How to use this tool

PCI Gap Analysis — Guide

How to track your PCI DSS v4.0 compliance status across all 12 requirements, use the status filters, and export a workbook for QSA pre-audit preparation.

What is this tool for?

PCI DSS has 12 high-level requirements and over 300 sub-controls. Tracking your compliance status across all of them — and knowing which gaps are blocking your acquirer application — requires a structured approach. This tool provides a complete checklist of all PCI DSS v4.0 requirements with status tracking, filtering by requirement domain and compliance goal, and CSV export for pre-audit workbooks.

It is designed for engineering leads and compliance teams working towards their first formal PCI DSS assessment, or managing ongoing compliance between annual QSA audits.


Step-by-step walkthrough

Step 1 — Review the summary stats
  1. The five stat cards at the top show totals for Compliant, Partial, Gap, Not Started, and Not Applicable requirements.
  2. Focus on the Gap and Not Started counts first — these are the items blocking PCI compliance.
Step 2 — Filter and find gaps
  1. Use the status filter chips to show only Gap items — this gives you your remediation backlog.
  2. Use the requirement number filter (1–12) to focus on a specific PCI domain (e.g. Req 8 for identity, Req 10 for logging).
  3. Use the goal filter to group requirements by their underlying security objective.
Step 3 — Update requirement statuses
  1. Click any requirement row to expand it and see the full control description.
  2. Use the status dropdown to update the requirement's current state: Compliant, Partial, Gap, Not Started, or Not Applicable.
  3. Add notes to record your implementation details or evidence location.
Step 4 — Export for QSA pre-audit
  1. Click Export CSV to download all requirements with statuses and notes.
  2. Share with your QSA as a pre-audit workbook to accelerate the formal assessment.

Status definitions

Use consistent status definitions across your team to ensure the gap analysis accurately reflects your compliance state.
Compliant
The control is fully implemented, tested, and documented. Evidence is available for QSA review.
Partial
The control is partially implemented. Some but not all sub-controls are satisfied. Remediation is in progress.
Gap
The control is not implemented. This is a blocking issue that must be remediated before passing a PCI assessment.
Not Started
The control has not been assessed yet. Treat as a gap until assessed.
Not Applicable
The control does not apply to your environment (e.g. you do not store PANs, so Req 3 storage controls may not apply). Requires QSA sign-off to confirm.
Not Applicable does not mean you can ignore a requirement. You must document why it does not apply and have a QSA confirm the scoping decision. Incorrectly marking controls as N/A is one of the most common findings in PCI audits.

Key terms

PCI DSSPayment Card Industry Data Security Standard — a set of security standards for organisations that handle branded credit cards. Maintained by the PCI Security Standards Council.
PCI DSS v4.0The current version of PCI DSS, effective March 2024. Key additions: customised approach option, MFA requirements extended to all CDE access, stricter requirements for automated agent accounts (Req 8.6).
QSAQualified Security Assessor — a PCI DSS auditor certified by the PCI Security Standards Council. Required for Level 1 merchants (>6M transactions/year) and many Level 2 merchants.
SAQSelf-Assessment Questionnaire — a reduced compliance validation for smaller merchants. Different types (A, A-EP, B, D) apply to different card data handling models.
ROCReport on Compliance — the formal document produced by a QSA certifying that a full PCI DSS assessment was completed and the organisation is compliant.
Compensating controlAn alternative security measure that provides equivalent protection to a PCI requirement that cannot be met as written. Must be documented and approved by a QSA.

Frequently asked questions

Ready to track your PCI DSS compliance?
Work through all 12 requirements, identify your gaps, and export a pre-audit workbook.