How StackHawk Helps You Achieve AppSec Requirements for PCI DSS v4.0.1 Compliance

PCI DSS v4.0.1 is now the active standard for organizations handling cardholder data. v4.0 retired on December 31, 2024, and all new 4.0 requirements became mandatory on March 31, 2025. If your team ships code that touches payment data, the compliance landscape fundamentally changed.

PCI DSS v4.0.1 moves from periodic compliance checks to continuous, proactive security throughout the development lifecycle. Application security, API testing, and pre-production vulnerability detection are now explicit requirements. And if you’re still relying on annual penetration tests and quarterly scans, you’re already behind.

StackHawk’s shift-left DAST approach addresses many of these requirements by finding vulnerabilities before production, where they’re cheapest to fix and can’t cause compliance violations. Here’s what we help with:

Compliance Area	PCI DSS v4.0.1 Requirements
Pre-production vulnerability detection	6.2.3, 6.2.4, 11.3, 11.4.2
Complete software and API inventory	6.3.2, 12.5.1
Change tracking and validation	6.5.1, 6.5.2, 11.4.2, 12.10.5
30-day critical vulnerability remediation	6.3, 6.3.1, 6.3.3, 12.3.1
Layered security integration	6.2.3, 6.3.2

PCI DSS v4.0.1: What’s Changed for AppSec Teams

The transition from PCI DSS v3.2.1 to v4.0.1 eliminates the annual audit mindset. Compliance is now continuous and ongoing. The scope has expanded to explicitly include APIs across all protocols: REST, GraphQL, gRPC, and SOAP. If you’ve been treating API security as a subset of web application security, that assumption is now officially outdated.

Pre-production security testing is now mandatory, not recommended. The standard requires formal vulnerability management processes with defined timelines. Developer training must be relevant to the actual languages and tools your team uses.

Version 4.0.1 clarifies some of the v4.0 language (particularly around the 30-day remediation requirement for critical vulnerabilities), but it doesn’t soften the fundamental shift: security must be proactive, not reactive.

Key PCI DSS Requirements Impacting AppSec Teams

Four requirement sections directly affect how you build and test software.

Requirement 6: Develop and Maintain Secure Systems and Software is the big one. It mandates pre-production code review, vulnerability detection before release, and the critical 30-day remediation timeline for critical vulnerabilities. If you’re still finding critical issues in production, you’re already failing this requirement.

Requirement 8.6.2: Prevent Hardcoded Secrets explicitly prohibits hardcoded application and system account credentials in code. This goes beyond committing AWS keys to GitHub, and includes any authentication credentials embedded in application code.

Requirement 11: Test Security of Systems and Networks Regularly requires internal vulnerability scans at least quarterly and penetration testing after significant changes. “At least quarterly” is the floor, not the target. Modern development velocity demands continuous testing.

Requirement 12: Support Information Security with Organizational Policies and Programs covers the governance side: documented processes, annual technology reviews, security training, and audit trails proving you’re actually doing what you say you’re doing.

What AppSec Teams Must Demonstrate

PCI DSS v4.0.1 requires evidence. Here’s what auditors will look for:

A continuous inventory of custom software, APIs, and third-party components. Not a spreadsheet from last quarter. Not architectural diagrams from six months ago. A real-time, accurate inventory of what’s actually running in your environment.

Pre-production vulnerability detection and code review prior to every release. You need proof that security testing happens before code reaches production, not just that you have security tools installed somewhere.

Documented processes for addressing critical vulnerabilities within 30 days of patch availability. This applies specifically to critical vulnerabilities. v4.0.1 clarifies this point. High, medium, and low severity vulnerabilities require organization-defined, risk-based remediation timelines that you must document and follow.

Relevant, role-specific security training for developers. If your Python developers are taking training on Java vulnerabilities, that doesn’t count. Training must match the actual technologies and frameworks your team uses.

Audit trails proving compliance activities happen consistently, not just before audits. Pipeline logs, scan results, remediation timelines, and change documentation all need to be complete and accessible.

StackHawk’s Approach to PCI DSS v4.0.1 Compliance

1. Identify and Test Vulnerabilities Before Production Release

PCI DSS Requirements: 6.2.3, 6.2.4, 11.3, 11.4.2

The Challenge:

Code must be reviewed for vulnerabilities prior to production release, but traditional DAST tools create bottlenecks. Production scanning is too late. If you’re finding critical vulnerabilities in production, you’re already out of compliance. Legacy DAST tools that take hours to complete can’t keep pace with daily or multiple-daily deployments. Penetration testing must occur after significant changes, but manual processes don’t scale to modern development velocity. The quarterly internal scan requirement is a baseline, not best practice. Waiting three months between security validations leaves massive exposure windows.

How StackHawk Helps:

CI/CD-native testing in pre-production means scans run directly in your pipeline in minutes, not hours. You get immediate feedback before code can reach production. No separate security environment. No waiting for the security team to find time to test. Security validation happens at the same pace as your builds.

Runtime vulnerability detection tests live applications in pre-production environments to find exploitable issues: OWASP Top 10 vulnerabilities, business logic flaws, authorization bypasses, and API-specific vulnerabilities. We test actual running code, not theoretical attack surfaces.

Automated testing on every commit ensures continuous vulnerability detection throughout the development lifecycle. This exceeds the quarterly minimum requirement by orders of magnitude. Every code change gets security validation automatically.

Deterministic, reproducible testing through configuration-as-code ensures consistent scanning across all builds with repeatable, auditable results. The same test runs the same way every time, providing reliable compliance evidence.

Comprehensive API protocol support covers REST, GraphQL, gRPC, and SOAP endpoints, all protocols now explicitly included in PCI DSS scope. If you’re building it, we can test it.

Evidence for Compliance:

• Pipeline test results showing pre-production vulnerability detection and code review validation
• Scan completion times demonstrating ability to test at development velocity without blocking releases
• Automated quality gates that prevent critical vulnerabilities from being deployed to production
• Historical scan records proving continuous testing that exceeds quarterly requirements
• Documentation of testing performed after significant infrastructure or application changes

2. Maintain Complete Software and API Inventory

PCI DSS Requirements: 6.3.2, 12.5.1

The Challenge:

You must maintain an inventory of all bespoke and custom software including third-party components. Shadow APIs and undocumented endpoints create blind spots in security coverage. If you don’t know an API exists, you can’t secure it. Manual inventory processes can’t keep pace with AI-accelerated development where code ships multiple times daily. Annual technology reviews require up-to-date documentation of all software in use, but that documentation is outdated the moment your next deployment completes.

How StackHawk Helps:

AI-powered API discovery from source code automatically identifies all APIs—REST, GraphQL, gRPC, and SOAP endpoints—by analyzing your repositories. No manual documentation overhead. No hoping developers remember to update the architecture diagrams.

Shadow API detection discovers undocumented APIs, internal microservice endpoints, and deprecated-but-still-live APIs that wouldn’t appear in architectural documentation. We find the APIs nobody remembers creating and everyone forgot to shut down.

Continuous attack surface mapping maintains up-to-date inventory as code changes, catching new APIs the moment they’re created and committed. Your inventory updates automatically, not quarterly.

Automatic OpenAPI spec generation creates and continuously updates specifications from source code, enabling comprehensive testing coverage without developers maintaining documentation manually. The source code is the source of truth.

Evidence for Compliance:

• Comprehensive application and API inventory dashboard showing all custom software
• Source code-driven discovery methodology documentation
• Regular inventory updates demonstrating continuous monitoring (not just annual reviews)
• Mapping of inventory to PCI DSS scope showing which systems handle cardholder data

3. Track and Respond to Significant Changes

PCI DSS Requirements: 6.5.1, 6.5.2, 11.4.2, 12.10.5

The Challenge:

All changes to production systems must follow established procedures including security impact documentation. Teams must verify that security controls remain in place after “significant changes.” But determining what constitutes a “significant change” requires understanding application context and business impact. Penetration testing is required after any significant infrastructure or application upgrade, but manual change tracking doesn’t scale with multiple daily deployments. Security incident response plans must include monitoring and responding to change-detection mechanisms, which means you need automated systems, not spreadsheets.

How StackHawk Helps:

Automated testing on every code change means every commit triggers security scans. Changes are validated before deployment with no manual triggering required. You don’t have to decide what’s “significant” because everything gets tested.

Integration with development workflows runs tests automatically as part of pull requests and CI/CD pipelines, providing security impact documentation for every change. The audit trail is built into your existing workflow.

Quality gates and policies let you configure automated responses based on finding severity. Block deployments with critical issues. Require security team review for significant changes. Enforce your security standards programmatically.

Audit trail and documentation through pipeline logs provide complete evidence of testing performed for every release, including what was tested, when, and what was found. Every deployment has a security record.

Continuous validation vs. periodic testing exceeds minimum penetration testing requirements by providing ongoing security validation of every change. You’re not testing after significant changes, you’re testing through every change.

Change detection built into workflow means StackHawk inherently monitors for significant changes that introduce new vulnerabilities by testing continuously.

Evidence for Compliance:

• Pipeline logs showing security testing performed on each deployment
• Quality gate configurations demonstrating automated enforcement of security standards
• Change history with associated test results showing security impact of changes
• Documentation proving security testing occurs after significant changes
• Failure/rollback procedures demonstrated through blocked deployments

4. Prioritize and Remediate Critical Vulnerabilities Within 30 Days

PCI DSS Requirements: 6.3, 6.3.1, 6.3.3, 12.3.1

The Challenge:

Critical vulnerabilities must be resolved within 30 days of patch or update release. v4.0.1 clarifies that this 30-day requirement applies specifically to critical vulnerabilities, not high-severity. High, medium, and low vulnerabilities require risk-based remediation timelines determined by your organization. Vulnerabilities must be assigned risk rankings based on industry best practices and potential impact.

The problem is teams need to distinguish between vulnerabilities that are genuinely critical versus those that appear severe but have limited exploitability. Manual triage processes create delays that can cause you to miss the 30-day deadline. A scanner that cries wolf about theoretical vulnerabilities wastes remediation time on issues that don’t matter while real critical vulnerabilities age past the deadline.

How StackHawk Helps:

Runtime validation eliminates false positives by testing against live applications with full application context. We prove actual exploitability rather than generating theoretical alerts. If we report a critical SQL injection vulnerability, you can trust it’s actually exploitable, which means it actually needs to be fixed within 30 days.

Clear severity classification aligns findings with industry standards (CVSS, OWASP risk ratings), making it easier to identify truly critical vulnerabilities requiring 30-day remediation versus high, medium, or low severity issues with organization-defined timelines.

Contextual risk assessment through testing in pre-production with real application behavior helps teams understand actual impact, supporting accurate risk ranking decisions. You’re seeing exploitability demonstrated.

Developer-friendly findings include code location, vulnerability explanation, exploit demonstration, and fix guidance to accelerate remediation. Developers get everything they need to fix the issue without security team hand-holding.

Integration with developer tools delivers findings directly to Jira, Slack, and pull requests where developers already work, reducing time between discovery and fix. No context-switching or waiting for reports.

Fix verification and validation through re-scan capabilities prove vulnerabilities are resolved before closing tickets, providing audit evidence that issues were actually fixed, not just marked as resolved.

Configurable SLAs let you set policies aligned with 30-day critical remediation requirements and organization-defined timelines for other severity levels.

Evidence for Compliance:

• Vulnerability severity classifications clearly distinguishing critical from high/medium/low based on industry standards
• Mean time to remediation (MTTR) metrics demonstrating 30-day compliance for critical vulnerabilities
• Documented remediation workflows and timelines for different severity levels
• Risk-based analysis supporting remediation timeframes for high, medium, and low vulnerabilities
• Closed-loop verification showing vulnerabilities were actually fixed, not just marked as resolved
• Historical trending showing consistent adherence to remediation SLAs

Building a Complete PCI DSS Compliance Strategy

PCI DSS Requirements: 6.2.3, 6.3.2, 8.6.2

The Challenge:

PCI DSS v4.0.1 covers the entire software development lifecycle, not just runtime testing. Organizations need comprehensive security coverage: source code analysis, dependency management, and secrets detection. No single tool addresses every AppSec requirement. You need integrated solutions that work together without creating tool sprawl or workflow friction.

StackHawk’s Role in Your Layered Security Approach:

SAST + DAST for complete vulnerability coverage (Requirement 6.2.3)

Static Application Security Testing analyzes source code to find potential vulnerabilities during development. StackHawk’s runtime DAST validates whether SAST findings are actually exploitable. SAST and DAST correlation reduces noise and busy work, while also providing defense-in-depth: SAST catches issues in code, StackHawk proves they’re real in running applications. This layered approach addresses Requirement 6.2.3’s code review mandates from multiple angles.

StackHawk partners with SAST providers including Semgrep and Endor Labs.

SCA for complete dependency inventory (Requirement 6.3.2)

Software Composition Analysis maintains comprehensive inventory of third-party components and identifies known vulnerabilities in open source dependencies. StackHawk tests whether vulnerable dependencies are actually exploitable in your application context. SCA identifies component risks; StackHawk validates real-world impact.

StackHawk partners with SCA providers including Semgrep and Endor Labs.

Secrets detection for hardcoded credential prevention (Requirement 8.6.2)

Dedicated secrets scanning detects hardcoded credentials in source code before deployment. StackHawk complements this by finding exposed secrets in API responses and runtime behavior. You get comprehensive coverage: static secrets detection plus runtime exposure validation.

StackHawk partners with secrets detection providers including Semgrep and Endor Labs.

ASPM for centralized compliance evidence

Application Security Posture Management tools aggregate findings from all security tools. StackHawk feeds runtime testing results into centralized compliance dashboards, providing a unified view of all AppSec findings, policy enforcement, and audit trails in one place.

StackHawk integrates with ASPM platforms including Jit (active integration) and Wiz (integration in development).

Evidence for Compliance:

• Integration documentation showing layered security approach across SDLC
• Unified compliance dashboards demonstrating comprehensive coverage
• Partner tool outputs complementing StackHawk’s runtime validation
• Complete audit trail spanning multiple security controls and requirements

Bottom line: PCI DSS v4.0.1 requires comprehensive AppSec coverage across the entire development lifecycle. StackHawk excels at pre-production runtime testing, API discovery, and continuous validation. Partner integrations fill gaps for source code analysis, dependency management, secrets detection, and centralized posture management. The combined approach provides complete compliance coverage while maintaining development velocity.

Getting Started with StackHawk to Support PCI DSS Compliance

PCI DSS v4.0.1 represents a fundamental shift toward continuous, proactive application security, moving from periodic audits to ongoing compliance validation. The annual penetration test model is dead. Quarterly scans are the bare minimum. Continuous security testing is now the baseline.

StackHawk’s shift-left DAST approach directly addresses the new requirements by testing APIs and applications in CI/CD before production, maintaining complete software inventories through source code analysis, and providing the audit trails needed to prove compliance. We’ve built security directly into the development process.

By integrating runtime security testing into developer workflows with automated, minute-long scans, organizations can meet certain PCI DSS requirements while maintaining—or even accelerating—development velocity. Security and speed are no longer trade-offs. StackHawk enables both by catching vulnerabilities when they’re cheapest to fix and providing developers with actionable, trustworthy findings.

Modernize your AppSec program for continuous compliance. Schedule a demo to see how StackHawk can help support your PCI DSS v4.0.1 compliance needs without slowing down development.