Payment Aggregator: PCI DSS v4.0.1 Readiness with 60% Scope Reduction
Payment aggregators carry cardholder data and heavy regulator and acquirer scrutiny. This case (client name withheld under NDA) shows how Cybersigma reduced the assessed environment and reached PCI DSS v4.0.1 readiness.
Client Overview
The client is a payment aggregator processing card transactions for multiple merchants, facing PCI DSS v4.0.1 requirements from acquirers.
- Industry: Payments / Fintech
- Region: India
- Scope: Cardholder data environment (v4.0.1)
Challenge
Cardholder data sprawled across systems, inflating the assessment. The aggregator needed to meet v4.0.1 mandatory requirements under acquirer pressure.
- Cardholder data spread across many systems
- v4.0.1 mandatory requirements (MFA, encryption, key management)
- Large, costly assessment scope
- Acquirer deadline pressure
Objectives
- Reduce PCI scope via tokenization and segmentation
- Meet v4.0.1 mandatory requirements
- Reach QSA-assessment readiness
- Produce acquirer-ready evidence
Our Approach
1. Scoping & Data Discovery
We found every place cardholder data lived and designed the target reduced environment.
2. Scope Reduction
Tokenization and network segmentation to shrink the assessed environment substantially.
3. v4.0.1 Remediation
MFA, encryption, key management and continuous evidence mapped to v4.0.1.
4. QSA Readiness
Evidence, SAQ/ROC preparation and acquirer-ready reporting with retest closure.
Solution
- Discovered every location of cardholder data and designed a reduced environment
- Applied tokenization and network segmentation to shrink assessed scope
- Implemented v4.0.1 mandatory controls (MFA, encryption, key management)
- Prepared SAQ/ROC evidence and acquirer-ready reporting with retest closure
Results
- ~60% reduction in assessed PCI scope
- v4.0.1 mandatory requirements met
- QSA-assessment readiness achieved
- Acquirer-ready evidence with retest closure
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