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Big Changes in PA-DSS v2.0

Maybe, maybe not. If you are a payment application vendor, are you worried about the changes that have happened with the new release of the Payment Application Data Security Standard (PA-DSS)? For the most part, the requirements have not changed but there are a couple of items that may require some changes in the application, the documentation, or even the processes around the application.

Storing sensitive authentication data

In PA-DSS version 1.2, it was not acceptable to store authentication data (i.e. track 1 data, CVV, etc.). The revision for PA-DSS version 2.0 now allows for sensitive authentication data (track1, track 2, CVV) to be stored but only if there is sufficient business justification and the data is stored securely. This is only for card issuers and companies that support issuing processing. It has never been permissible for merchants to store this information even if encrypted. During the testing portion of the audit, the auditor will be testing for sensitive authentication data using forensic methods. The auditor will also verify that the application is intended for card issuers and/or companies that support issuing services.

Auditing

One of the changes to PA-DSS is that the application needs to support centralized auditing. This means the audit data must be able to be moved to a centralized log server (i.e. syslog-ng, Windows Event Logs). During the testing portion of the audit, the auditor is going to have to see that the lab has a centralized log sever configured and that the application logs are moving to this server. The PA-DSS Implementation Guide also has to provide instructions and procedures for incorporating the logs into a centralized logging environment.

One less requirement

As a final note, there is one less requirement. Requires 10 and 11 have been merged, instead of having two separate requirements, one for the merchant and one for the payment application vendor, there is now only one requirement covering remote access to the payment application.

Conclusion

The PA-DSS version 2.0 requirements, in most cases, are clearer. It makes it easier for payment application vendors to understand the requirements and to pass the audit.

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