For those who have been reading this blog long enough, you would know that we are absolutely, completely, mind-numbingly devoted to the anti-certificate movement within the PCI-DSS. Really. And every single month, almost, it never fails that we get enquiry that our customer or their acquirer are demanding to see the precious certificate of compliance. And rejecting the AoC. Rejecting the RoC.
It has truly become so farcical in PCI-DSS when acquirers – banks! – demand this of our customers. To an extent that even our customers give a wry shrug at us, the way my wife and I would shrug at each other when my kid tells us that he just witnessed an elephant doing hoola-hoops in a tutu in his kindergarten that morning.
We have written it before and will keep writing it till the horn sounds for the second coming: Compliance ‘certificates’ are NOT recognised by the PCI-SSC! PCI-DSS seals with those wondrous badges (like the police etc) are not recognised by the PCI-SSC. In the words of the council:
PCI COUNCIL REMONSTRATING TO ALL PRO-CERTIFICATES TO STOP DOING THIS NONSENSE
The only documentation recognized for PCI DSS validation are the official documents from the PCI SSC website. Any other form of certificate or documentation issued for the purposes of illustrating compliance to PCI DSS or any other PCI standard are not authorized or validated, and their use is not acceptable for evidencing compliance.
So banks – please, please, for the sake of all that is good and worthy in our God given Earth – DO NOT demand your providers/customers/merchants to show the certificate of compliance. It’s ridiculous and it demonstrates that you, an entity that should know PCI first and foremost, are absolutely not doing your job well. You are making demands for things that are considered unauthorized and unacceptable!
We are not saying certificates are illegal or those peddling these certificates are cheating anyone. By far and large, all QSAs generally provide these so called certificates as an easy way to illustrate compliance, or just to have the customer frame it up and put it onto their wall. This is perfectly, absolutely fine. Even our QSAs do it. It’s not the problem with the QSAs putting these certificates out. The problem are with the acquirers or those demanding to see PCI compliance from their merchants/providers etc. Banks, financial institutions etc who refuses to see anything else but the ‘certificate’ as evidence of PCI-DSS compliance. It’s frustrating. Yes, most clients will be able to provide these ‘certificates’, but where it boils us up is when the acquirer refuses to accept the RoC and AoC as evidence of compliance! WHY NOT? Because likely the person in the bank requesting PCI-DSS have zero clue what PCI-DSS is , or what it’s supposed to be, in the first place.
Banks, here is a simple illustration:
Would you accept the below as proof of compliance:
Or would you accept the one below:
If you answer the first one, then the question is why do you reject the second one?
“Well because it looks fake and it looks like its scrawled by a two year old, or a random hamster running around on a paper with ink on its paws,” you reply.
Well, guess what?
Both should either be rejected, or accepted because both are of the same value. SAME VALUE. Just because one certificate isn’t designed as aesthetically nicer than the other doesn’t make it less of a certificate. Why? Because the baseline worth of the certificate is zero. There is ZERO value to the certificate on paper. The only value attached to it is from the viewpoint of the person looking at this worthless piece of paper and going, “Hum, that looks nice.” or “Hmm, that color looks off.”
I know this may sound like an over-reaction, because at the end, since Certificate of Compliance is now the norm (due to these demands) – everyone who has an AoC would probably have a certificate as well, right? Well, what about those doing their own SAQ? Do they design their own Certificate then and say this is a self attested cert? So, Mr Bank, how do you wriggle yourself out of this kerfuffle? Why do you place so much value into something that (according to PCI SSC) is absolutely worthless, and do not focus on the actual documents that are worth something? And worse of all – to actually reject the documents that are formally from PCI-SSC and accept only these glorified certificates that are worth as much as the paper its printed on!
I think, the only resolution to this is to completely do away with PCI certificates. The next person touting these certificates as the only means of PCI validation, we are going to show them that certificate that’s drawn by the hamster and see what they say.
Jokes aside – let us know if you have any questions on PCI-DSS or any security compliance in your company – we are always willing to help out – drop us a note at email@example.com.