PCI DSS 4.0: Customised Approach Validation Explained

A Fundamental Shift in PCI Validation

PCI DSS 4.0 introduces two paths to compliance: the Defined Approach (traditional, prescriptive controls) and the new Customised Approach. The Customised Approach allows organisations to meet the security objective of a requirement using alternative controls:as long as they can demonstrate equivalent or better protection.

This is not the same as compensating controls (which still exist). The Customised Approach is a fundamentally different validation methodology available for most PCI DSS requirements.

How the Customised Approach Works

For each requirement where you want to use the Customised Approach:

1. Understand the security objective: Each PCI DSS 4.0 requirement now includes an explicit Customised Approach Objective describing what the control is meant to achieve.

2. Design your alternative control: Develop a control that meets the stated objective using your preferred method.

3. Document your controls matrix: Create a detailed document showing how your alternative control addresses each element of the objective.

4. Conduct a targeted risk analysis: Perform a formal risk analysis demonstrating that your approach manages the risk at least as effectively as the defined control.

5. Testing by your QSA: Your Qualified Security Assessor must derive testing procedures specific to your custom control and validate its effectiveness.

When to Use the Customised Approach

The Customised Approach is valuable when:

• Your technology stack doesn't align with the prescriptive requirements (e.g., modern cloud-native architectures)
• You have stronger alternative controls that better fit your environment
• You want to use innovative security technologies that aren't contemplated by the defined requirements

It's not a shortcut. The documentation and testing requirements are actually more rigorous than the Defined Approach. Only use it when you have a genuine reason and the resources to support it.

Key Dates

PCI DSS 4.0 replaced version 3.2.1 on 31 March 2024. Requirements identified as future-dated best practices become mandatory on 31 March 2025. Organisations should already be operating under PCI DSS 4.0 and preparing for the future-dated requirements.