Category: PCI DSS Compliance

Customized Approach

Simply put

The Customized Approach is one of two ways organizations can meet and validate PCI DSS requirements, introduced in PCI DSS v4.x as an alternative to the traditional Defined Approach. Instead of following the specific control steps written into a requirement, an organization designs its own security controls to achieve the goal that the requirement is meant to accomplish. This gives organizations flexibility to use tailored or newer security solutions, provided they can demonstrate the intended objective is met.

Formal definition

The Customized Approach is a validation and implementation path defined in PCI DSS v4.x that allows an entity to meet a requirement's stated Customized Approach Objective through controls of its own design, rather than by satisfying the prescriptive testing procedures of the Defined Approach. It differs from the Defined Approach, which follows the requirement as written, and from compensating controls, which are a separate mechanism within the Defined Approach used when an entity cannot meet a requirement as stated for a legitimate technical or documented business constraint. Under the Customized Approach, the entity is responsible for designing, documenting, implementing, and maintaining evidence that its controls achieve the requirement's objective, and this evidence is subject to assessment; specific requirement numbering, wording, and the exact objectives should be confirmed against the current published version of PCI DSS, as these differ between versions. The Customized Approach is a PCI DSS construct and should not be conflated with controls governed by other PCI standards such as PA-DSS, the PCI Software Security Framework, PCI PIN, PCI P2PE, or PCI 3DS.

Why it matters

The Customized Approach represents a significant shift in how PCI DSS accommodates modern security architectures. Prior to PCI DSS v4.x, organizations that could not follow a requirement exactly as written had limited flexibility, relying primarily on compensating controls within the Defined Approach. The Customized Approach acknowledges that mature security programs may employ tailored or newer technologies that achieve a requirement's intended security outcome without matching the prescriptive testing procedures written into the standard. This matters most to organizations with sophisticated, well-documented security operations that want to align validation with the controls they have actually engineered rather than retrofitting to prescriptive steps.

The trade-off is that the Customized Approach places substantially more responsibility on the entity. Instead of following a defined checklist, the organization must design controls that meet the requirement's stated Customized Approach Objective, and it must produce and maintain evidence that those controls actually achieve that objective. That evidence is subject to assessment, which typically demands greater rigor in documentation, targeted risk analysis, and ongoing maintenance than the Defined Approach. Organizations that underestimate this burden may find the Customized Approach more resource-intensive than expected.

Because the Customized Approach is a PCI DSS construct tied to specific requirement objectives, and because requirement numbering, wording, and the exact objectives differ between versions of the standard, organizations should confirm details against the current published version of PCI DSS rather than assuming fixed language. It should also not be confused with controls governed by other PCI standards such as PA-DSS, the PCI Software Security Framework, PCI PIN, PCI P2PE, or PCI 3DS.

Who it's relevant to

Compliance officers and PCI DSS program owners

Those responsible for validation strategy need to decide, requirement by requirement, whether the Defined Approach or Customized Approach best fits their organization. They must weigh the flexibility of tailored controls against the added documentation, evidence, and maintenance obligations the Customized Approach imposes, and confirm objectives against the current published version of the standard.

Security engineers and architects

Teams that build and operate tailored or newer security solutions can use the Customized Approach to align validation with the controls they have actually engineered, provided they can design controls that meet the stated Customized Approach Objective and produce evidence that those controls achieve it.

Qualified Security Assessors and internal assessors

Assessors must evaluate whether an entity's self-designed controls achieve the requirement's Customized Approach Objective, reviewing the entity's documentation and evidence rather than checking against the prescriptive testing procedures used in the Defined Approach.

Organizations with mature, well-documented security programs

Entities with the operational maturity to design, document, implement, and maintain evidence for custom controls are best positioned to benefit, since the Customized Approach shifts the responsibility for demonstrating that objectives are met onto the entity itself.

Inside Customized Approach

Customized Approach objective

The Customized Approach focuses on meeting the stated security objective of a PCI DSS requirement rather than following the prescriptive controls of the Defined Approach. Each applicable requirement in the current standard includes a Customized Approach Objective that the entity's alternative controls must satisfy.

Entity-designed controls

Under this approach, the entity designs and implements its own controls to meet the requirement's objective. This allows flexibility to use technologies or methods not described in the prescriptive requirement, provided they achieve the intended outcome.

Targeted Risk Analysis

A Customized Approach requires the entity to perform and document a targeted risk analysis for each requirement addressed this way, supporting how the designed controls meet the objective. Confirm the specific documentation and analysis expectations against the current published PCI DSS version, as wording and structure differ between versions.

Controls matrix and evidence

The entity typically documents the mapping between its custom controls and the requirement objective, along with evidence that the controls are effective. This supports assessor evaluation.

Assessor validation

A qualified assessor must derive and perform testing procedures to validate that the customized controls meet the objective, since standard testing procedures for the Defined Approach may not directly apply. Validation depends on the specific implementation rather than on the label alone.

Relationship to the Defined Approach

The Customized Approach is one of two ways to meet a requirement in the current PCI DSS; the other is the Defined Approach, which follows the prescriptive requirements and standard testing procedures. It is distinct from the compensating controls mechanism used in earlier contexts.

Common questions

Answers to the questions practitioners most commonly ask about Customized Approach.

Does the customized approach mean an entity can skip a PCI DSS requirement or its security objective?

No. The customized approach does not remove or waive any requirement's security objective. It provides flexibility in how an entity meets the objective, allowing controls other than the defined ones stated in the standard, but the underlying objective must still be met and validated. The customized approach addresses the method of meeting the objective, not whether the objective applies.

Is the customized approach the same as a compensating control?

No. These are distinct concepts and should not be conflated. Compensating controls address situations where an entity cannot meet a defined requirement as stated and must justify an alternative, typically due to a documented constraint. The customized approach is a deliberate way to meet a requirement's stated security objective using controls the entity designs, rather than the defined controls. Confirm the specific definitions, expectations, and documentation for each against the current published PCI DSS, as wording and structure differ between versions.

What documentation is expected when an entity uses the customized approach?

The entity is generally expected to document how its implemented controls meet the stated security objective, including a controls matrix and a supporting risk analysis or targeted risk assessment for the approach. The assessor then designs and performs testing appropriate to those controls. Because required artifacts and their exact form depend on the version in effect, confirm the current documentation expectations against the published standard rather than assuming a fixed template.

Who is responsible for testing customized approach controls, the entity or the assessor?

Both have roles. The entity is responsible for designing, implementing, documenting, and maintaining the controls and for demonstrating that they meet the stated security objective. The assessor is responsible for reviewing that documentation, deriving and performing appropriate testing procedures for the entity's specific controls, and reaching a conclusion. The customized approach typically places greater analytical burden on both parties than the defined approach.

Can an entity use the customized approach for some requirements and the defined approach for others?

In general, the approach can be selected on a per-requirement basis, so an entity may meet some requirements using the defined approach and others using the customized approach. How this selection is recorded and reflected in the assessment output depends on the version and reporting templates in effect, so confirm the current rules and documentation mechanics against the published standard.

Is the customized approach appropriate for entities with limited security maturity?

It is generally better suited to entities with mature risk management and the ability to design, justify, and evidence controls against a stated security objective, because it shifts analytical and documentation responsibility onto the entity and its assessor. Entities without that maturity may find the defined approach more straightforward to implement and validate. This is a general consideration rather than a formal eligibility rule; confirm any applicability guidance against the current standard.

Common misconceptions

The Customized Approach is the same as a compensating control.

They are not the same. Compensating controls address a situation where an entity cannot meet a stated requirement as written and needs an alternative due to a legitimate constraint. The Customized Approach is a distinct method for meeting a requirement's objective through entity-designed controls, with its own targeted risk analysis and assessor-derived testing. Confirm the exact treatment of each in the current published PCI DSS version.

The Customized Approach lets an entity skip requirements or lower the security bar.

The Customized Approach still requires meeting the stated security objective of the requirement. It is intended to offer flexibility in how the objective is achieved, not to reduce the level of protection, and it typically involves more documentation, risk analysis, and assessor effort than the Defined Approach.

Choosing the Customized Approach automatically reduces PCI DSS scope.

The approach concerns how a requirement's objective is met, not scope reduction. Effects on scope depend on the actual controls implemented, the data flows involved, and validation, not on the choice of approach itself.

Best practices

Confirm which requirements you intend to address with the Customized Approach against the current published PCI DSS version, since requirement numbering, wording, and Customized Approach Objectives differ between versions.

Perform and document a targeted risk analysis for each requirement handled under the Customized Approach, clearly linking your designed controls to the requirement's stated objective.

Maintain a controls matrix that maps each custom control to the objective it satisfies, together with evidence of the control's effectiveness.

Engage a qualified assessor early so testing procedures can be derived and agreed for validating that customized controls meet the objective.

Do not treat the Customized Approach as a way to skip requirements or reduce the security bar; ensure controls demonstrably meet the intended outcome and plan for the additional documentation effort involved.

Distinguish the Customized Approach from compensating controls in your documentation, and verify how each is defined and permitted in the current standard rather than assuming they are interchangeable.