Do Banks Need to Be PCI Compliant?

Banking is one of the most heavily regulated industries and for good reason. With sensitive customer data and financial transactions, they’re a primary target for cyberattacks.

Among the many standards banks must meet, the Payment Card Industry Data Security Standard (PCI DSS) is often overlooked. If your financial institution handles credit card data from major brands like Visa, Mastercard, Discover, American Express, or JCB International, PCI compliance is mandatory.

The requirements are maintained by the PCI Security Standards Council and are intended to prevent security breaches, strengthen your risk posture, and build customer trust. PCI DSS also aligns with other security frameworks, making it a valuable foundation for broader compliance efforts.

What Is PCI DSS?

PCI DSS is a set of security requirements to protect cardholder data. Any organization that stores, processes, or transmits credit or debit card information must comply.

PCI compliance is required regardless of whether a business uses its own systems or a third-party payment processor. PCI requirements still apply even if card data only passes through the organization’s servers to credit card companies and isn’t stored.

The Payment Card Industry Security Standards Council provides guidance to help financial institutions and other organizations detect fraud, prevent data loss, and respond to breaches effectively.

Is PCI DSS a Legal Requirement for Banks?

No, PCI DSS isn’t required by law. However, major payment card brands require PCI DSS compliance as part of their agreements with banks, financial institutions, merchants, and service providers that process credit card information.

Issuing banks provide credit cards to consumers, while acquiring banks manage merchant accounts and handle payment processing.

Since PCI DSS compliance is included in the contract, it is legally required.

Becoming a PCI Compliant Bank

There are 12 main requirements for PCI DSS compliance:

Protect all cardholder data with a system of well-maintained firewalls.
Change all default passwords to unique strong passwords.
Protect stored cardholder data.
Encrypt any cardholder data that is transmitted via open networks.
Use antivirus software and keep it up to date.
Make sure that systems and applications are secure.
Restrict access to cardholder data to a need-to-know basis.
Assigned a unique ID to anyone with access.
Restrict physical access to cardholder data.
Closely monitor all access activity.
Regularly test all security systems.
Information security policies should be consistent and clear to all employees.

There are 281 additional directives, which may or may not apply to you based on the size of your company and how many credit card transactions you process in a given year.

To become PCI DSS compliant, first you must determine which standards you need to meet. Then, assess your existing program to see where data protection is sufficient and where you may need to make changes to meet the necessary security requirements.

Establishing and proving compliance with all of the appropriate standards can be a challenging and time-consuming process.

Fortunately, the PCI SSC provides organizations with the tools to implement the PCI data security standards, including PCI Self-Assessment Questionnaires (PCI SAQs), training and education, assessment and scanning qualifications, and PCI DSS certification programs.

Should Banks Complete a PCI Assessment?

Yes, banks must complete a PCI assessment annually to prove compliance. The results must be submitted to the acquiring bank in a Report on Compliance (ROC) or an Attestation of Compliance (AOC).

The type of assessment depends on your merchant level and the card brand’s specific requirements. Larger institutions may also need quarterly PCI network vulnerability scans by an Approved Scanning Vendor (ASV).

Smaller entities typically use a Self-Assessment Questionnaire, which varies based on how transactions are handled, such as card-present vs. card-not-present or fully vs. partially outsourced processing.

If your financial institution already meets certain regulatory standards, there may be overlap with PCI DSS, but you’re still responsible for full compliance. Failure to comply with PCI requirements can lead to fines, loss of card processing privileges, and severe reputational damage following a data breach.

PCI Compliance Best Practices for Banks

The PCI Security Standards Council has a list of resources to help you achieve and maintain PCI compliance. Here’s a summary of the recommendations in their “Best Practices for Maintaining PCI DSS Compliance” supplement.

1. Develop and Maintain a Sustainable Security Program

To meet PCI compliance requirements, banks need to focus their efforts on the primary goal of PCI DSS: protecting payment card data.

Only retain credit card information when strictly necessary for business operations. Establish and enforce a clear data retention policy, and securely delete any cardholder data that is no longer needed. This includes payment data flowing through point-of-sale (POS) systems, e-commerce platforms, or any on-site credit card payment infrastructure.

2. Build a Structured Program with Defined Policies

A well-defined compliance program includes strategic planning, clear roles and responsibilities, and aligned policies, processes, and procedures. When developing a compliance program, understand the distinctions between the following:

A program sets long-term goals, assigns accountability, and establishes oversight mechanisms.
A policy expresses management’s intent and defines rules for protecting payment application environments.
A process/procedure often defines the step-by-step actions that must be taken per the program and supporting rules.

3. Develop Performance Metrics to Measure Success

Establishing security metrics helps organizations assess how well they’re managing risks and maintaining PCI DSS compliance. Metrics should capture the effectiveness of risk assessments, access control mechanisms, and authentication systems, among others.

Use inputs like control evaluations, system logs, and incident tracking to inform performance indicators. These insights can be shared with stakeholders to justify resources and demonstrate progress in meeting compliance levels.

Metrics also help banks demonstrate ROI for security initiatives and identify areas needing remediation before audits.

4. Assign Ownership for Coordinating Security Activities

PCI DSS compliance requires dedicated leadership. Assign a compliance officer or equivalent role to coordinate all PCI-related security activities. This individual should:

Understand the bank’s technical infrastructure, including POS systems, public networks, and e-commerce gateways.
Be qualified to manage PCI DSS controls and ideally have experience working with a Qualified Security Assessor.
Serve as the central point of contact for updates, audits, and cross-departmental coordination.

5. Focus on Security and Risk Management Beyond Minimum Compliance

PCI DSS establishes a minimal set of security criteria for payment card account data protection. PCI DSS measures may not be sufficient to fully mitigate the financial risks connected with various forms of sensitive data that enterprises may have. It should not be considered a comprehensive checklist for addressing all security concerns.

A more robust strategy would be to focus on developing a security culture, protecting the organization’s IT infrastructure, and then allowing compliance to follow.

Choosing security controls using a risk-based approach allows businesses to adjust particular security measures to address varied degrees of operational risks.

6. Continuously Monitor and Improve Security Controls

A static approach to compliance gets outdated quickly. Develop a continuous monitoring strategy to ensure that controls remain effective across all operational areas, including branches, data centers, and on-site environments.

Your monitoring program should:

Align with overall security objectives and compliance levels.
Cover all locations within the PCI DSS scope, from retail to back office.
Validate that controls (e.g., access control, log review, authentication) function properly.
Track employee adherence to policies and flag deviations.

7. Maintain a Security Awareness Culture

Attackers target people, not just technology. This makes security awareness training a core component of effective PCI compliance. In fact, PCI DSS Requirement 12.6 mandates that organizations develop and maintain a formal program that includes:

Regular employee training upon hiring and at least annually thereafter
Clearly defined communication methods
Continuous reinforcement through internal campaigns or communication channels

Training should address how to identify phishing attacks, protect payment card data, and follow authentication protocols.

8. Monitor the PCI Compliance of Third-Party Service Providers

Third-Party Service Providers (TPSP) are often the ones implementing and maintaining the security measures to meet PCI DSS standards. Entities and their TPSPs must have explicit knowledge of their roles and duties to comply with applicable PCI DSS criteria.

Monitoring TPSP status is an essential part of compliance because it allows the entity to assess whether a change in status requires a change in the relationship.

9. Evolve the Compliance Program to Address Changes

PCI DSS compliance is a continuous process that must evolve alongside your business operations and technology stack.

Organizations that approach PCI as a point-in-time audit often fall behind. Instead, compliance programs should adapt dynamically by:

Regularly reviewing new risk assessment findings.
Updating documentation to reflect organizational structure changes.
Tracking developments in the broader payment card industry and aligning policies accordingly.

We also recommend that compliance managers establish mechanisms to communicate updates and changes efficiently across departments and to any impacted team members.

ZenGRC Helps Organizations Manage Their Compliance

ZenGRC is a centralized platform that helps you manage policies, map controls to PCI requirements, automate evidence collection, and assign tasks across teams all in one place. Whether you’re conducting a self-assessment or working with a Qualified Security Assessor, ZenGRC reduces administrative overhead and improves audit readiness.
Schedule a demo to see how ZenGRC supports smarter compliance workflows and strengthens your overall security posture.