PCI's Potential Black Friday Nightmare

A 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.

October promises to be a big month for everyone involved with PCI, but maybe not for the expected reason. On Oct. 28, 2013, every payment application validated under Payment Application Data Security Standard (PA-DSS) version 1.2—and there are a lot of them—will see its validation expire. The applications will no longer be acceptable for new deployments, a potential nightmare for every retailer using a validated payment application. If a retailer has any payment app that glitches in early November, it could have far fewer—if any—choices as a replacement.

The problem: A large number of applications still haven't been revalidated under PA-DSS 2.0. Given the time that has already elapsed, coupled with the human tendency to delay the unpleasant, we're looking at a likely crush of last-minute validation renewal requests that could strain both PA-QSA and PCI SSC resources.

For retailers, this means applications that may still be secure won't necessarily be supported by vendors. Much worse, this situation could create a huge backlog of applications to be evaluated by PA-QSAs and then approved by the PCI Council. That process will take weeks, and quite possibly months, to work through. Retailers should note that this is happening barely one month before Black Friday. Fear not, though. All of these problems can be averted if software vendors all act quickly, well ahead of deadline. (Editor's Note: In other words, we're all doomed.)

For retailers who do have a payment app that blows up right after the October 28 deadline—as Murphy's Law demands—merchants will have three unpleasant choices: live with their current apps and patch what can be patched; deal exclusively with the potentially smaller set of software vendors who have already gotten revalidated and negotiate from a weakened position (because the vendor also knows you have very few choices); or take a risk and buy and implement a non-validated app and then hope you don't get breached or caught. The retailer, in that last case, should insist on language promising an immediate free upgrade (if necessary) once the app has been approved.

Application vendors will work in the remaining nine months (I hope) to validate their expiring version 1.2 payment applications under PA-DSS version 2.0. To extend the expiry date of their applications, vendors must submit a new PA-DSS version 2.0 report on validation (ROV), which will extend the expiry date of the validated version of the payment application to October 2016.

The changes between PA-DSS version 1.2 requirements and those in version 2.0 may not have been substantial. What is new, however, is that PA-QSAs now have detailed ROV Reporting Instructions that they must follow.

The impact of the ROV Reporting Instructions is likely to result in increased rigor in the PA-QSA's testing and reporting that may require additional time and effort to complete and document. The PCI Security Standards Council (PCI SSC) appears to recognize the possible increased validation effort in its Frequently Asked Questions for Transition from v1.2 to v2.0, when the Council states: "We strongly advise that PA-QSAs and payment application vendors use the transition period to familiarize themselves with and prepare for the changes in the new Program Guide, particularly for pricing and processes, before submitting application ROVs, revalidations or changes to the Council for review."

This increased rigor is good.This increased rigor is good, and it should benefit merchants. It may also result in validation logjams involving software vendors and their PA-QSAs if there are delays beginning their revalidations, and then further logjams if a pile of ROVs all show up on the PCI SSC's doorstep in mid-October.

Memo to application vendors: You may want to think about scheduling your PA-QSA's time now (if you have not already), and be sure to allow adequate time for the PCI SSC review process in your planning, too. Vendors need to remember they won't be the only one in the PCI SSC's queue. I know that PA-QSA firms will be gearing up for the expected rush in ROV renewals, and I'm pretty sure they also hope the application vendors will similarly plan ahead.

As the PCI SSC notes, vendors should anticipate changes in "pricing and process" that can affect the timing and, possibly, the cost of their new ROV. Your PA-QSA will be aware of the October deadline. I am sure they, too, have read the part of the FAQ that states: "Assessors are expected to perform a fresh assessment each time, as the results from previous assessments are not necessarily relevant for a current assessment."

The message for merchants is to stay on top of developments with your payment application vendor. If you have a payment application with a PA-DSS expiry of October, contact your vendor and find out when you can expect the updated version. Visa and MasterCard have not changed their mandates that merchants use PA-DSS validated applications. That means merchants also must budget the time and resources to upgrade their payment applications this summer (if you are lucky) or autumn.

What if a merchant's payment application vendor is late and misses the Oct. 28, 2013, expiry or the merchant cannot install the application in time? If merchants have a properly installed (per the vendor's PA-DSS Implementation Guide) and validated application, they should still be in compliance with the Visa and MasterCard mandates—at least for now. However, those merchants could end up with an application that is no longer maintained by the vendor or that will no longer receive security patches or updates and, therefore, may increase their vulnerability to a data breach with each passing day.

Although the October 28 sunset for PA-DSS primarily affects payment application vendors, merchants will also be impacted. Merchants must plan now for a summer/autumn payment application upgrade. Otherwise, they will need to plan on supporting an expired application that—although possibly still secure—is approaching its end-of-life. Spinning through the list of PA-DSS validated applications, quite a number appear to be facing the October 28 validation deadline. I suggest merchants check their own applications on the PCI SSC's list and assess their upgrade strategy.

What do you think? I'd like to hear your thoughts. Either leave a comment or E-mail me.