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PCI DSS Incident Response Plan Template (Requirement 12.10)

PCI DSS incident response plan template for Requirement 12.10 - roles, brand notification, containment, forensics, and annual testing outline.

Published: September 2026 Compliance · PCI DSS 8-12 min read

PCI DSS 12.10 requires a documented incident response plan that is tested at least annually, with 24/7 personnel coverage for suspected or confirmed security incidents. This page is an outline template - adapt it to your CDE, legal counsel, and brand/acquirer notification duties.

Related: Requirement 12 · Policy templates · Fines · Evidence list · Agentic SOC.

Gotcha: An untested IR plan fails 12.10. Document tabletop date, attendees, and lessons learned. Visa WTDIC timelines (for example certain Member reporting duties within three calendar days) are often shorter than corporate IR SLAs - bake brand and acquirer contacts into the plan.

IR Plan Template Sections

  1. Purpose / scope - CDE and connected systems
  2. Definitions - suspected vs confirmed account data compromise
  3. Roles and 24/7 contact tree (12.10.3)
  4. Detection sources - IDS/NSC/FIM/payment-page tamper/unauthorized wireless (ties to 12.10.5)
  5. Severity / triage
  6. Containment, eradication, recovery
  7. Evidence preservation / PFI engagement triggers
  8. Notification matrix - acquirer, brands, regulators (for example CBUAE 72-hour duties where Article 18 applies to Card Schemes), customers, law enforcement
  9. Business continuity / backups
  10. Communications - legal-approved messaging
  11. Post-incident review - update the plan (12.10.6)
  12. Training cadence (12.10.4 / TRA 12.10.4.1)
  13. Annual test record appendix

Close each tabletop with owners, findings, and plan revision dates so assessors can sample the operating cycle.

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Frequently Asked Questions

Is a PFI always required?

Brand and acquirer programs dictate PFI engagement after confirmed account data compromise. Document the trigger in the plan.

Can a SOC runbook replace this plan?

SOC runbooks feed the plan; Requirement 12.10 still needs the documented entity IR plan and annual test record.

Does CBUAE 72-hour notice apply to every UAE merchant?

Article 18 paragraph 22 is a Card Scheme duty under Circular C 15/2021. Merchants still follow brand/acquirer notice rules - and any other licence-specific regulator duties that apply to them.

Requirement 12 · Policy templates · Fines · Evidence list · Agentic SOC · UAE and KSA

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