Beyond the Pentest: Adjacent Activities That Uncover PCI DSS Risks

Introduction

A penetration test won’t always tell you if your environment is misconfigured. It won’t warn you about cryptographic keys exposed in forgotten buckets or if your team is unprepared for a ransomware attack. Yet these issues pose direct threats to PCI DSS compliance.

Many organizations treat penetration testing as a one-off black-box assessment, triggered solely by PCI DSS requirements. But the standard itself asks broader questions about security posture, readiness, and risk. To answer those questions meaningfully, you need more than just a pentest.

This article explores lesser-used but high-value technical assurance activities that help uncover the real PCI DSS risks a penetration test alone may miss.

PCI DSS and Penetration Testing: What’s Actually Required?

PCI DSS does not mandate a specific pentest methodology, nor does it limit validation to black-box assessments. Instead, it asks for assurance that segmentation is effective, cardholder data isn’t leaking, system components are hardened, and controls around cryptographic keys, access, and incident response actually work.

However, these questions often remain unanswered if the only activity conducted is a black-box pentest against a narrow attack surface. What’s typically missed:

• Weak or missing hardening of shared resources (related to Req 2.2)
• Sensitive data stored or exposed unintentionally (Req 3.1, 3.2, 3.4)
• Misconfigured segmentation (Req 1.3, 1.4)
• Poor key management (Req 3.5, 3.6)
• Unverified incident response (Req 12.10)

In addition to traditional penetration testing, Tenendo offers a range of complementary services – including tabletop exercises, partial code reviews, cloud configuration assessments, sensitive data discovery, and ransomware readiness simulations – to help organizations uncover hidden PCI DSS risks.

Let’s look at what complementary exercises can reveal.

The Hidden Heroes: Adjacent Assurance Activities

Here is the summary of those additional services that will allow you to cover additional risks and address PCI DSS requirements not covered by penetration testing.

	What it is	Why it matters	Example
Tabletop Exercises (Related article)	A scenario-based discussion simulating a security incident.	Validates incident response plans (PCI DSS 12.10.x), reveals communication gaps, and exposes unrealistic assumptions.	IR team didn’t know how to respond to PAN discovered in system logs.
Ransomware Readiness Simulation	Simulation of an attack lifecycle and recovery drill.	Assesses how fast systems can be restored and what alerts are triggered (Req 10.x, 12.10).	Actual restore time is 72 hours; management believed it was under one.
Partial Code Review	Scoped review of applications handling sensitive data, crypto, or authentication.	Helps validate secure coding (Req 6), especially for custom logic that stores or processes CHD.	Cryptographic keys or user credentials found hardcoded in front-end scripts.
Cloud Configuration Review / Segmentation Analysis (Related article)	IAM, network segmentation, and shared resources review across cloud accounts.	Ensures effective isolation and least privilege (Req 1.2, 1.3, 7.x).	Misconfigured IAM roles allow access to PCI-restricted S3 buckets.
Sensitive Data & Secrets Discovery	Scan of filesystems, object storage, logs, and code repos for PAN, CVV, private keys, credentials, and secrets.	Validates “no storage” claims, proves secure key handling.	Old payment batch files with plaintext PANs found in dev archive.

Why These Are Rarely Done (But Should Be)

• Over-reliance on pentest reports for all compliance validation
• Budgeting and planning does not account for broader assurance
• QSAs may not request these if not volunteered

These activities are not explicitly required by PCI DSS line-by-line but are often the only way to demonstrate effectiveness of controls.

How to Integrate These Activities into PCI DSS Strategy

• Pre-assessment Gap Phase: Identify risk areas to test more thoroughly. For example, consider partial code review of the most critical payment applications exposed to untrusted networks.
• Evidence Phase: Use storage scans to demonstrate data minimization and help validate the scope of PCI DSS applicability.
• Compensating Controls: Support them with proven controls from tabletop or code review.
• Roadmap Planning: Phase these in over a 12-month PCI cycle to reduce burden.

We’ll be publishing a series of articles that dive deeper into each of these complementary services – how  they work, what they uncover, and how they strengthen your PCI DSS posture – so stay tuned.

Need help organizing or conducting any of these activities? Contact us to help building a customized PCI DSS assurance strategy.