Companies Increasingly Fail Interim Security Test, But Gap Narrows

The share of companies passing their interim security tests under the Payment Card Industry's Data Security Standard (PCI DSS) — a practice run to help firms meet full compliance — dropped to 37% in 2018, the lowest level in five years, according to Verizon's "2019 Payment Security Report," published Nov. 12.

The decline in successful interim security audits is steep. In 2016, more than half of companies — 55% — taking a practice run through the painful compliance process mandated by PCI DSS passed the interim compliance audit. The ability to pass the assessment is a measure of the stability of a company's compliance processes and security controls, says Ciske Van Oosten, senior manager of global intelligence for Verizon's Security Assurance Consulting practice.

In the past, companies seemed on a path to improving their processes every year, but after 2016, companies started failing more often, Van Oosten says.

"We thought the growth was going to continue forever," he says. "But we now see that full compliance needs to be sustainable in the long term and not just at a point in time."

The news is not all bad. While a smaller share of companies maintained their security controls between compliance tests, the amount by which the average company fell out of compliance remained stable or declined. In 2018, the average gap between full compliance and the interim assessment for companies that failed to pass was about 10%, six percentage points less than four years ago, Van Oosten says.

The quarterly interim testing helps companies identify places where they have fallen out of compliance with security requirements and gives them a chance to fix the issues before the actual compliance testing.

"Organizations are required to not only achieve 100 percent full compliance with the PCI DSS, but also to maintain it," the report stated. "This means having all applicable security controls continuously in place and functioning as intended."

The Payment Card Industry's compliance regime has been a major headaches for companies, requiring significant amounts of investment and resources. Yet with breaches continuing to plague businesses and third-party risk becoming much more of a concern, PCI DSS has become the preferred way to test whether partners and vendors are meeting their security obligations, Van Oosten says.

"We had a lot of attention in the media [in the past], but that is not driving the attention on compliance," he says. "The driver for PCI DSS seems to be business to business, where a company will not do business with a partner unless they can show that they handle the data correctly."

The reason for the decline over the past two years in interim compliance is not obvious, says Van Oosten.

The PCI DSS requirements organizations most often failed to maintain include No. 11 ("Test Security Systems and Process"), No. 6 ("Develop and maintain secure systems"), and No. 8 ("Authenticate access"). A third of companies — the largest portion — failed to run regular network and vulnerability scans (requirement 11.2), according to Verizon's report. Twenty-eight percent of companies failed to protect software components and applications from known vulnerabilities (requirement 6.2), and 27% failed to recheck security control flagged by penetration testing to ensure that issues were fixed (requirement 11.3.3).

"The largest compliance drop occurred against Requirement 6, as organizations struggled to maintain effective vulnerability management, software development and change processes," the report stated. "It is then perhaps not too surprising that Requirement 11 remained the poorest performer—both in overall compliance and control gap—as organizations struggle to sustain compliance with security testing requirements year after year."

Van Oosten urged companies to have a security program in place to guide the implementation of necessary security controls. In addition, companies need to have a way of generating metrics to measure their progress in implementing the controls, he says.

"Security controls are all that stand between you and attackers out there on the Internet," Van Oosten says. "You need to manage PCI-DSS compliance as a program."

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