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Appendix A3: Designated Entities Supplemental Validation (DESV)

Overview

This Appendix applies only to entities designated by a payment brand(s) or acquirer as requiring additional validation of existing PCI DSS requirements. An entity is required to undergo an assessment according to this Appendix ONLY if instructed to do so by an acquirer or a payment brand. Examples of entities that this Appendix could apply to include:

  • Those storing, processing, and/or transmitting large volumes of account data,
  • Those providing aggregation points for account data, or
  • Those that have suffered significant or repeated breaches of account data.

Additionally, other PCI standards may reference completion of this Appendix.

These supplemental validation steps are intended to provide greater assurance that PCI DSS controls are maintained effectively and on a continuous basis through validation of business-as-usual (BAU) processes and increased validation and scoping consideration.

Note: Some PCI DSS requirements in this Appendix have defined timeframes (for example, an activity that is to be performed at least once every three months or six months). For an initial assessment to such requirements, it is not required that an activity has been performed for every such timeframe during the previous year, if the assessor verifies:

  • The activity was performed in accordance with the applicable requirement within the most recent timeframe (for example, the most recent three-month or six-month period), and
  • The entity has documented policies and procedures for continuing to perform the activity within the defined timeframe.

For subsequent years after the initial assessment, an activity must have been performed within each required timeframe. For example, an activity required at least every three months must have been performed at least four times during the previous year at an interval that does not exceed 90-92 days. Refer to section 7 Descriptions of Timeframes Used in PCI DSS Requirements for additional guidance about initial assessments.

Not all requirements in PCI DSS apply to all entities that may undergo a PCI DSS assessment. It is for this reason that some PCI DSS Requirements are duplicated in this appendix. Any questions about this appendix should be addressed to acquirers or payment brands.

Sections

A3. Designated Entities Supplemental Validation (DESV)

Implement enhanced controls for high-risk entities requiring additional validation of PCI DSS compliance.

https://WithPCI.com
20
Sub-requirements
37
Test Points
Moderate (2.7)
Implementation Difficulty

Control Types

Governance
Process (16)
Technical
Documentation
Training

Key Risks

Inadequate executive oversight
Compliance program gaps
Third-party risk management failures
Insufficient resource allocation

Frequently Asked Questions

What triggers DESV requirements for an organization?

1) Processing >20M transactions/year, 2) History of breaches, 3) Complex hybrid cloud environments, 4) Designation by acquiring bank. Applies to all service providers meeting criteria.

How does DESV differ from standard PCI validation?

Requires: 1) Quarterly board-level reporting, 2) Enhanced third-party monitoring, 3) Cryptographic evidence chain, 4) 90-day log retention, 5) NIST-aligned risk assessments.

What's required for executive compliance oversight?

1) CISO reports directly to board, 2) Quarterly security posture reviews, 3) Approved risk acceptance authority, 4) Personal liability for false attestations. Document in corporate bylaws.

How are compliance resources validated under DESV?

Must demonstrate: 1) Dedicated security FTE allocation, 2) Automated compliance tooling budget, 3) Third-party audit contracts. Track via Jira Service Management dashboards.

What evidence shows continuous compliance monitoring?

1) Real-time SIEM dashboards, 2) Automated policy enforcement via Terraform, 3) Weekly vulnerability trend reports, 4) Blockchain-attested change logs.

Common QSA Questions

Show board meeting minutes approving compliance budget

2025-Q1 minutes document: 1) $2.1M security budget approval, 2) Risk appetite statement update, 3) CISO performance metrics. Signed with Qualified Electronic Signatures.

Demonstrate third-party risk scoring methodology

We use BitSight with: 1) PCI DSS-specific rating criteria, 2) Automated SLA tracking, 3) 45-day remediation deadlines. Dashboard shows 98% vendors compliant.

Provide cryptographic chain-of-custody for audit evidence

All artifacts stored in AWS S3 with: 1) Object Lock governance mode, 2) SHA-384 hashes in QLDB, 3) Sigstore signatures. Last audit validated 100% evidence integrity.

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