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PCI DSS AI Compliance Checklist

Assess your AI system's PCI DSS compliance. 22 questions across 5 categories.

Cardholder Data Protection in AI

Encryption, storage, and minimization of cardholder data processed by AI systems according to PCI DSS requirements.

Does your AI system store and process only the minimum necessary cardholder data (e.g., it does not store the full PAN or CVV unless absolutely required)?

PCI DSS requirement 3.1 mandates minimizing stored cardholder data. AI models must not retain sensitive authentication data (SAD) post-authorization.

No, full cardholder data is stored Partially, but some unnecessary data is stored Yes, only the minimum necessary data is stored I don't know

Is cardholder data encrypted at rest within AI training datasets and model weights?

PCI DSS 3.4: Strong encryption (e.g., AES-256) is required for all stored CHD, including AI datasets.

No, there is no encryption We use weak encryption (outdated algorithm) Yes, we use AES-256 or stronger encryption I don't know

Is cardholder data encrypted in transit when the AI system communicates via APIs (using TLS 1.2+)?

PCI DSS 4.1: Strong cryptography (at least TLS 1.2) is required for transmitting CHD over public networks.

No, or we use an outdated protocol (e.g., TLS 1.1) Yes, we use TLS 1.2 Yes, we use the most secure TLS 1.3 I don't know

Do you use tokenization or format-preserving encryption (FPE) to prevent AI models from accessing original PANs?

Tokenization is a best practice for reducing PCI DSS scope. It allows AI models to work with tokens instead of raw card numbers.

No, we use original PANs Partially, tokenization is not comprehensive Yes, we use comprehensive tokenization or FPE I don't know

Do you have documented key management processes for the encryption keys used by the AI system (covering generation, rotation, revocation)?

PCI DSS 3.5 & 3.6: Cryptographic keys must be protected, and key rotation must be performed regularly (at least annually).

No formal key management process We have one, but keys are not rotated regularly Yes, documented with automated rotation and HSM protection I don't know

Access Control & Authentication

Restricting access to cardholder data in AI systems through role-based access control (RBAC) and strong authentication.

Do you enforce role-based access control (RBAC) to limit access to cardholder data based on the "need-to-know" principle?

PCI DSS 7.1: Access to cardholder data (CHD) must be restricted based on business need-to-know.

No, access is not restricted Yes, but it is not strictly enforced Yes, we have strict, need-to-know based RBAC I don't know

Is multi-factor authentication (MFA) mandatory for all users who access the AI system handling cardholder data (e.g., data scientists, ML engineers)?

PCI DSS 8.3: MFA is required for all access into the Cardholder Data Environment (CDE).

No, we only use password authentication Partially, it is mandatory only for administrators Yes, it is mandatory for all CDE access I don't know

If your AI is a customer-facing chatbot, are users authenticated before the bot displays transaction information or account status?

Chatbots must not display cardholder or payment data without proper authentication. Strong Customer Authentication (SCA) is required.

No authentication in the chatbot Yes, but authentication is weak (e.g., email only) Yes, we enforce Strong Customer Authentication (SCA) Not applicable, we do not have a customer-facing chatbot

Does every user have a unique ID to access the system, and are generic/shared accounts prohibited?

PCI DSS 8.1: To ensure accountability, all access must be tied to a unique identifier. Shared accounts (e.g., "team", "admin") are prohibited.

Yes, we use shared accounts Mostly unique, but some shared accounts exist No, all access is tied to a unique ID I don't know

Does the system automatically terminate inactive user sessions (after a maximum of 15 minutes of inactivity)?

PCI DSS 8.1.8: Automatic termination of inactive sessions (max. 15 minutes) is required for systems within the CDE.

No automatic session timeout Yes, but after more than 15 minutes Yes, after 15 minutes or less I don't know

AI-Powered Fraud Detection & Monitoring

AI-powered anomaly detection, real-time monitoring, and audit logging to identify suspicious activities.

Does the AI system use real-time anomaly detection to identify suspicious transactions or access patterns?

PCI DSS 11.4 requires tools to detect unauthorized access. AI-based fraud detection is a recognized best practice.

No anomaly detection We only use a rule-based (non-AI) system Yes, we use AI-powered, real-time detection I don't know

Do you log all access to cardholder data (CHD) and all model inferences, recording the user ID, timestamp, and action taken?

PCI DSS 10.2: All individual user access to cardholder data must be logged. AI inferences should also be auditable.

No audit logging Logging is partial (missing fields) Yes, logging is comprehensive (user, time, action) I don't know

Are audit logs retained for at least one year, and do you have an automated alerting system for suspicious events?

PCI DSS 10.7: Logs must be retained for at least one year, with three months immediately available online. Automated alerts enable rapid response.

We do not retain logs For less than 1 year, or no alerting Yes, for 1+ years with automated alerts I don't know

Are audit logs protected from unauthorized modification (e.g., using write-once storage or cryptographic hashing)?

PCI DSS 10.5: Logs must be protected from alteration. This requires tamper-evident storage (e.g., WORM) or hash-based integrity checks.

No protection against modification Protected only by basic file permissions Yes, with tamper-evident storage or cryptographic hashing I don't know

Third-Party AI Services

Vendor due diligence, API security, and compliance verification for third-party AI providers.

Do all third-party AI providers (e.g., OpenAI, Google AI) that access cardholder data have a valid PCI DSS Attestation of Compliance (AOC)?

PCI DSS 12.8: A documented compliance review must be conducted annually for all service providers that store, process, or transmit CHD.

We do not verify their AOCs Only some of our vendors have an AOC Yes, all relevant vendors are PCI DSS compliant Not applicable, we do not use third-party AI with CHD access

Is access to third-party AI APIs restricted (e.g., using API key rotation, rate limiting, IP whitelisting)?

API keys must be rotated regularly, and rate limiting should be used to protect against brute-force attacks.

No access restrictions are in place Yes, but controls are partial (e.g., rate limit only) Yes, comprehensive controls are in place (key rotation, rate limit, IP whitelist) I don't know

Do you have written agreements (SLAs) with third-party AI providers that define their data security and incident notification responsibilities?

PCI DSS 12.8.2: A written agreement must be in place, acknowledging the service provider's responsibility for security and defining breach notification timeframes.

No such written agreement exists Yes, but it lacks specific PCI DSS security terms Yes, we have a PCI DSS-compliant agreement with all vendors I don't know

Do you know and document the geographic locations where third-party AI providers store cardholder data (data residency), and does this comply with PCI DSS?

The scope of PCI DSS includes remote locations. You must know which datacenters house AI models containing CHD.

We don't know where the data is stored We know, but it is not documented Yes, it is documented and stored in a PCI DSS compliant datacenter I don't know

Incident Response & Audit Readiness

Maintaining an incident response plan, breach notification processes, and readiness for PCI DSS audits.

Do you have a documented incident response plan for potential data breaches or compromises involving the AI system?

PCI DSS 12.10: An incident response plan is required, including defined roles, a communication plan, and business recovery steps.

No incident response plan We have a generic plan, but it is not AI-specific Yes, we have a documented, AI-specific plan I don't know

Do you have a defined process to notify payment brands (e.g., Visa, Mastercard) and your acquirer bank within 72 hours of a potential breach?

PCI DSS requires prompt breach notification. Separately, Visa and Mastercard also mandate 72-hour reporting.

No breach notification process A process exists, but it is not formally documented Yes, we have a documented 72-hour notification process I don't know

Do you maintain up-to-date documentation of the AI system's data flows, network topology, and all CDE components?

PCI DSS 12.1: Up-to-date network diagrams and data flow documentation are required for CDE scoping and audits.

No documentation It exists but is outdated (>6 months old) Yes, we have current and comprehensive documentation I don't know

Is the AI system subject to at least annual vulnerability scans and penetration testing, and are all critical findings remediated?

PCI DSS 11.3: Annual penetration testing is mandatory for all CDE systems, including public-facing AI APIs and model serving infrastructure.

No such testing is performed Testing is performed, but not annually Yes, annually, with remediation of findings I don't know

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Is your AI fraud detection system PCI DSS compliant?

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