Frequently Asked Question

Can PFIs provide reports to their clients before sending the report to the affected payment brands?
No. It is not acceptable for reports (draft or final) to be issued to clients, acquirers, issuers, or other parties for review/amendment before being sent to payment brands and/or acquirers. PCI Forensic Investigators (PFIs) are obliged under the terms of the PFI Program Guide to provide Preliminary Incident Response Reports and Final PFI Reports to their client, each affected payment brand, and their client's affected acquirer(s). The reports must be sent to all parties (clients, affected payment brands and all affected acquirer(s) identified in Appendix C of the Final PFI Report) at the same time.
Appendix A of the PFI Program Guide describes the provisions PFI Companies must include in their contracts to support the report delivery requirements. Appendix C: Impacted Entities should be broken out into separate lists for each acquirer (if more than one acquirer is involved), with a complete "master list" provided to each affected payment brand.
The judgements, conclusions, and findings in PFI reports must be based solely on the factual evidence obtained during the investigation and reflect the independent judgement, findings, and conclusion of the PFI company. If an amendment is required to a Final PFI Report post-issue, for example to correct a factual error or omission, the amendment must be clearly evidenced in the Table of Changes in the revised report and the report version number incremented appropriately.
Related
-
What are the expectations for entities when assigning risk rankings to vulnerabilities and resolving or addressing those vulnerabilities?
-
Is phishing-resistant authentication alone acceptable as multi-factor authentication for PCI DSS Requirements 8.4.1 and 8.4.3?
-
Are passkeys synced across devices, implemented according to the FIDO2 requirements, acceptable for use as phishing-resistant authentication to meet PCI DSS Requirement 8.4.2?
Featured FAQ Articles
Featured
-
Do PCI DSS requirements for keyed cryptographic hashing apply to previously hashed PANs?
-
Is the PCI DSS Attestation of Compliance intended to be shared?
-
How does an entity report the results of a PCI DSS assessment for new requirements that are noted in PCI DSS as best practices until a future date?
-
Where do I direct questions about complying with PCI standards?
-
Can SAQ eligibility criteria be used as a guide for determining applicability of PCI DSS requirements for merchant assessments documented in a Report on Compliance?
Most Popular
-
What are the expectations for entities when assigning risk rankings to vulnerabilities and resolving or addressing those vulnerabilities?
-
Is phishing-resistant authentication alone acceptable as multi-factor authentication for PCI DSS Requirements 8.4.1 and 8.4.3?
-
Are passkeys synced across devices, implemented according to the FIDO2 requirements, acceptable for use as phishing-resistant authentication to meet PCI DSS Requirement 8.4.2?
-
How should PCI DSS v4.x requirements noted as superseded by another requirement be reported after 31 March 2025?
-
Are providers of third-party scripts for e-commerce environments considered third-party service providers for PCI DSS Requirements 12.8 and 12.9?
Most Recently Updated
-
How often must service providers test penetration testing segmentation controls under PCI DSS?
-
Are merchants allowed to request card-verification codes/values from cardholders?
-
What is the maximum period of time that cardholder data can be stored?
-
How can an entity ensure that hashed and truncated versions cannot be correlated?
-
Are point-of-interaction devices required to be physically secured (for example, with a cable or tether) to prevent removal or substitution to meet PCI DSS Requirement 9.5?