PCI DSS Gap Analysis: How to Identify Compliance Gaps

Meeting PCI DSS requirements starts with understanding where your organization stands today. That’s where a PCI DSS gap analysis comes in. It’s a diagnostic process that pinpoints which controls are already in place, which ones are missing, and what actions are needed to achieve full compliance.

If your organization stores, processes, or transmits payment card data, conducting a gap analysis is a practical first step to strengthening security and reducing risk. This guide walks through the process—from scoping and assessment to remediation and reporting—to help you build a solid foundation for PCI compliance.

What Is a PCI DSS Gap Analysis?

A PCI DSS gap analysis is a structured review of your organization’s systems, policies, and procedures to determine how well they align with the Payment Card Industry Data Security Standard (PCI DSS).

The goal is to identify weaknesses (e.g., missing firewalls, outdated encryption protocols, or inadequate access controls) before undergoing a formal compliance assessment. This proactive approach allows businesses to prioritize fixes, reduce audit complexity, and improve overall security posture.

Why a PCI DSS Gap Analysis Is Important

A thorough gap analysis offers more than just a compliance checklist such as:

Pinpoints risk areas before they become liabilities
Improves audit readiness and reduces time spent on remediation later
Supports internal accountability by linking controls to systems and teams
Strengthens customer trust by demonstrating a proactive approach to data protection

In regulated industries like finance and e-commerce, PCI non-compliance can result in fines, reputational damage, and even loss of payment processing privileges. A gap analysis signals that security is being taken seriously and helps build confidence with clients and partners alike.

Step 1: Define the Scope of Your Analysis

The first step in a PCI DSS gap analysis is to define the Cardholder Data Environment (CDE)—the systems and networks that store, process, or transmit cardholder data.

Key activities include:

Identifying all in-scope systems and applications, including cloud services and third-party platforms
Mapping data flows using network diagrams and flowcharts to track how cardholder data moves through your infrastructure
Reviewing third-party involvement, such as payment processors or cloud providers, and collecting their PCI attestations (e.g., AOCs)

Failing to correctly scope your CDE can lead to blind spots that undermine the accuracy and effectiveness of your gap analysis.

Step 2: Review PCI DSS Requirements

PCI DSS v4.0 is organized into six control objectives and 12 core requirements, covering areas like:

Not every requirement applies equally to every organization. Factors like business model, transaction volume, and how cardholder data is processed influence which controls are relevant and how they’re implemented.

By reviewing the standard through the lens of your business model, you can tailor the analysis to focus only on relevant controls—saving time and avoiding unnecessary work.

Step 3: Conduct the Initial Assessment

With your scope defined and requirements reviewed, the next phase is data collection. This includes:

This step provides a practical understanding of how controls function day-to-day, and often reveals hidden compliance gaps such as

Combining technical review with stakeholder insights ensures a realistic picture of your current state.

Step 4: Identify and Document Compliance Gaps

Once the current state of your security environment is understood, the next step is to evaluate each PCI DSS control to determine its implementation status such as:

Evaluate not just the existence of controls, but also their effectiveness. A policy that mandates log reviews, for example, is insufficient if those logs aren’t actually monitored.

Document all gaps with:

This clear documentation not only supports internal understanding, it also helps external assessors or compliance partners verify the accuracy of the findings and track progress toward closure.

Step 5: Prioritize Risks

Not all gaps carry the same weight. Prioritize based on risk level (the likelihood and impact of exploitation), operational urgency, and ease of remediation.

For example, an exposed internal system with no firewall is a critical issue, while a minor logging configuration may pose lower risk.

Assess the resources, time, and potential disruptions required to remediate each gap. This prioritization helps teams focus efforts where they matter most.

Organizations that want to reduce this complexity often choose to work with PCI-compliant hosting providers like AISN, who offer environments built to meet PCI standards and can streamline much of the technical remediation work.

Step 6: Create a Remediation Strategy

A well-structured remediation strategy turns your gap analysis findings into a concrete action plan. Typical remediation activities include:

Reconfiguring firewalls to segment the Cardholder Data Environment (CDE)
Enforcing multi-factor authentication (MFA) for all remote and administrative access
Encrypting stored and transmitted cardholder data using strong, approved algorithms
Updating or creating written security policies and access control procedures
Deploying or tuning antivirus and endpoint protection systems
Providing role-specific security awareness training to staff
Implementing centralized logging and regular log reviews

To ensure accountability, each remediation task should be assigned to a responsible team or individual. Ownership must be clearly defined, especially for shared systems or third-party dependencies.

In regulated sectors, maintaining a detailed remediation log also demonstrates due diligence if an auditor or client requests proof of your compliance efforts.

Step 7: Report and Communicate Results

The final stage of the gap analysis involves organizing your findings into a clear, actionable report that includes:

Clear reporting ensures alignment between technical teams and decision-makers, and provides essential documentation for future assessments or audits.

What Comes Next: From Gap Analysis to Full Compliance

Your PCI DSS gap analysis is just the beginning as it sets the stage for formal validation. Whether through a Self-Assessment Questionnaire (SAQ) or a Report on Compliance (ROC) with a Qualified Security Assessor (QSA), maintaining compliance long-term requires:

For many organizations, working with a PCI-compliant hosting provider like AISN simplifies this ongoing effort. From secure infrastructure to audit preparation, AISN offers solutions designed to help businesses maintain compliance year-round.

Turn Insight Into Action

A well-executed PCI DSS gap analysis does more than uncover compliance shortfalls, it sharpens your security focus and drives meaningful improvements.

In today’s threat landscape, that kind of clarity is invaluable. But it only delivers value if you act on it. Organizations that embed PCI compliance into their operations—rather than treating it as a one-time project—are better equipped to manage risk, earn customer trust, and adapt to future requirements.

AIS Network can help you move forward with confidence whether you need guidance with remediation, assistance with audit prep, or full-service PCI hosting support. Contact us today to learn more.