The PCI Security Standards Council (PCI SSC) released
version 2.0 of the PCI Secure Software Standard in January 2026, marking a
major revision from the previous v1.2.1. If your organization develops,
assesses, or relies on payment software, this update carries significant
implications. Here's a breakdown of what's changed and what you need to know.
A Major Revision - Not A Minor Update
First and foremost, the PCI SSC has emphasized that this is
a major revision. Unlike incremental updates, there is no definitive one-to-one
mapping between v1.2.1 and v2.0. Organizations should approach this as a
significant rethink of the standard's structure, language, and scope - not
simply an updated checklist.
Key Terminology Changes
One of the most immediately noticeable shifts is the
language used throughout the standard. The term "Payment Software"
has been removed entirely. In its place, the standard now revolves around the
concept of "Sensitive Assets." This broader framing better captures
the range of data, resources, and functionality that software must protect.
Several related glossary terms have also been updated:
- "Critical
Asset" is now "Sensitive Asset" (and has been rewritten)
- "Sensitive
Function" is now "Sensitive Functionality" (and has been
rewritten)
- "Sensitive
Data" and "Sensitive Resource" definitions have both been
revised
- A
new term, "Strong Authentication," has been introduced
The glossary itself has been moved in-house: v2.0 includes a
new Appendix A that supersedes the previously external SSF Glossary document,
making all defined terms available within the standard itself. Additionally,
"Control Objectives" have been renamed "Security
Objectives" throughout the document.
New Companion Document: Sensitive Asset Identification
A brand-new external companion document has been introduced
alongside v2.0 - the Sensitive Asset Identification document. This is not
optional reading: it is a mandatory companion to the standard and forms part of
its program. 
The document provides additional context and examples for
understanding Sensitive Assets, Sensitive Data, Sensitive Functionality, and
Sensitive Resources. For vendors working with EMVCo 3DS-related data, the
standard also relies on the PCI 3DS Data Matrix document.
Restructured Test Requirements And Methodology
All test requirements have been essentially rewritten in
v2.0. The new approach is structured around three core methods:
- Documentation
Review
- Static
Analysis
- Dynamic
Analysis
Additional new sections include Software Testing, Provision
of Source Code, Technical Constraints, and Technical FAQs - the last of which
mirrors language from existing PCI Technical FAQ documents.
Overhauled Core Requirements
The core section has been retitled "Core - All
Software" to emphasize that these requirements apply universally to all
software assessed under the standard. The eleven Security Objectives now cover:
- Security
Objective 1: Software Architecture, Composition, and Versioning -
including requirements for Bill of Materials (BOM), versioning practices,
and the use of wildcards.
- Security
Objective 2: Sensitive Asset Identification - relies on the new
companion document covers identifying Sensitive Data, Sensitive
Resources, Sensitive Functionality, and Sensitive Modes of Operation.
- Security
Objective 3: Sensitive Asset Storage and Retention
- Security
Objective 4: Sensitive Modes of Operation - applies only when a
Sensitive Mode of Operation is present introduces "Strong
Authentication."
- Security
Objective 5: Sensitive Asset Protection - including the software
design itself as a sensitive asset, and formalizing the concept of
"anomalous behavior."
- Security
Objective 6: Sensitive Asset Output - formalizes secure channel
requirements.
- Security
Objective 7: Random Numbers - covers both leveraging an external
RNG and implementing one within the software.
- Security
Objective 8: Key Management
- Security
Objective 9: Cryptography (a single encompassing requirement for
cases not covered elsewhere)
- Security
Objective 10: Threats and Vulnerabilities
- Security
Objective 11: Secure Deployment and Management - includes
implementation guidance and software versioning.
 
Changes To Modules : Modules are additional
requirements that apply on top of the Core - All Software section, based on
defined criteria.
- Module
A (Account Data Protection): Requirements have been revised to
focus specifically on PAN and SAD in relation to PCI DSS.
- Module
B (formerly Terminal Software Requirements, now POI Device Software): The
module has been retitled and its requirements refined and reduced. Several
requirements previously in Module B have been absorbed into the Core - All
Software section. SRED requirements have also been revised.
- Module
C (formerly Web Software Requirements, now Publicly-accessible Software): The
module has been retitled to better reflect its intent. Several
requirements from the old C.1 section have been moved to the Core section.
Requirements C.1.5 and C.1.6 have been removed, as they are now covered by
the PCI Secure SLC Standard.
- Module
D (NEW - Software Development Kits): This is an entirely new
module. v2.0 is now better suited to accommodate the assessment of SDKs,
including EMVCo 3DS SDKs. Module D introduces a new set of objectives and
requirements specifically for this category.
Structural And Administrative Changes
Several structural changes have been made to align v2.0 more
closely with the broader PCI Standards framework:
- A
new "Sensitive Assets" section has been added to the
introduction.
- The
"Stakeholder Roles and Responsibilities" section has been
removed from the standard and relocated to the PCI Secure Software Program
Guide.
- The
"Scope of Security Requirements" section has been removed
entirely.
- Related
Publications have been moved to a new Appendix B.
- A
new Appendix C covers Technical References.
- SLC-related
requirements have been removed from this standard, as they are now covered
under the PCI Secure SLC Standard.
- The
standard now relies on "Strong Cryptography" as the baseline for
cryptographic requirements, replacing the previous "Effective Key
Strength" framework.
What This Means For Your Organization
Whether you are a software vendor seeking or maintaining
certification, an assessor reviewing compliance, or a payment brand evaluating
software, v2.0 represents a meaningful shift. The expanded focus on Sensitive
Assets (rather than Payment Software alone) broadens the standard's
applicability. The introduction of Module D makes it relevant to SDK developers
for the first time. And the comprehensive rewrite of test requirements means
existing assessment processes will need to be revisited.
Organizations currently certified or in the process of
certification under v1.2.1 should review the full v2.0 standard and the new
Sensitive Asset Identification companion document to understand how
requirements map (or don't map) to their current implementations.
The PCI SSC has made clear that this version is designed to
be more structured, more broadly applicable, and better aligned with the
evolving software security landscape - including the growing role of SDKs,
third-party components, and complex software supply chains.
For the full standard and companion documents, visit the PCI
Security Standards Council website at PCIsecuritystandards.org.
Need Help Navigating PCI Secure Software Standard V2.0?
At QRC Assurance and Solutions, we understand that major
standard revisions can be complex to interpret and even more challenging to
implement. Whether you are a software vendor preparing for assessment under
v2.0, an organization reviewing your current certification status, or a
development team working through the new Sensitive Asset framework for the
first time - our team of qualified security experts is here to guide you every
step of the way.
Our services include:
- Gap
assessments against PCI Secure Software Standard v2.0
- Pre-assessment
readiness reviews
- Support
for Module D (SDK) assessments - new to v2.0
- Guidance
on the mandatory Sensitive Asset Identification companion document
- End-to-end
PCI SSF assessment and certification support
Don't let a major revision catch your organization off
guard. Get ahead of the changes with expert support from a team that lives and
breathes payment security compliance. Contact us today to schedule a
consultation or learn more about how QRC Assurance and Solutions can help you
achieve and maintain compliance with confidence.
Visit us at: www.qrcsolutionz.com | Email us at:
connect@qrcsolutionz.com
 

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