Frequently Asked Question

Does PCI DSS apply to “hot cards,” expired, cancelled or invalid card account numbers?

PCI DSS applies to any primary account number (PAN), including active, expired, or cancelled PAN, except where the organization can provide documentation which confirms that the PAN is inactive or otherwise disabled and no longer poses a fraud risk to the payment system. If, however, the PAN is later reactivated, PCI DSS will again apply.

When payment cards expire, the same account number is often reused on the new card with a different expiry date. The PAN must therefore be verified as not being valid before expired cards are excluded from PCI DSS scope.

Entities should retain PAN based on business/legal needs, as defined in data retention policy (PCI DSS Requirement 3.1).  Remember: If you don’t need it, don’t store it.


July 2015
Article Number: 1038