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PCI DSS Compensating Controls Explained (With Worked Examples)

What PCI DSS compensating controls are, when they are allowed, the four criteria, how to fill in the worksheet and how they differ from the customised approach.

By Sovereign SecureUpdated 8 min read

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On this page
  1. What is a PCI DSS compensating control?
  2. When is a compensating control allowed?
  3. What are the four compensating control criteria?
  4. What does “above and beyond” mean?
  5. Compensating control examples in practice
  6. How do you complete the Compensating Controls Worksheet?
  7. What is the difference between a compensating control and the customised approach?
  8. Why are compensating controls rejected?
  9. How long can a compensating control stay in place?
  10. Getting it right first time

Compensating controls are alternative safeguards used when a required control cannot be implemented as written, chosen to reduce the same risk to a similar level. In PCI DSS, a compensating control is allowed only when a legitimate, documented technical or business constraint stops you meeting a requirement. It must meet the intent and rigour of the original requirement, give a similar level of defence, go above and beyond other PCI DSS requirements, and be proportionate to the extra risk. You document it on the Compensating Controls Worksheet in Appendix C of the standard, and it is re-validated at every assessment.

Compensating controls are widely misunderstood. They are not a way to avoid work, and an assessor will reject one that does not meet the criteria. This guide explains how they work under PCI DSS v4.0.1.

Key takeaways

  • A compensating control is an alternative to a defined requirement when a genuine constraint prevents you meeting it.
  • Every compensating control must pass four criteria set in Appendix B of PCI DSS.
  • Controls you are already required to have do not count; the alternative must go above and beyond.
  • Each one is documented on a worksheet and re-validated at every assessment.
  • The customised approach introduced in v4.0 is a different mechanism with different rules.

What is a PCI DSS compensating control?

PCI DSS v4.0.1 offers two ways to meet a requirement. The defined approach means implementing the requirement as written and having it tested with the standard’s testing procedures. The customised approach means meeting the requirement’s stated objective with a control you design.

Compensating controls belong to the defined approach. You use one when you cannot meet a defined requirement as stated because of a documented constraint, and you have put other controls in place that reduce the risk to a similar level. Appendix B of the standard sets the rules and Appendix C contains the worksheet. Both are in PCI DSS v4.0.1, available from the PCI SSC document library.

When is a compensating control allowed?

Only when the constraint is real. An assessor will test that first.

Accepted as a constraint Not accepted
A legacy payment application cannot run on a supported operating system “It costs too much”
A specialist device cannot generate the audit logs the standard requires “We have not had time”
Changing a system would break a critical process, and no practical fix exists before the assessment “The vendor has not got round to it”
A third-party platform you depend on does not support a required control “We did not know about the requirement”

Cost may influence how quickly you remove a constraint, but it is not a constraint in itself.

What are the four compensating control criteria?

Appendix B sets four criteria. Fail any one and the compensating control is not valid.

Criterion What the assessor checks
1. Meets the intent and rigour of the original requirement You understand what the requirement protects against and your alternative addresses the same thing
2. Provides a similar level of defence The combined controls offset the risk the original requirement was designed to address
3. Goes above and beyond other PCI DSS requirements Nothing in the package is something you already have to do
4. Is commensurate with the additional risk The controls are proportionate to the extra risk created by not meeting the requirement

What does “above and beyond” mean?

You cannot count a control you are already required to implement. If a requirement already obliges you to do something for that system, doing it does not compensate for something else.

Existing requirements can still help when you apply them to something they would not otherwise cover, or apply them more strictly than required. For example, reviewing logs for a specific legacy system in near real time, rather than at the frequency the standard sets, goes beyond the baseline.

Compensating control examples in practice

Example 1: an unsupported operating system

A retailer runs a payment application on an operating system that no longer receives security updates. The vendor’s replacement will not be ready for a year, so the retailer cannot meet the requirement to install critical security patches within one month of release (6.3.3).

A credible compensating control might combine:

  • Moving the system into its own tightly restricted network segment that allows only the connections the application needs.
  • Application allow-listing, so only approved executables can run.
  • File integrity monitoring on critical system and application files.
  • Real-time alerting on any unexpected logon, process or network connection, reviewed promptly.
  • Authenticated scanning of the system more often than quarterly, through vulnerability scanning services, with results reviewed each time.
  • A documented, funded plan and date to migrate to the supported replacement.

None of these alone would be enough. Together they address the specific risk that unpatched vulnerabilities could be exploited. The assessor will test each element, so the retailer also needs evidence that they work, such as PCI DSS penetration testing of the new segment.

More compensating controls examples

The same pattern, a genuine constraint answered by several layered controls, applies to other requirements. These are typical starting points, not ready-made answers: each still has to pass the four criteria for your environment.

Requirement you cannot meet as written Typical constraint Controls often combined to compensate
Unique IDs for every user (8.2.1) A legacy system supports only one shared administrator account A privileged access tool that releases the password to named people one at a time, session recording, and alerts on any use outside the tool
Stored PAN rendered unreadable (3.5.1) A legacy database or application cannot encrypt, truncate or tokenise the field Tight isolation of the database, access limited to named administrators, database activity monitoring with alerts, and a dated replacement plan
Audit logs for all access (10.2.1) A specialist device cannot produce the logs the standard requires All access forced through a jump host that logs and records every session, with the device unreachable from anywhere else

Compensating controls outside PCI DSS

The idea is not unique to card payments. The NIST glossary defines a compensating security control as one used in place of a recommended baseline control that gives equivalent or comparable protection. In financial controls, the classic example is a finance team too small to separate who raises and who approves payments, which compensates with an independent review of every payment run by a manager outside the team.

Not every scheme works this way. ISO 27001 has no separate compensating control process: you choose controls through risk treatment and justify them in your Statement of Applicability. Cyber Essentials is pass or fail against fixed requirements, so unsupported software, for example, must be removed or moved into a segregated sub-set outside the certified scope.

How do you complete the Compensating Controls Worksheet?

The worksheet in Appendix C has six sections. Write it for someone who has never seen your environment.

Section What to write
Constraints Why you cannot meet the original requirement, with evidence
Definition of compensating controls Exactly what you have put in place instead: systems, settings, owners
Objective The intent of the original requirement and how your controls meet it
Identified risk The additional risk created by not meeting the original requirement
Validation of compensating controls How the controls were tested and shown to work
Maintenance How you keep them working and check the constraint still exists

Be specific about systems, configurations and evidence. Vague statements such as “enhanced monitoring is in place” will not survive review. In a Self-Assessment Questionnaire, you mark the requirement “In Place with CCW” and attach the worksheet. Our guide to common SAQ mistakes shows how these are often misused, and our free PCI compliance check gives a quick view of the gaps you may need to close first.

What is the difference between a compensating control and the customised approach?

They are easy to confuse, but they work differently.

Aspect Compensating control Customised approach
Why you use it A constraint stops you meeting the defined requirement You choose to meet the objective differently, even if you could meet the defined requirement
Where available ROC or SAQ ROC only
Documentation Compensating Controls Worksheet (Appendix C) Controls matrix and a targeted risk analysis for each control (12.3.2; Appendices D and E)
Testing The assessor tests the alternative against the four criteria The assessor designs testing procedures specific to your control
Suited to Legacy systems and genuine constraints Organisations with mature risk management

Some requirements cannot be met with the customised approach at all. If you are simply stuck with a legacy system, a compensating control is usually the right tool.

Why are compensating controls rejected?

  • The constraint is really about cost or convenience.
  • The proposed controls are already required by other PCI DSS requirements.
  • The controls do not address the specific risk created by the gap.
  • There is no evidence the controls operated effectively over the assessment period.
  • The worksheet is generic and could describe any environment.

How long can a compensating control stay in place?

As long as the constraint exists and the control keeps passing validation, but treat it as a debt to be repaid. It is re-evaluated at every assessment. Between assessments, monitor it like any other control, record and fix failures, and check whether the constraint still exists. Once the constraint is gone, the compensating control is no longer valid and you must meet the original requirement. A PCI DSS gap analysis is a good time to review them all.

Getting it right first time

The best time to discuss a compensating control is before you build it, not during the assessment. Sovereign Secure is a PCI SSC-approved Qualified Security Assessor company and a member of the PCI SSC Global Executive Assessor Roundtable (GEAR) for 2026 to 2028. A PCI DSS consultant from our team can help design and document the control, and we test it as part of your PCI compliance audit.

Your next step

FAQ

Questions we often hear

Can't find your answer? Call us on +44 161 523 5276 or send us a message.

Can I use a compensating control to save money?

No. A compensating control needs a legitimate, documented technical or business constraint. Cost or inconvenience on its own is not accepted, and the alternative must still provide a similar level of protection.

Is a compensating control a permanent solution?

There is no fixed time limit, but it must be re-validated at every assessment and should be treated as temporary. Most organisations pair it with a funded plan to remove the underlying constraint, such as replacing a legacy system.

What is the difference between a compensating control and the customised approach?

A compensating control responds to a constraint that stops you meeting a defined requirement. The customised approach is a deliberate choice to meet a requirement's objective in a different way, is only available in a Report on Compliance, and needs a targeted risk analysis for each control.

Does a QSA need to approve our compensating controls?

In a Report on Compliance, the QSA must validate every compensating control. In a Self-Assessment Questionnaire you document them yourself on the worksheet, but your acquirer may challenge weak ones, so an independent review is worthwhile.

Can a compensating control be used for any requirement?

In principle, most requirements can be met with a compensating control if a genuine constraint exists. In practice, some, such as the ban on storing sensitive authentication data after authorisation, are very hard to compensate for credibly.

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