PCI: Listed vs. Non-Listed P2PE Solutions

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With credit card processing, it is important to understand the different parts and pieces that make-up the required security components. The PCI Security Standards Council (PCI-SSC) has released an assessment methodology for merchants using Point-to-Point Encryption (P2PE) solutions. The addition of the Non-Listed Encryption Solution Assessment (NESA) and the accompanying audit process provides merchants an expanded pool of encryption solutions beyond the current list of validated providers, allowing for a wider range of security offerings of the merchant is willing to accept the added liability and cost of a self-certified solution. It is very important to understand the assessment requirements of each before deciding between a listed or a non-listed solution.

The process for becoming a listed solution with the PCI-SSC begins with an audit performed by a third party independent Qualified Security Assessor (QSA) who has been certified specifically for P2PE assessments. During this technical assessment, the P2PE QSA will evaluate the solution against the relevant controls outlined in the following six P2PE Domains from the PCI-SSC:

  • Domain 1: Encryption Device and Application Management
  • Domain 2: Application Security
  • Domain 3: P2PE Solution Management
  • Domain 4: Merchant Managed Solutions (not applicable to 3rd party solution providers)
  • Domain 5: Decryption Environment
  • Domain 6: P2PE Cryptographic Key Operations and Device Management

For each applicable control, the P2PE QSA will collect evidence from the solution and observe all required procedures to ensure compliance with the standard. The results of the assessment are then documented using the P2PE Report on Validation (P-ROV) template which will be submitted by the QSA directly to the PCI-SSC for final review. Once a representative of the PCI-SSC has reviewed, approved, and signed the submitted P-ROV, the solution will receive an official listing on the PCI website.

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The process of implementing and validating a new or existing solution can be quite lengthy and the NESA process gives solution providers the ability to provide a degree of security assurance to customers, along with scope reduction, while they work towards a validated listing. Much like the process for becoming a listed solution, non-listed solution providers need to engage their own P2PE QSA to perform an assessment of their solution. The requirements for this type of assessment, however, have been relaxed in that a non-listed solution assessment can be completed without meeting the requirements for P2PE Domains 1, 2, or 3, but must meet all applicable requirements of Domains 5 and 6. Though the QSA will still complete a P-ROV for informational purposes, the end result of this assessment will also include a set of documents (referred to as the NESA documentation) which will include:

  • A description of the solution
  • A summary of the application’s full compliance, partial compliance, or non-compliance with Domains 1,2, and 3
  • A statement of compliance confirming the applicable requirements of Domains 5 and 6 are met
  • The assessing P2PE QSA’s recommendation as to how the solution impacts the merchants PCI scope

This set of documents serves the same purpose as a listed solution’s P-ROV or Attestation of Validation (AOV), without being submitted to the PCI Council or the Payment Brands, and will be used by PCI QSA’s when assessing the PCI compliance of a merchant utilizing the non-listed solution. As with standard PCI certification documentation, this NESA documentation should be distributed to clients on an annual basis, and whenever there are significant changes to the system.

At the merchant level, the difference between implementing a listed versus a non-listed solution becomes apparent during the annual PCI-DSS re-certification. A merchant using a listed solution in accordance with the solution providers P2PE Instruction Manual (PIM) and the pre-requisites of the SAQ P2PE automatically qualifies for a drastic reduction in PCI scope when assessing their environment. This is because the security and isolation of credit card data has been verified by a representative of the PCI-SSC. This same level of scope reduction is not guaranteed with a non-listed solution and will really depend on what is permitted by the merchant’s acquirer as well as the payment brands. In some cases, the acquirer or payment brands may require the aid of a PCI QSA to review the solution provider’s NESA documentation and the merchant’s implementation of the solution to determine what PCI-DSS requirements are covered, and to what degree. The results of this secondary solution assessment will determine which areas of the merchant environment are in scope of PCI, but will not qualify the merchant to utilize the SAQ P2PE.

You can get more information from the official PCI Security Standards Council website or your QSA.

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