One Year On: Why Ignoring PCI DSS 4.0.1 Compliance Is a Risk You Can’t Afford

More than a year has passed since PCI DSS 4.0.1 became mandatory, yet many organizations are still struggling to comply, or worse, failing their audits entirely. If your business handles cardholder data and you’ve not yet made the necessary changes you’re not alone, but you are at risk. 

In this blog, we explore what’s changed under PCI DSS 4.0.1, why ongoing non-compliance is so concerning, and how organizations like yours can address the challenge head-on. We'll also explain how Eckoh can help you not only achieve compliance but do so with confidence and minimal disruption. 

The Compliance Gap: Still Too Wide 

PCI DSS 4.0.1 went live in March 2024, introducing a modernized, risk-based approach to payment security. New requirements included: 

• Multi-factor authentication (MFA) for all access to cardholder data environments 
• Strong encryption and secure transmission protocols 
• Continuous risk assessments and monitoring 
• Enhanced validation of service provider security 
• More detailed and frequent documentation and testing 

Despite these well-publicized updates, many organizations are still not compliant and risk failing audits. 

Why PCI DSS 4.0.1 Is So Difficult 

PCI DSS 4.0.1 was designed to be more flexible, introducing customized implementation options alongside defined controls. But with this flexibility comes more room for misinterpretation. 

Here are a few of the common misunderstandings we see: 

• Using customized controls without sufficient documentation or justification 
• Assuming third-party providers are fully responsible for PCI compliance 
• Failing to fully identify the entire cardholder data environment  
• Overlooking new monitoring and response testing requirements 
• Inconsistent MFA deployment or tokenization methods 

Even a small misstep, such as missing a single control or misunderstanding documentation requirements, can mean audit failure followed by expensive remediation and reassessment. 

Compliance Failure Is Widespread—Not Just PCI 

The challenge isn’t limited to PCI DSS. Organizations are struggling with security audits across the board. 

According to the Thales 2025 Global Data Threat Report, 45% of organizations failed a compliance audit in the past year: 

“The tendency to dismiss compliance audits as ineffective ‘checkbox’ exercises reflects a failure to understand their purpose: to verify, at a given time, that controls are in place to prevent or minimize damage from data breaches… Compliance failure rates remain high, with 45% of 2025 respondents reporting a recent failed compliance audit.” 
Thales 2025 Global Data Threat Report 

This highlights how complex and expensive compliance has become, even for well-resourced organizations. It also reinforces the urgency of addressing PCI DSS 4.0.1 now, before non-compliance turns into a costly breach or audit failure. 

The Real Risks of Inaction 

Failing to comply with PCI DSS 4.0.1 isn’t just a technical gap, it’s a strategic risk. Here’s why: 

1. Regulatory and Financial Penalties 

Non-compliance can lead to fines, card scheme penalties, and loss of payment processing privileges. 

2. Disruption from Audit Failures 

Audit failures often require significant and immediate remediation—costing time, money, and operational capacity. 

3. Increased Breach Risk 

Compliance frameworks are built around security best practices. If you’re not compliant, you’re also likely exposed. 

4. Damage to Trust 

Consumers expect their payment data to be secure. A compliance failure or breach damages brand reputation and customer trust. 

Whilst the risks of non-compliance are high, maintaining compliance is expensive. An assessment from a PCI certified QSA costs on average $15,000 and enterprises can be looking at total costs of at least $70,000 for a full PCI audit and testing, plus potentially hundreds of thousands more for the remediation required to achieve compliance. And these costs keep coming. PCI compliance is not a ‘once and done’ situation, it’s an ongoing burden.  

Fortunately, there is a simpler solution.  

Descope from PCI with Eckoh 

Instead of building complex controls and systems to meet PCI DSS requirements, many organizations choose a different route: descoping from PCI DSS entirely. That’s where Eckoh comes in. 

Eckoh’s secure payment solutions ensure that card data never touches your systems, whether customers are paying by phone, chat, email, or web form. 

With sensitive data removed, your environment is out of PCI scope. That means less to assess, fewer tools to secure, and lower overall compliance costs. With Eckoh, there's no risk of falling short due to misunderstood requirements or inconsistent controls, because the data simply isn’t there. 

The PCI DSS 4.0.1 deadline has passed, but for many organizations, compliance is still a work in progress. It’s not too late, but inaction now could mean audit failure, financial penalties, or even a damaging data breach. 

Talk to Eckoh Today 

The good news? With Eckoh, you can eliminate PCI risk entirely, streamline your audit process, and protect your customers across every channel. Talk to us today about how we can help you.