Managing scripts on payment pages has become a key focus area under PCI DSS, particularly as third-party and dynamically loaded scripts introduce new risk. As attacks targeting client-side scripts continue to increase and PCI DSS v4.x places greater emphasis on ongoing monitoring, organizations are expected to demonstrate not only visibility into payment page scripts, but also effective controls to detect unauthorized changes.
This FAQ addresses common questions related to script inventory, integrity validation, and detection mechanisms for payment pages in compliance with PCI DSS requirements. These insights are designed to help teams understand what is required and how to implement these controls to maintain strong security practices in a practical, defensible way.
1. Scope of Scripts in Payment Pages
Q: For payment pages where functionality is added via iFrames, can the focus be limited to the content/headers inside the iFrame?
A: No, you cannot limit the scope to just the iFrame. Per PCI DSS 4.0.1, any scripts in the underlying page where the iFrame is embedded are also in scope. This includes ensuring that these scripts are authorized, inventoried, and validated for integrity, as they can affect the security of the payment process.
2. Script Inventory Management
Q: Can a repository-based system serve as the inventory of scripts, as long as it includes technical justifications?
A: Yes, a repository-based system can act as the inventory of scripts if it includes technical justifications. However, controls must be implemented to ensure that only approved scripts from the repository are deployed to production. Change management and detection mechanisms should reconcile production scripts with the approved inventory. While hash-based validation is common, alternative controls in your system may suffice if appropriately implemented.
Q: Does requiring multiple reviewers for changes fulfill the "script is authorized" requirement?
A: Yes, requiring multiple reviewers for changes can serve as evidence of script authorization, provided there is a clear audit trail of the approval process. It is critical to ensure that scripts reviewed and approved match those deployed in production.
Q: Can we rely on sampling to validate script inventory instead of listing all production scripts?
A: No, PCI DSS typically requires full validation that all scripts on a production page are accounted for in the inventory, so sampling may not suffice. It’s critical to ensure that every script is tracked and reconciled against the approved inventory.
3. Integrity Validation Requirements
Q: Can a Content Security Policy (CSP) cover the script integrity validation requirement?
A: CSP alone is insufficient for meeting the script integrity validation requirement. While CSP restricts which scripts can execute, it does not validate their integrity. CSP should be used in conjunction with tools like Subresource Integrity (SRI) or third-party solutions (e.g., Akamai, JScrambler, SourceDefense) to ensure comprehensive script management and validation.
4. Tamper Detection Mechanisms
Q: Can detection mechanisms run in a testing environment if they simulate production conditions?
A: Yes, detection mechanisms can operate in a testing environment as long as they accurately simulate production conditions. The QSA must confirm that the test environment mirrors production to an extent that ensures the effectiveness of the detection mechanisms.
Q: What type of evidence is required when using integrity mechanisms like Web Binary Transparency?
A: Evidence should include logs or reports from the mechanism demonstrating how it verifies the integrity of scripts deployed in production. This may involve hashing results, proof of reconciliation between approved and deployed scripts, and an audit trail of integrity checks.
5. Incident Response and Trigger Management
Q: Can we triage tamper-detection triggers without activating the Incident Response Plan (IRP) for every alert?
A: Yes, initial triggers can be triaged by on-call staff. Only confirmed incidents should escalate to the IRP. Documenting false positives and refining the system over time will help ensure an effective and compliant process.
6. Determining applicability for requirements 6.4.3 and 11.6.1
Q: If an Iframe is not externally available for E-Commerce transactions and no consumers are using the payment page offered, are the above requirements not applicable?
A: The short answer is yes; they should be marked as not applicable. There are two main reasons for this. The DSS defines a consumer as “an individual cardholder purchasing goods, services.” In this case, the payment page is only used by employees in a call center to enter payment information. This is clearly not a consumer per the DSS. The second reason is that this payment page is not accessible on the internet and is completely used for internal payment processing and there is no E-Commerce website.
Moving Forward with PCI DSS Compliance
As PCI DSS continues to place greater emphasis on client-side security, organizations should view script inventory, integrity validation, and tamper detection as ongoing operational disciplines. Clear scoping, well-documented authorization processes, and effective monitoring mechanisms are essential to demonstrating that payment page scripts are both controlled and protected.
By implementing controls that are consistent, auditable, and relevant to how scripts are actually deployed and monitored in production, teams can reduce risk while positioning themselves for a smoother PCI DSS assessment. Taking a proactive approach to these requirements strengthens overall payment page security and supports a strong compliance posture.
If you still have questions about PCI DSS validation, contact us today to learn more. In the meantime, discover additional insights in these helpful resources:
- PCI DSS v4.x MFA Requirements Explained: Passkeys, Phishing Resistance, and Compliance
- Modernizing PCI DSS Authentication Using Phishing-Resistant Methods
- What you Need to Know About the PCI DSS Customized Approach
About the Authors
Bill Soverns is a Senior Associate with Schellman based in Dallas, Texas. Prior to joining Schellman, Inc in 2021, Bill worked as the CISO, for a nationwide Contact Center specializing in Information Security oversight and all compliance initiatives including PCI, SOC1, SOC2, HITRUST, and HIPAA. Bill also led and supported various other projects including enterprise wide implementations of various antivirus, FIM, SIEM solutions. Bill has over 30 years of experience comprised of serving clients in various industries, including Contact Centers, Payment processing switches, and financial institutions. Bill is now focused primarily on PCI-DSS assessments for organizations across various industries.
Adam Bush is a Managing Director at Schellman and is responsible for the delivery and growth of Schellman’s Payment and Identity Security services portfolio. Since joining in 2012, his primary focus has been maturing and delivering PCI services to complement Schellman’s strong foundation in the service provider and merchant space.
Adam brings more than 20 years’ experience in technology focused services. Prior to Schellman, he has held a number of positions in the departments of Network Support, IT Finance, Project Management, IT Audit, and Security Consulting Services. In addition to his great depth of experience leading merchant and service provider PCI engagements across multiple industry verticals, Adam also has experience leading FFIEC Audit engagements in the financial services industry, as well as conducting network penetration tests, vulnerability assessments and social engineering.
Adam holds a Bachelor of Science degree in Business Administration with a concentration in Management Information Systems as well as a Master’s degree in Accounting and Information Management from the University of Texas at Dallas. He is a member of the Global Executive Assessor Roundtable, and maintains multiple industry certifications including PCI QSA, CISSP and CISA.