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No. Completing an external scan through an Approved Scanning Vendor (ASV) does not, by itself, make an organization PCI DSS compliant. It is evidence for one applicable control. PCI DSS also distinguishes quarterly external ASV scans from internal vulnerability scans, and requires findings to be addressed and rescanned as applicable.
External ASV scans and internal scans are different requirements
PCI DSS v4.0 treats external and internal vulnerability scanning separately. Both are recurring activities, but they differ in who may perform them and how findings are evaluated.
| Requirement | Who performs it | Frequency | How findings are handled |
|---|---|---|---|
| External scans, Requirement 11.3.2 | A PCI SSC-listed ASV, using the scan solution associated with that ASV. | At least once every three months. | Meet the ASV Program Guide’s passing-scan requirements, resolve vulnerabilities, and rescan as needed to verify remediation. |
| Internal scans, Requirement 11.3.1 | Qualified personnel with reasonable organizational independence from the systems scanned. An ASV or QSA is not required. | At least once every three months. | Resolve critical and high-risk vulnerabilities under the entity’s risk-ranking process and rescan to confirm resolution. |
The quarterly frequencies are specified in PCI DSS v4.0 materials, including PCI SSC’s SAQ C. Requirements can differ by PCI DSS version and validation path, so confirm which standard and assessment apply to your organization.
Who can perform internal scans?
Internal scans do not have to be performed by an ASV or a QSA. They must be performed by qualified personnel, with reasonable organizational independence between the tester and the systems being scanned. For example, an administrator should not be responsible for scanning the network they administer. A qualified internal employee or a specialist firm may perform the work. The scanning tool’s vulnerability information should be current.
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How to rank findings and remediate them
Use internal scan results as one input to the vulnerability identification and risk-ranking process under Requirement 6.3.1. Rank findings in light of their potential impact and your environment; the organization need not adopt an external severity rating without evaluation.
- Critical and high-risk findings: Resolve them as required by the applicable scanning and risk-management requirements.
- Lower-ranked findings: Address them according to risk documented through a targeted risk analysis. Addressing a finding may mean fixing it or applying an appropriate mitigation, such as a compensating control or disabling a vulnerable service.
- Critical security patches and updates: PCI DSS Requirement 6.3.3 says these must be resolved within one month of release. Other applicable patches follow entity-defined timeframes aligned with their assigned risk.
For external scans, use a PCI SSC-listed ASV and follow its applicable scan and rescan process. PCI SSC assesses ASVs through technical testing of scan performance and reporting, lists approved vendors, and requires annual recertification. Because approval status can change, check the current PCI SSC ASV listing rather than relying on an old vendor list.
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What counts as evidence across four quarters?
PCI SSC FAQ 1152 explains that evidence for the previous four quarters may consist of a collection of scan results rather than one clean report covering the entire environment. Taken together, the records must show that in-scope systems were scanned at least once every three months, findings were addressed, and rescans verified remediation where needed. A rescan may demonstrate that earlier findings were fixed even if new findings appear later.
Multiple reports do not cure incomplete scans, a missed scan period, or findings that remain unaddressed. For external scans, FAQ 1152 discusses a passing scan in the context of the ASV Program Guide and identifies a CVSS score of 4.0 or greater as a failure threshold. That threshold belongs to the ASV scanning context; it is not a substitute for checking current program requirements. Internal scan findings are handled under Requirement 11.3.1.
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- What You Get: Anker USB-C Hub (7-in-1), welcome guide, 18-month warranty, and our friendly customer service.
Does SAQ A require ASV scans if payment processing is outsourced?
It can. PCI SSC FAQ 1604 says PCI DSS v4.x SAQ A requires ASV external scans for specified merchant e-commerce webpages even when payment processing is fully outsourced. The examples are a merchant page that redirects customers to a compliant third party and a page that embeds the third party’s payment page or form. The scan addresses compromise risk to the merchant webpage and its connection to the third-party payment process. Outsourcing does not remove the merchant’s responsibility for requirements that apply to it under SAQ A.
What if a quarterly scan was missed?
A scan performed later cannot be backdated or create evidence that the scan took place during a missed interval. PCI SSC says periodic activities cannot be performed retroactively, and a compensating control cannot replace the required scan frequency. An assessor considers corrective actions and subsequent performance under the applicable assessment practices; a later scan does not erase the missed period.
Rank #4
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What an ASV report does—and does not—prove
An ASV report documents scan results and supports evidence for the external scanning requirement. It does not attest that other PCI DSS requirements have been assessed or met. As PCI SSC puts it in FAQ 1234, “The ASV will produce a scan report that details the results of the vulnerability scan — this scan report is not an indication that any other PCI DSS requirements have been reviewed or are in place.” Acquirers, payment brands, or other entities that accept compliance reports may have additional reporting expectations, so check with the relevant party.
Quick Recap
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- What You Get: Anker 332 USB-C Hub (5-in-1), welcome guide, our worry-free 18-month warranty, and friendly customer service.
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