PCI DSS violations: What they are and how to avoid them in 2025

PCI DSS violations directly threaten your ability to accept payments and protect your customers’ sensitive information. As cyberattacks become more sophisticated, gaps in your compliance controls can quickly lead to data breaches, audit failures, and costly remediation. 

In this guide, we’ll explain why staying on top of PCI DSS requirements matters and how to guard against common pitfalls.

Why PCI DSS violations matter in today’s threat landscape

Every day, attackers probe for weak points in payment systems—from unencrypted databases to misconfigured networks—and any lapse in your PCI controls can be an open door. Failing to encrypt cardholder data, monitor access, or apply security patches leaves you vulnerable to breaches that compromise customer trust and lead to extensive investigations. 

By understanding the critical nature of these requirements, you ensure your security efforts focus on the most dangerous gaps before they’re exploited.

The rising risk of fines and reputational damage

Non‑compliance with PCI DSS can trigger penalties of up to tens or even hundreds of thousands of dollars per month. These are determined and enforced by payment brands and acquiring banks, not PCI SSC. 

Beyond financial losses, publicized breaches erode customer confidence and can lead to the termination of partnerships with key vendors. Maintaining strong, continuous compliance not only avoids steep fines but also preserves your reputation, thus demonstrating to customers and partners that you take their data protection seriously.

‍The cost of non-compliance in modern payment ecosystems

Non-compliance penalties start modestly but escalate rapidly. 

Industry reports note that initial fines after a breach typically range $5,000–$10,000 per month, jumping to $25,000–$50,000 per month by months four to six,  and $50,000–$100,000+ monthly if issues persist. 

Smaller merchants commonly incur $5,000–$100,000 per month in recurring fines, while major breaches have led to multi-million‑dollar penalties. In extreme cases, fines or related regulatory penalties can approach half a million dollars per incident.

Beyond direct fines, non-compliance carries steep hidden costs. Mandatory forensic investigations and breach remediation can cost hundreds of thousands more, and companies often face costly legal actions. For example, Target’s 2013 breach (tied to PCI gaps) ultimately cost the company roughly $292 million. 

Reputation damage is also significant: studies show that about 66% of consumers would lose trust in a company after a data breach. Higher credit-card processing fees, increased transaction rates, or even loss of merchant account privileges may follow compliance failures. The combined direct and indirect costs of PCI DSS violations can easily dwarf the expense of proactive compliance.

What triggers PCI compliance fines?

PCI DSS fines are typically imposed when an organization fails to meet required security obligations. Common triggers include:

• Cardholder data breaches or exposures: Any incident that leaks credit card data (e.g., due to malware, hacking, or insecure storage) often triggers penalties. For example, storing unencrypted PANs or CVV codes is a direct violation. Even sending card data without strong encryption or proper isolation (weak segmentation) can count as a breach of PCI rules.
  
  
• Non-adherence to technical controls: Skipping required security controls, such as neglecting firewalls, vulnerability scans, patching, or multi-factor authentication (MFA) – can incur fines. PCI regulations mandate regular system scans and security measures; failing these checks (or running non-compliant payment applications) is a violation. For instance, outdated software or missing network security controls put card data at risk and can prompt fines.
  
  
• Failure to submit required reports (SAQs/ROCs): PCI DSS requires merchants to validate compliance annually. Small merchants typically file a Self-Assessment Questionnaire (SAQ), while large ones need a Report on Compliance (ROC) from a QSA. Failing to complete and submit these compliance reports to the acquiring bank on schedule is a violation. If you never file an SAQ or ROC as required, or if the report is incomplete, fines can be levied.
  
  
• Late or no breach reporting: If a breach or security incident occurs, merchants must report it promptly (often within hours or days, per card brand rules). Missing that deadline or hiding the incident can lead to steep penalties. The PCI rules explicitly impose fines for “failing to report a breach within the specified time”. Delays in notifying your bank or the card brands about a compromise will be treated as a serious violation.

Any significant gap in compliance, whether a technical lapse or a reporting failure, can therefore trigger PCI fines. The payment brands and acquiring banks monitor adherence closely, and non-conformance (even if unintentional) is met with fines to enforce remediation.

Who imposes the fines?

PCI DSS fines are not issued by the PCI Security Standards Council. Instead, the card networks and acquiring banks enforce penalties. Major payment brands (Visa, Mastercard, AmEx, Discover, JCB, etc) set the rules and can decide when fines are warranted. They levy fines on the acquiring (merchant) bank for non-compliance. The acquirer then passes those costs (and any extra fees) down to the merchant. 

For example, NordLayer explains that if Visa finds a merchant lacking sufficient encryption, “Visa will technically fine the merchant’s bank… however, the bank will then pass on the fine to the business in question.” 

Similarly, SecurityCompass notes that fines are imposed “by acquiring banks and payment processors, not the PCI SSC.”

Thus, responsibility cascades: card brands set penalties, banks enforce them, and merchants (and their service providers) ultimately pay. An acquiring bank is contractually responsible for its merchants’ PCI compliance, so it has the authority to charge the merchant when a violation occurs. 

In severe cases, banks can also suspend or revoke a merchant’s account if compliance isn’t restored. The financial liability for PCI fines flows from the card brands to banks or processors to the merchant or service provider responsible for the violation.

What constitutes a PCI DSS violation?

Any breach of PCI DSS v4.0.1 control opens your business to financial penalties, disrupted payment capabilities, and damaged trust. Here's what you need to watch for:

1. Weak encryption or missing access logs

If your systems aren’t using strong encryption—like TLS 1.2 or higher—as required by Requirement 4 of PCI DSS, or if they don’t log and review all access to cardholder data under Requirement 10, you risk data exposure and miss your ability to detect unauthorized activity. 

Proper encryption and logging help you protect customer information and prove compliance.

2. Storing PAN or CVV without protection

PCI DSS Requirement 3 forbids storing CVV codes after authorization in any form - readable or non-readable. The requirement allows storing Primary Account Numbers (PAN) if rendered unreadable (encryption, hashing, truncation, or tokenization). Keeping them in plain text, even briefly, violates this core rule and increases risk. 

Encrypting or not storing these values ensures you adhere to PCI’s most sensitive data protections.

3. Skipped vulnerability scans or delayed patching

PCI DSS Requirements 6 and 11 mandate that you patch vulnerabilities promptly—within 30 days for critical issues—and perform vulnerability scans at least quarterly. When you fall behind, you leave open doors for attackers. 

By staying on schedule, you minimize risk and maintain a secure, compliant environment.

4. Failing to apply multi-factor authentication (MFA) or segmentation

PCI DSS v4.0.1 requires multi-factor authentication (MFA) for all access into the Cardholder Data Environment (CDE) (Requirement 8.4.2) and network segmentation to isolate that environment.  Without these, you risk unauthorized access to critical systems. Applying MFA and segmentation keeps your payment zone secure and compliant.

Top PCI DSS 4.0 violations you need to avoid

The updated standard introduces specific new failure triggers, such as:

1. Failing to maintain continuous compliance

With PCI DSS 4.0, compliance cannot be “turned off” between audits. Controls must be in place and evidence available at all times. Treating compliance as a periodic obligation invites violations immediately. Embracing continuous processes ensures compliance is embedded daily.

2. Misusing the customized approach

PCI DSS v4.0.1 allows tailored control methods instead of default controls, but only with full documentation, testing, and Qualified Security Assessor (QSA) approval. Skipping any of these steps turns flexibility into non-compliance. Properly recorded and tested alternatives allow you to innovate securely.

3. Weak passwords or no phishing-resistant MFA

New rules now require passwords of at least 12 characters (8 if MFA and other controls apply) (Requirement 8.3.6) and stronger MFA (Requirement 8.4.2). Using shorter passwords or weak authentication methods violates these requirements and heightens the risk of credential theft. Full adherence boosts your account security and audit readiness.

4. Missing phishing protection and awareness training

Under Requirement 12.6.3, PCI DSS v4.0.1 mandates regular employee training on phishing. If your staff aren't trained or protections aren't in place, you face violations. Implementing these measures shields your organization from social engineering threats and strengthens compliance.

Preventing PCI DSS Violations: A practical step‑by‑step guide

Keeping cardholder data safe and avoiding PCI DSS 4.0.1 violations starts with simple, repeatable steps your whole team can follow. Here’s a walkthrough:

1. Map your payment environment

Begin by creating and maintaining an up‑to‑date inventory of every device, application, and service that touches card data, whether it’s a point‑of‑sale terminal, a cloud service, or a third‑party processor. Revisiting this inventory at least once a year ensures you never overlook a new system or vendor, and it gives you clear boundaries for where PCI controls must apply.

2. Get to know the standard

‍Take time to read through the latest PCI DSS requirements and identify which ones matter most for your setup. By understanding what the standard demands—be it strong encryption, regular scans, or strict access controls—you’ll know exactly where to focus your efforts and why each control exists.

3. Train your team regularly

Security is a shared responsibility. Schedule brief, engaging sessions so every employee, from the front‑line cashier to the network engineer, understands how their daily actions protect card data. When staff learn to spot phishing attempts, handle data properly, and follow secure procedures, they become your strongest line of defense.

4. Encrypt data everywhere

Anytime cardholder information is transmitted or stored, it needs strong encryption, ideally TLS 1.2+ for transmission and AES‑256 for storage. Avoid keeping PAN or CVV beyond what’s necessary; if you do store it, make sure it’s fully encrypted. This practice makes stolen data unreadable and removes the biggest risk from data breaches.

5. Control who can see card data

‍Limit access so that only the people who need cardholder information to do their jobs can get to it. Use unique user IDs, strong passwords of at least 12 characters (8 if MFA and other controls apply), and MFA for every login to payment systems. This way, you’ll know exactly who did what and when, and stop unauthorized attempts before they succeed.

6. Isolate your payment network

‍Segment the CDE from the rest of your business network with firewalls and access rules. If an intrusion occurs elsewhere in your network, this separation keeps attackers away from the systems that handle payments, reducing your scope for compliance and your exposure to risk.

7. Stay on top of vulnerabilities

‍Set up quarterly vulnerability scans and follow up immediately with patches and configuration fixes. If a weakness appears—whether in a server, application, or network device—address it within 30 days. This disciplined cycle prevents small issues from turning into big problems during an audit or a cyber attack.

8. Lock down your wireless

‍If you must use Wi‑Fi for payment processes, secure it with WPA2 or higher encryption, change all default passwords, and consider validated point‑to‑point encryption. Regularly audit access points to make sure no rogue devices can eavesdrop on your transactions.

9. Log and monitor continuously

‍Configure your systems so every access, change, and error in the CDE is recorded in detail. Use real‑time alerts to flag unusual patterns—like failed logins or sudden data exports—and investigate immediately. Continuous oversight helps you catch issues before they lead to violations or breaches.

10. Keep software up to date

‍Whether it’s your payment application, operating system, or network firmware, apply security patches as soon as they’re available. Outdated software is one of the most common routes attackers use to compromise systems, so this step protects both your compliance status and your customers.

11. Control physical entry

‍Make sure only authorized personnel can reach servers or devices that store or process card data. Use locks, badges, cameras, and visitor logs to track who enters secure areas, so you can demonstrate that cardholder data remains under strict physical control.

12. Review and test compliance

‍Perform self‑assessments and bring in external experts periodically to challenge your assumptions and find gaps you might have missed. Regular testing, whether through internal audits or third‑party assessments, keeps your controls sharp and your documentation audit‑ready.

13. Document and update policies

‍Write down your security policies—covering encryption, access, incident response, and more—and review them at least once a year or when your technology changes. Embedding these policies into your training and daily workflows ensures everyone follows the same secure practices.

14. Prepare for incidents

‍Have a clear incident response plan that names roles, steps, and communication channels. When a breach or security event happens, you’ll move quickly, notify the right people, and restore operations without panic, demonstrating to regulators that you’re in control.

How Scrut helps you avoid PCI DSS violations

• PCI DSS 4.0‑ready framework
  Scrut embeds every control from the latest PCI DSS 4.0 standard into your workflow, so you immediately see which encryption settings, access rules, and segmentation requirements apply. 
  
  This direct mapping prevents guesswork, ensuring your team configures systems correctly from the start and reduces the chance of missing a critical control that could trigger a violation.

• Automated evidence mapping
  By automatically capturing logs from vulnerability scans, patch installations, and user training sessions, Scrut ties each event to its corresponding PCI requirement.
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  This real‑time mapping saves you from hunting down disparate files and guarantees that when an auditor asks for proof, you can present up‑to‑the‑minute evidence without manual effort.

• Audit preparation tools with centralized logs
  Scrut gathers network diagrams, test results, and control checks into one secure workspace. 
  
  Rather than scrambling to assemble documents at audit time, you’ll have a single source showing your compliance status. This makes audit prep faster, more organized, and far less stressful—helping you avoid violations due to missing or outdated records.

• Real‑time control dashboards
  With live dashboards, you’ll see immediately if a certificate is expiring, a scan has failed, or a segmentation rule was changed. Instant alerts let your team fix these issues before they amount to non‑compliance. This continuous visibility is critical under PCI DSS 4.0’s requirement for ongoing enforcement.
  
  
• Policy templates for key documentation gaps: Scrut’s library includes customizable templates for data access policies, encryption standards, network segmentation procedures, and phishing awareness. 

Each template is already aligned with specific PCI controls, so you can quickly fill in your environment’s details and close documentation gaps that often lead to violations.

Ready to strengthen your PCI DSS compliance and eliminate violations? Schedule a demo with Scrut today and see how automated controls, real-time monitoring, and audit‑ready reports can keep your payment environment secure and compliant.

FAQs

What are common PCI DSS violations?

Common violations include unencrypted storage of card data, missing multi‑factor authentication, and skipped vulnerability scans. These oversights leave payment data exposed and breach core PCI requirements.

What happens if you violate PCI DSS?

‍Violations can lead to fines from payment networks, increased transaction fees, and suspension of card processing privileges. They also raise the risk of data breaches and damage your company’s reputation.

Who is liable for PCI DSS non-compliance?

‍The merchant or service provider that stores, processes, or transmits cardholder data is responsible for compliance. Ultimately, your organization’s leadership and IT/security teams share accountability for meeting PCI standards.

How can PCI DSS violations be prevented?

‍Implement continuous monitoring, enforce strong encryption and multi‑factor authentication, and conduct regular internal audits and staff training. Automating evidence collection and maintaining up‑to‑date documentation also keeps you ahead of potential gaps.

What are the consequences of non-compliance?

‍Beyond financial penalties and higher processing costs, non‑compliance can trigger legal action from regulators and erode customer trust. It may also force costly remediation efforts and longer‑term damage to your brand.