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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Selecting a PCI QSA Vendor

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If you are a merchant that accepts credit cards, you are required to comply with the requirements of the Payment Card Industry (PCI) Data Security Standards (DSS), and you must demonstrate that compliance each calendar year to your bank.

You can find more information about what that means to your business here. Once you are ready start your compliance effort, you will need to engage a third-party team to help make sure you are making the correct decisions about demonstrating that compliance, working on changes as they occur to make sure you aren’t making poor security decisions, and they will certify your compliance with a standard format report that lists why they think your environment is secure enough for customer transactions called a Report of Compliance (RoC).

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It can be difficult to find the correct partner that can help guide you through this difficult and expensive process, but a little work in the beginning can save you headaches and expenses later in the process.

The first thing to remember is you need to run your business, and that already means having a secure information technology (IT) environment and worrying about adequate security. Being PCI compliant an having a secure network is not the same thing. The PCI DSS provides you a standard framework that list the minimum requirements for implementing a secure IT environment. You have to know your specific requirements and what makes your environment different than the “standard” IT environment. Your Qualified Security Assessor (QSA) needs to have the skills required to understand technology in general, and your specific environment, before thy can perform their job well.

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Here are three tips to help you choose the right QSA for your PCI Compliance audit:

  • How experienced is the QSA? You don’t want to pay to train your QSA on how to do perform their job. You want someone who already has a few years of experience.
  • What is the approach to the audit used by the QSA? You have to understand how the QSA will interact with your team and how well their approach will work with your culture and corporate environment. The best-case scenario is they fit seamlessly with your employees and have the professionalism and communication skills to work well with the entire team.
  • Will the QSA stand behind their work? If things go bad and there are questions about your security measures, or even a breach of customer data, you want someone who is confident in their security decisions and will defend your decisions.

Pricing is another area that can be hard to compare from company to company. I looked at 5 different companies and they gave me 5 very different pricing solutions. The cheapest was almost half the cost of the most expensive.  There are several factors that will play into pricing and those factors will vary for each company, but your overall network complexity, number of credit card transactions, and requested services can really drive huge swings in pricing. Don’t be afraid to do some comparison shopping to find a vendor with pricing that meets your budget, but the cheapest vendor doesn’t always mean they are the one you need to select.

It can be preferred to pay slightly more if you are going to get much better service and support.