FAQ #1312 Diff

If an entity uses a service provider that is not PCI DSS compliant, how does this impact the entity's compliance?

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Each payment brand may have their own requirements for using compliant service providers. Entities should contact their acquirer (merchant bank) or the payment brands directly to understand any requirements they have. Whether a service provider is required to validate PCI DSS compliance is determined by the individual payment brands.

There are many different scenarios where an entity, such as a merchant, may share cardholder data (CHD) or outsource elements of their cardholder data environment (CDE) to a service provider. In all scenarios, the entity must manage their service providers
When an entity (the TPSP customer) uses one or more TPSPs for functions within or related to the customer's cardholder data environment, it will impact the customer's PCI DSS compliance, specifically with PCI DSS Requirement 12.8 and with any PCI DSS requirements the TPSP is meeting on the customer's behalf.
In all scenarios where a TPSP is used, the customer must manage and oversee all their TPSP relationships and monitor the PCI DSS compliance status of their TPSPs
in accordance with Requirement 12.8. This includes performing due diligence, having appropriate agreements in place, identifying which requirements apply to the entitycustomer and which apply to the service providerTPSP, and monitoring the compliance status of service providersTPSPs at least annually. Requirement 12.8 does not specify that the entity's service providers must becustomer's TPSPs must be PCI DSS compliant, only that the entity monitorcustomer monitors their compliance status . Service providersas specified in the requirement. Therefore, TPSPs do not need to be validated as PCI DSS compliant in order for the entityfor the customer to meet Requirement 12.8.
If, however, a service provider provides a service that is in scope for the entity's PCI DSS requirements, then theHowever, if a TPSP provides a service that meets a PCI DSS requirement(s) on behalf of the customer, then those requirements are in scope for the customer's assessment and the TPSP's compliance of that service will impact the entitycustomer's compliance. For example;, if an entity engages a service provider to manage their firewalls, and the service provider is not meetinga customer engages a TPSP to manage their network security controls, and the TPSP does not provide evidence that it meets the applicable PCI DSS requirements in PCI DSS Requirement 1, then those requirements are not in place for the merchant's compliancecustomer's assessment. As another example, service providersTPSPs that store cardholder data on behalf of other entities wouldcustomers need to meet the applicable requirements related to access controls, physical security etc., in order for their customers to consider those requirements in place .

A service provider may be able to demonstrate that they've met the applicable requirements without undergoing a formal compliance validation. Refer to the "Use of Third-Party Service Providers / Outsourcing" section in PCI DSS v3 for guidance on how service providers may provide evidence of their compliance to their customers.
for their assessments.
Whether a TPSP is required to undergo a PCI DSS assessment is determined by organizations that manage compliance programs (for example, an acquirer, payment brand, or another entity). Entities should contact the organization that manages their compliance program directly to understand the requirements for TPSPs. Contact details for the payment brands can be found in FAQ #1142: How do I contact the payment card brands?
Refer to FAQ 1576: What evidence is a TPSP expected to provide to customers to demonstrate PCI DSS compliance?

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