- Published on
Designing a PCI DSS v4 Compliant Environment on AWS
- Authors

- Name
- Benson Macharia
- @benson-macharia
PCI DSS (Payment Card Industry Data Security Standard) is a global security standard designed to protect credit and debit card data. It applies to any organization that stores, processes, or transmits cardholder information. PCI DSS is important because payment card data is a major target for cybercriminals, and a single breach can lead to financial loss, legal penalties, and loss of customer trust. By following PCI DSS requirements, organizations reduce the risk of data breaches and show customers and partners that their payment data is handled securely.

PCI DSS version 4 introduces more stringent and modern security requirements to address today’s evolving threats and cloud-based environments. It places stronger emphasis on continuous security, risk-based controls, and accountability rather than simple checkbox compliance. The main requirements for PCI DSS v4 include:
| Requirement | New or Updated in v4? |
|---|---|
| 1. Install and maintain network security controls | Updated (stronger focus on cloud and dynamic environments) |
| 2. Apply secure configurations to all system components | Updated (explicit system hardening and configuration management) |
| 3. Protect stored account data | Updated (clearer encryption, key management, and data retention rules) |
| 4. Protect cardholder data with strong cryptography during transmission | No (clarified and reinforced) |
| 5. Protect all systems and networks from malicious software | Updated (explicit coverage for phishing and evolving malware threats) |
| 6. Develop and maintain secure systems and software | Updated (secure software development lifecycle and change management) |
| 7. Restrict access to system components and cardholder data by business need to know | No |
| 8. Identify users and authenticate access to system components | Yes (expanded Multi-Factor Authentication requirements) |
| 9. Restrict physical access to cardholder data | No |
| 10. Log and monitor all access to system components and cardholder data | Yes (stronger logging, monitoring, and alerting expectations) |
| 11. Test security of systems and networks regularly | Updated (continuous testing and targeted risk analysis) |
| 12. Support information security with organizational policies and programs | Yes (defined roles, ongoing risk assessments, and security awareness) |
AWS Cloud helps organizations achieve PCI DSS v4 compliance faster and more efficiently compared to traditional on-premises data centers. AWS provides a secure-by-design infrastructure with built-in controls for network security, encryption, identity management, logging, and monitoring, which directly support many PCI DSS requirements.
PCI DSS v4 Compliance on AWS
By using managed AWS services, organizations reduce operational overhead, improve consistency, and more easily meet the continuous security expectations introduced in PCI DSS v4. The sections below provide a detailed guide on how different AWS services can assist organizations in achieving PCI DSS v4 compliance.
Requirement 1: Install and maintain network security controls
AWS enables strong network security using services such as Amazon VPC, security groups, and network ACLs to control inbound and outbound traffic. Customers can design isolated cardholder data environments (CDEs) using VPC segmentation, private subnets, and AWS Network Firewall. These controls are software-defined, easier to audit, and quicker to change than traditional physical firewalls.
Requirement 2: Apply secure configurations to all system components
AWS helps enforce secure system configurations using services like AWS Systems Manager, AWS Config, and Amazon Machine Images (AMIs). Organizations can define baseline configurations, continuously monitor drift, and automatically remediate non-compliant resources. This supports PCI DSS v4’s emphasis on configuration management and continuous compliance.
Requirement 3: Protect stored account data
AWS provides strong encryption capabilities through AWS Key Management Service (KMS) and AWS CloudHSM. Cardholder data can be encrypted at rest across services such as Amazon RDS, DynamoDB, and S3. AWS also supports key rotation, access controls, and separation of duties, which are critical for PCI DSS v4 key management requirements.
Requirement 4: Protect cardholder data during transmission
AWS supports encryption in transit using TLS across its services. Load balancers such as Application Load Balancer and Network Load Balancer integrate with AWS Certificate Manager to manage certificates securely. This allows organizations to enforce strong cryptography without managing certificates manually.
Requirement 5: Protect all systems and networks from malicious software
AWS helps protect against malware and phishing threats using Amazon GuardDuty, AWS Shield, and Amazon Inspector. These services provide threat detection, vulnerability scanning, and continuous monitoring, aligning with PCI DSS v4’s expanded focus on evolving attack techniques.
Requirement 6: Develop and maintain secure systems and software
AWS supports secure development through services such as AWS CodePipeline, CodeBuild, and CodeDeploy, combined with security scanning tools like Amazon Inspector. Infrastructure as Code using AWS CloudFormation allows secure, repeatable deployments and controlled change management.
Requirement 7: Restrict access to system components and cardholder data
AWS Identity and Access Management (IAM) allows fine-grained, role-based access control using least privilege principles. Access to the cardholder data environment can be tightly controlled and audited, reducing the risk of unauthorized access.
Requirement 8: Identify users and authenticate access to system components
PCI DSS v4 significantly expands Multi-Factor Authentication (MFA) requirements, which AWS supports natively through IAM and AWS Single Sign-On. MFA can be enforced for all privileged and remote access to systems that handle cardholder data.
Requirement 9: Restrict physical access to cardholder data
Under the AWS shared responsibility model, AWS manages physical security of data centers, including access controls, surveillance, and environmental protections. This removes a major compliance burden compared to on-premises data centers.
Requirement 10: Log and monitor all access to system components and cardholder data
AWS provides centralized logging and monitoring using AWS CloudTrail, Amazon CloudWatch, and AWS OpenSearch. These services enable detailed audit trails, real-time alerts, and log retention, supporting PCI DSS v4’s stronger monitoring and detection requirements.
Requirement 11: Test security of systems and networks regularly
AWS supports continuous testing through Amazon Inspector, automated vulnerability scanning, and integration with third-party penetration testing tools. PCI DSS v4’s requirement for targeted risk analysis is easier to achieve with automated and scalable cloud-based testing.
Requirement 12: Support information security with organizational policies and programs
AWS provides compliance reports, audit artifacts, and security best practices through AWS Artifact. Combined with services like AWS Organizations and Security Hub, organizations can define responsibilities, perform risk assessments, and maintain ongoing security governance as required by PCI DSS v4.
Conclusion
In conclusion, designing a PCI DSS v4 compliant environment on AWS allows organizations to meet strict security requirements while gaining the flexibility and scalability of the cloud. AWS provides a wide range of managed services that support encryption, access control, monitoring, and continuous security, which are core to PCI DSS v4. By leveraging the AWS shared responsibility model and security best practices, organizations can reduce complexity, lower operational costs, and maintain compliance more effectively than in traditional on-premises environments. This approach not only helps achieve compliance faster but also supports ongoing security improvements as threats and business needs evolve.
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