it: Matproof does not test network segmentation. A qualified tester covers the semi-annual segmentation tests for 11.4.6.

What Matproof tests for PCI DSS

  • Cardholder Data Environment (CDE) — web apps, APIs, databases
  • All systems connected to or that can impact the security of the CDE
  • External attack surface of CDE-adjacent systems
  • Applications handling card data (PAN, CVV, track data)
  • Service-provider CDE boundaries (for Reqt 11.4.6)

PCI DSS pentest evidence reports

  • Findings mapped to Requirements 11.4.1 through 11.4.6
  • Methodology documentation (NIST SP 800-115 / OWASP alignment)
  • External test evidence split by report section
  • Retest verification for Requirement 11.4.4
  • CVSS 3.1 scoring with business-impact rationale
  • Evidence for Requirement 11.4 testing between pentests

PCI DSS 4.0 Penetration Testing — FAQ

Is penetration testing required for PCI DSS?

Yes. PCI DSS 4.0 Requirement 11.4 explicitly mandates penetration testing for all merchants and service providers. Internal and external tests are required annually; service providers must test segmentation controls semi-annually.

Does PCI DSS 4.0 accept AI-automated pentesting?

PCI DSS 4.0 does not prescribe a specific execution method. It requires industry-accepted methodology (NIST SP 800-115, OSSTMM, OWASP) and qualified personnel reviewing results. Sentinel follows OWASP methodology. It does not replace the 11.4 pentest by a qualified internal or external tester. Use it for testing between those pentests and for re-tests after fixes.

What's changed in PCI DSS 4.0 vs 3.2.1?

4.0 adds explicit methodology documentation requirements (11.4.1), strengthens segmentation testing (11.4.5 and 11.4.6), and introduces a 'customised approach' that allows continuous testing as an alternative to point-in-time. Continuous testing with Matproof can give evidence for a customised approach. Your QSA decides if it is accepted.

How does continuous PCI DSS testing compare to annual testing?

Annual testing satisfies the minimum. Continuous testing supports the intent. Requirement 11.4.4 requires re-testing after fixes, and 12.10.x requires rapid detection of new exposures. Continuous scanning catches drift that annual testing misses. Matproof gives the ongoing evidence between pentests. It does not replace the annual pentest by a qualified internal or external tester.

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