Playing Games with PCI Compliance Deadlines

The report warns that PCI DSS v4.0 became mandatory on April 1, 2024, with certain future-dated requirements effective by April 1, 2025, and cautions organizations against delaying implementation until just before their next assessment. It explains how QSAs might detect (or fail to detect) late implementations or fraudulent backdating, gives examples of requirements that leave clear audit trails versus those that do not, and recommends that organizations proactively align with v4.0 and prepare for the future-dated requirements to avoid non-compliance.