PCI DSS Compensating Controls Worksheet: How to Write One That Passes

When compensating controls are appropriate

• Documented constraint (legacy, legal, technical)
• Same intent/objective as the original requirement
• Risk addressed without lowering security
• Additional controls beyond the minimum often expected

Writing the worksheet

Be specific: systems, CHD exposure, residual risk, how the compensating control is tested each assessment period, and who maintains it.

Maintenance

Revalidate when architecture changes. Expired compensating controls are a finding waiting to happen.

How CyberSilo Helps

• Evidence mapping in CyberSilo CSA
• Detection and logging proof with ThreatHawk SIEM
• Advisory scoping — contact CyberSilo

Frequently Asked Questions

Can every requirement be compensated?

No — some requirements disallow compensating controls; check the DSS text.

Is a policy enough?

Rarely — expect technical and process evidence.

Customized Approach vs compensating?

v4 Customized Approach is a different path with its own documentation — do not conflate.

Related Resources

• PCI hub
• TRA template