Restaurant PCI
compliance:
What to know
about PCI DSS 4.0

The United States is the largest fast-food consumer in the world, according to CEO World Magazine. And with over 200,000 quick service restaurants (QSRs) in the US, it’s estimated that about 37% (over 84 million adults) consume fast food every day. In 2022 the fast food industry was projected to have a market size of $331.41 billion. Research from PYMNTS indicates that 37% of QSR consumers use a debit card while 33% use a credit card. This sheer volume of credit and debit card payments indicates why the Payment Card Industry Data Security Standard (PCI DSS), or in this instance restaurant PCI compliance, is so important to help maintain trustworthiness with customers and to secure business operations.

Restaurant PCI compliance has received a major overhaul thanks to PCI DSS 4.0, the latest version of the set of compliance rules that apply to most businesses that process card payments and goes into effect 31 March 2024. The update, released in 2022, has important ramifications for the cybersecurity and compliance strategies of QSRs.

Keep reading for a breakdown of the most important changes to PCI compliance for restaurants that arise out of the PCI DSS 4.0 framework, along with tips on what QSRs can do to work towards compliance with the new requirements.

Before diving into the new policies on restaurant PCI compliance, let's define PCI DSS 4.0 and explain why it's important.

PCI DSS v4.0 is the latest major release of the Payment Card Industry Data Security Standard framework. PCI DSS is a set of guidelines and requirements designed to help secure credit and debit card payments. It is a framework that major payment card brands and credit card processing companies, such as Mastercard, Visa and Discover, require merchants, for example hotels, retail shops, restaurants, to follow as a prerequisite for accepting card payments. Its main purpose is to secure sensitive data during the payment process—data that is a major target for external and internal threat actors—given that it's easy to exploit for financial gain.

The PCI DSS v4.0 requirements were introduced in 2022, but they won't go fully into effect until March 2024, at which point the PCI DSS 3.2.1 requirements will finish phasing out.

As the first overhaul of the PCI DSS requirements since version 3.0 appeared in 2013, PCI DSS 4.0 introduces a number of new requirements designed to enhance the security of payment card processing. While none of these requirements were designed specifically or solely for the restaurant industry, several of them have important ramifications for the way restaurants handle cybersecurity.

Requirement 3.5.1 of PCI DSS 4.0 introduces a mandate requiring businesses to protect payment card data using disk-level or partition-level encryption. For restaurants, this means that any device on which payment data is stored, even if only temporarily, must support advanced encryption features.

For example, if a QSR uses tablets as point-of-sale (POS) devices that can accept payments from customers, those tablets would need to be capable of encrypting the entire disk or disk partition that stores payment data. The same rule would apply to any payment kiosks or in-restaurant servers that store payment data. According to Restaurant Dive, “With point-of-sale systems being the most important technology for restaurants, it’s no coincidence that many POS companies are sprinting to adopt more capabilities in response.” 

The new version of PCI DSS also strengthens the network security requirements that restaurants and other organizations must meet in order to process credit card payments. Requirement 4.2.1 mandates that businesses' network certificates (which enable secure connections and authenticate the validity of remote devices) are valid and up to date. This change helps prevent attackers from impersonating legitimate parties in order to intercept card payment data.

While this requirement doesn't necessarily require restaurants to install additional network security hardware, it does mean that any devices through which payment data passes are capable of validating network certificates. To help work towards compliance, businesses should make sure their device operating systems are up to date, a goal they can meet by establishing regular update cycles.

Requirement 5.4.1 of PCI DSS v4.0 takes aim at phishing attacks, in which threat actors impersonate legitimate users (such as an employee's business) in order to exfiltrate sensitive information. As part of the new rules, businesses need to establish measures to detect phishing attacks, as well as educate their personnel against the risk of phishing attacks.

QSRs can meet some of these anti-phishing requirements by deploying software designed to intercept malicious messages on email, text and other communication systems used by their employees. But since restaurant staff also often interact with the public in person, some restaurants may wish to invest in anti-phishing education programs designed to help staff detect attackers who may use social engineering tactics, such as posing as customers claiming to have been charged twice and asking to review payment records (which could contain other customers' card data) to confirm the mistake.

PCI DSS Key Requirement 7 includes several updates that significantly enhance the user identity and access control protections of the PCI DSS framework. Under the new rules, businesses must review all user accounts and their associated access permissions. They must also ensure they actively manage access privileges in a way that mitigates risk.

For QSRs, this means practices like allowing multiple staff members to access payment systems using a single, shared account may no longer be permissible. Instead, they will need to establish separate accounts for each employee and follow practices like least privilege, which restricts access rights to the bare minimum necessary for each user to perform their job.

The authentication systems that employees and other users rely on to connect to payment systems must be stronger to meet PCI DSS 4.0 requirements. Multi-factor authentication (MFA) means users must satisfy multiple requirements, such as a password as well as a secret code sent to the user on their phone, in order to complete a login process.

PCI DSS 4.0 introduced significant changes to MFA requirements. Access to the cardholder data environment (CDE) will extend beyond just administrators to secure all access to the CDE, meaning everyone has to implement MFA and all users will be challenged each time they access the CDE. Section 8 of the updated framework includes rules that require multi-factor authentication (MFA) to protect devices and applications that process payments or manage payment data.

For restaurants, meeting the new MFA requirements requires any devices used on the restaurant floor that can access the cardholder data environment (CDE) to be equipped with MFA access controls. Backend servers or applications that help to process payments will also need to meet the new MFA rules.

Key Requirement 10 of PCI DSS 4.0 introduces rules that require businesses to detect and respond promptly to the failure of any of the security controls they have in place. Within the PCI DSS v4.0, the term "Promptly" is defined as "As soon as reasonably possible". The goal is to ensure organizations are prepared to find and mitigate security threats to payment systems as rapidly as possible, rather than waiting until their next audit to catch problems.

Given that restaurant businesses often operate multiple sites without having cybersecurity staff on hand at each location, the new rapid-response requirements will require restaurants to double-down on automated security monitoring solutions that can identify and help to mitigate cybersecurity attacks without requiring security experts to travel on-site to respond to restaurant PCI DSS compliance risks.