Migrating from SOC 2 to PCI DSS
Approximately 60% of PCI DSS and SOC 2 requirements overlap in areas like access control, encryption, and monitoring. However, PCI DSS is highly prescriptive with specific technical requirements, while SOC 2 is principles-based. The main work is implementing CDE scoping, network segmentation, and meeting specific technical standards.
Critical Compliance Gaps
Cardholder Data Environment (CDE) Scope
PCI DSS requires precise scoping of the Cardholder Data Environment—every system that stores, processes, or transmits cardholder data. SOC 2 scope is more flexible and business-defined.
Prescriptive Technical Controls
PCI DSS v4.0 has 12 specific requirement categories with detailed technical specifications (e.g., specific encryption algorithms, password complexity rules). SOC 2 is principles-based.
Network Segmentation
PCI DSS strongly recommends (and effectively requires) network segmentation to reduce CDE scope. SOC 2 doesn't prescribe network architecture.
Quarterly Vulnerability Scanning
PCI DSS requires quarterly internal and external vulnerability scans by an Approved Scanning Vendor (ASV). SOC 2 requires vulnerability management but not specific scanning frequency.
Annual Penetration Testing
PCI DSS mandates annual penetration testing of CDE with specific methodology requirements. SOC 2 doesn't require penetration testing.
Step-by-Step Migration Roadmap
Follow these 12 steps to achieve PCI DSS compliance. Estimated timeline: 16 weeks.
Define Cardholder Data Environment (CDE) scope precisely
Implement network segmentation to isolate CDE
Map SOC 2 controls to PCI DSS 12 requirement categories
Engage Approved Scanning Vendor (ASV) for quarterly external scans
Implement quarterly internal vulnerability scanning
Schedule annual penetration testing per PCI DSS methodology
Implement specific encryption requirements (TLS 1.2+, strong cryptography)
Configure MFA for all CDE access per v4.0 requirements
Establish PCI-specific logging and monitoring for CDE
Create incident response plan addressing payment card breaches
Complete Self-Assessment Questionnaire (SAQ) or prepare for QSA audit
Implement file integrity monitoring for critical systems
Unique PCI DSS Requirements
Strategic Use Cases
Verification Sources
Last verified: January 12, 2026
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SOC 2 to PCI DSS Migration FAQs
Do I need PCI DSS if I use Stripe or PayPal$2
It depends on how you integrate. If you use hosted payment pages and never touch card data, you may only need SAQ A (minimal requirements). If your servers process or store card data, you need full PCI DSS compliance.
What's the difference between SAQ and QSA audit$3
Self-Assessment Questionnaires (SAQ) are for smaller merchants and have varying levels (A through D). A Qualified Security Assessor (QSA) audit is required for Level 1 merchants (>6M transactions) and produces a Report on Compliance (ROC).
How often do I need to validate PCI DSS compliance$4
Annually for the SAQ or QSA assessment, quarterly for ASV external vulnerability scans, and ongoing for internal security controls. PCI DSS v4.0 emphasizes continuous compliance.
Can I be SOC 2 and PCI DSS compliant with one audit$5
Not exactly—they require separate reports. However, many auditors offer combined engagements that leverage shared controls, reducing total audit time and cost by 20-30%.
About RiscLens
Our mission is to provide transparency and clarity to early-stage technology companies navigating the complexities of SOC 2 (System and Organization Controls 2) compliance.
Who we serve
Built specifically for early-stage and growing technology companies—SaaS, fintech, and healthcare tech—preparing for their first SOC 2 audit or responding to enterprise customer requirements.
What we provide
Clarity before commitment. We help teams understand realistic cost ranges, timeline expectations, and common gaps before they engage auditors or expensive compliance vendors.
Our Boundaries
We do not provide legal advice, audit services, or certifications. Our assessments support internal planning—they are not a substitute for professional compliance guidance.
SOC 2 (System and Organization Controls 2) is a voluntary compliance standard for service organizations, developed by the AICPA, which specifies how organizations should manage customer data based on the Trust Services Criteria: security, availability, processing integrity, confidentiality, and privacy.
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