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What Are Compensating Controls in PCI DSS?

This article describes what compensating controls are, when they should be used and provides examples

In PCI DSS, a compensating control is an alternative security measure used when an organisation cannot meet a specific PCI DSS requirement exactly as written, but can implement a different control that achieves the same security outcome.

Compensating controls are only acceptable when:

  • The original requirement cannot be met due to a legitimate technical or business constraint

  • The alternative control provides an equivalent level of protection

  • The approach is properly documented and justified

They are not intended as shortcuts or permanent workarounds.

Why compensating controls exist

PCI DSS requirements are designed to apply across many different environments.

However, some organisations may face situations where:

  • Legacy systems cannot support modern configuration requirements

  • Certain technical constraints prevent implementation as written

  • A requirement is not feasible without major redesign

In these cases, PCI DSS allows compensating controls to ensure security is still maintained.

The goal is flexibility without reducing protection.

What compensating controls are NOT

Compensating controls are not:

  • A way to avoid compliance

  • A “partial implementation”

  • A replacement for good security practice

  • Automatically accepted without review

Assessors and acquirers expect compensating controls to be used rarely and only when properly justified.

When compensating controls may be used

Compensating controls may be considered when:

  • A PCI DSS requirement cannot be met due to documented technical limitations

  • The organisation can implement an alternative measure that provides equivalent protection

  • The risk of not meeting the requirement is fully addressed

Examples include:

  • Legacy systems that cannot support MFA

  • Technical inability to encrypt stored PAN in a specific manner

  • Environmental constraints in physical security controls

Requirements for a valid compensating control

For a compensating control to be acceptable, it must:

1. Meet the intent of the original requirement

It must address the same security objective.

2. Provide an equivalent level of defence

The alternative must reduce risk to the same extent.

3. Be above and beyond other PCI DSS requirements

You cannot simply point to another existing requirement as the compensating control.

4. Be documented and reviewed

Compensating controls require formal documentation and assessor evaluation.

Compensating Control Worksheets (CCWs)

PCI DSS requires compensating controls to be recorded using a Compensating Control Worksheet (CCW).

A CCW documents:

  • The requirement being compensated for

  • Why it cannot be met as written

  • The alternative control implemented

  • How the alternative meets the requirement’s intent

  • Evidence that the control is effective

CCWs are typically reviewed during assessments and may be requested by acquirers.

Example (simplified)

Requirement

MFA must be enabled for all administrative access.

Constraint

A legacy system cannot technically support MFA.

Compensating control

The organisation implements:

  • Strict network segmentation preventing remote access

  • Dedicated jump servers with MFA enforced

  • Enhanced logging and alerting for all admin actions

  • Short session timeouts and privileged access review

This combination may provide equivalent security, but must be:

  • Justified

  • Documented in a CCW

  • Approved by the assessor

Important considerations under PCI DSS v4.x

PCI DSS v4.x places greater emphasis on:

  • Demonstrating security outcomes

  • Evidence of control effectiveness

  • Continuous compliance rather than annual snapshots

As a result, compensating controls must be:

  • Strongly defensible

  • Properly maintained

  • Continuously evidenced

Weak or informal workarounds are less likely to be accepted.

Best practice guidance

Compensating controls should be treated as:

  • Exceptional

  • Temporary where possible

  • Fully documented

  • Reviewed regularly

Where feasible, organisations should plan to meet the requirement directly in the long term.

Key takeaway

A compensating control is a formally documented alternative that achieves the same security objective as a PCI DSS requirement when compliance “as written” is not possible.

They are not shortcuts — they require strong justification, equivalent protection, and assessor approval.