ROC Revolution: Navigating the Impact of PCI DSS 4.0 on Reporting Efficiency and the Price of Customization

The blog post was written by a friend and former co-worker you may know as the PCI Guru, he discusses a notable change in the Payment Card Industry Data Security Standard (PCI DSS) Report On Compliance (ROC) Reporting Template, specifically in version 4.0. He highlights a shift in the template’s language, emphasizing the need for specific and detailed responses rather than the use of templated language. This change signifies a departure from previous versions where the Council’s Assessor Quality Management (AQM) team recommended templated responses for compliance.

The post suggests that the new requirements in version 4.0 will limit the flexibility for Qualified Security Assessors (QSAs) to reuse wording and will necessitate more time and effort in completing ROCs. The author anticipates a potential 50% or more increase in work effort for QSAs. Additionally, there is criticism and caution regarding the use of the Customized Approach, emphasizing the potential significant increase in ROC cost (75% or more on top of the anticipated 50% increase) due to extensive testing and review requirements. The post concludes by warning firms who consider the Customized Approach to prepare for potential challenges and costs associated with this method, advising them to justify such decisions to management.