PCI Memo To Mobile Payment App Developers: It’s Up To YouWritten by Walter Conway
A 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.
One of the highlights of last week’s PCI Community Meeting was the long-awaited release of the PCI Security Standards Council’s guidance on mobile-payment application developers. The document lays out a set of requirements that together form a roadmap for mobile-payment application developers and would-be developers.
Currently, retailers have a choice. They can use their smartphones and tablets, sticking on a dongle that reads a payment card’s magnetic stripe, and be cruising down the mobile commerce highway. Or they can be PCI DSS compliant. Unfortunately, the PCI Council has stated that smartphones and tablets are not secure, pointing to recent guidance from the National Institute of Standards and Technology (NIST) to support that position. The question, therefore, is: When will retailers have secure applications that enable them to use a wide range of smartphones and tablets for mobile commerce while still being PCI DSS compliant? I don’t think we have an easy answer to that question yet.
Is having both mobile commerce and PCI DSS compliance too much to ask? I don’t think so. But we all will find out soon.
The future of mobile commerce is in the smartphones, tablets and assorted iDevices that merchants and consumers love. These devices are behind the surge of new merchants that have never before taken payment cards. The devices have also attracted a new set of application developers, who may not know secure coding techniques or understand the risks inherent in a payment transaction. I suspect many of these developers think OWASP is a cry for insect repellent.
This future—or is it the present?—poses risks. The mobile devices often exist outside of any enterprise security management. A device’s location changes as regularly as the merchant moves to different locations (that is what mobile commerce is all about) and it links to different networks. And if that is not enough, it is hard to detect tampering or malware on the device.
As a result, it is not possible for a retailer to be PCI DSS compliant when using a personal smart device.
That fact, however, has not stopped many merchants from using these devices, and therein lays our PCI DSS compliance challenge.
MasterCard was the first to recognize that PCI DSS compliance is not possible—downgrading it to a “unique challenge”—when it released its merchant guidance in May. The card brand’s position was that because mobile commerce using a smart device equipped with a card-reading dongle is inevitable and because PCI DSS compliance is not realistic, retailers should do their best to be safe.
Visa followed shortly thereafter with similar guidance.