To meet the PCI DSS 4.0 vulnerability and malware management requirement, you must continuously identify vulnerabilities and malicious software risks across all systems in scope for cardholder data, remediate them based on risk, and keep evidence that scanning, patching, and anti-malware controls operate as designed ¹. Operationalize it by defining scope, setting a patch and scanning cadence, enforcing anti-malware coverage, and documenting exceptions.

Key takeaways:

• Scope first: tie vulnerability and malware controls to your cardholder data environment (CDE) and connected systems ¹.
• Auditors look for repeatable operations: scanning, patching, anti-malware coverage, and ticketed remediation with proof ¹.
• Evidence matters as much as execution: keep logs, reports, approvals, and exception records that show the program runs ¹.

The vulnerability and malware management requirement is one of the most operationally “observable” parts of PCI DSS: assessors can quickly test whether you consistently find issues and fix them, and whether malware controls are deployed and monitored across in-scope assets ¹. For a CCO, GRC lead, or compliance officer, the fastest path is to treat this as a closed-loop lifecycle: discover assets, identify vulnerabilities and malware risk, prioritize remediation, fix or mitigate, and retain proof.

This page translates the requirement into a practical implementation guide you can hand to Security and IT Operations without losing compliance intent. It also flags where teams typically fail: unclear scope, patching that relies on “best effort,” vulnerability findings that never close, and anti-malware controls that exist but don’t cover endpoints consistently. PCI DSS allows different technical implementations, but the compliance outcome is the same: you can demonstrate you identify and remediate vulnerabilities and malicious software risk in the environment that stores, processes, or transmits cardholder data ¹.

Vulnerability and malware management requirement (PCI DSS 4.0)

Regulatory text

Requirement (PCI DSS 4.0, PCI-04): “Identify and remediate vulnerabilities and malicious software risk.” ¹

What the operator must do (plain-English reading)

You need a repeatable program that:

1. finds security weaknesses and malware exposure in PCI scope,
2. fixes them or reduces risk to an acceptable level, and
3. produces evidence that proves it happened ¹.

This is not a one-time project. Assessors will expect operational consistency: routine scanning and monitoring, remediation tracked to closure, and accountable exceptions ¹.

Who it applies to

Entities: Merchants and service providers that must comply with PCI DSS ¹.

Operational context (what’s “in scope” for your work):

• Systems in the cardholder data environment (CDE): endpoints, servers, network devices, security appliances, and workloads that store/process/transmit cardholder data ¹.
• Systems connected to or impacting the CDE (for example, administrative systems used to manage CDE components), based on your PCI scoping approach ¹.
• Third-party-managed infrastructure or software that is part of your payment processing flows still requires you to manage risk and retain compliance evidence, even if some operations are performed by a third party ¹.

What you actually need to do (step-by-step)

Step 1: Lock scope and ownership

1. Define in-scope asset inventory for vulnerability and malware controls. Use your PCI scope boundaries and confirm which assets must be scanned/patched and have malware controls ¹.
2. Assign RACI. You need named owners for: vulnerability scanning, patching, endpoint protection, server protection, and exception handling ¹.
3. Document tool-to-asset coverage. Map each in-scope asset class (workstations, servers, containers, network devices) to the control that covers it (scanner + patch mechanism + anti-malware/EDR) ¹.

Deliverable outcome: a scope list and a coverage map you can hand to an assessor.

Step 2: Establish a vulnerability identification cadence

1. Run authenticated vulnerability scans where feasible. Authenticated scans reduce false negatives and strengthen evidence that you actually identified vulnerabilities ¹.
2. Ensure scan results are retained and attributable. Reports must show: target list, scan date/time, scanner identity, and findings ¹.
3. Create a triage workflow. Findings must flow into ticketing with severity, owner, and due dates defined by your risk policy ¹.

Practical tip: if your scanner covers “most” systems but misses a subnet or a cloud account, treat it as a scope gap and fix coverage before you argue severity. Assessors routinely test for blind spots ¹.

Step 3: Operationalize patching and remediation

1. Set remediation SLAs by risk tier. PCI DSS does not require a specific number in the excerpt you provided, so define internal SLAs that your teams can meet and auditors can test against ¹.
2. Patch through standardized mechanisms. Use managed patch tooling for endpoints and servers; for appliances, use vendor patch processes and change control records ¹.
3. Track remediation to closure. Every high-impact finding should have a ticket, evidence of fix (patch applied, configuration changed), and a retest/verification step ¹.
4. Handle compensating controls and exceptions. If you cannot patch, document the risk decision, the mitigation (for example, segmentation, virtual patching, configuration hardening), and the review cadence ¹.

Step 4: Deploy and govern anti-malware controls

1. Define where anti-malware is required. At minimum, endpoints and servers that can execute or introduce malicious code should be covered based on your risk model and scope ¹.
2. Standardize on centrally managed protection. Central management matters because it produces audit-ready evidence: policy settings, coverage, alerting, and update status ¹.
3. Enable continuous monitoring and alert response. Malware detections should create incidents with investigation notes and closure evidence ¹.
4. Control tampering and exclusions. Document who can disable agents or add exclusions, require approvals, and review exclusions periodically ¹.

Step 5: Prove the control works (evidence-first operations)

1. Run management review. A monthly (or similarly regular) operational review meeting with documented minutes is an efficient way to show governance without inventing extra paperwork ¹.
2. Perform spot checks. Sample assets to confirm: scanner sees them, patching is current per policy, and anti-malware is installed and checking in ¹.
3. Maintain an audit binder (digital). Organize artifacts by time period and control area so you can respond quickly during a PCI assessment ¹.

Required evidence and artifacts to retain

Keep artifacts that show both design (what you intended) and operation (what happened):

Program design

• Vulnerability management policy and remediation standard ¹
• Malware protection standard (deployment requirements, alert handling, exclusions) ¹
• Scope list of in-scope assets and networks, including ownership ¹
• RACI and escalation paths ¹

Operational evidence (most-requested by assessors)

• Vulnerability scan reports for in-scope assets, with dates and targets ¹
• Remediation tickets showing assignment, fix, and closure notes ¹
• Patch deployment reports or change records proving updates were applied ¹
• Anti-malware/EDR console exports: coverage, last check-in, policy status, detections, and response actions ¹
• Exception register: unpatched vulnerabilities, EDR exclusions, and documented risk acceptance with approvals ¹

Common exam/audit questions and hangups

Assessors and internal audit commonly probe these areas:

1. “Show me your in-scope asset list. How do you know it’s complete?” Expect sampling and reconciliation against CMDB/cloud inventory ¹.
2. “Are scans authenticated? If not, why, and how do you mitigate coverage risk?” Have a documented rationale and compensating visibility ¹.
3. “Pick three critical findings. Walk me from discovery to closure.” If you can’t tell the story with timestamps and proof, you will struggle ¹.
4. “Do you have anti-malware everywhere it needs to be, and can you prove it?” Console evidence beats screenshots of local agents ¹.
5. “How do you prevent someone from disabling protection or adding risky exclusions?” Governance and approvals matter ¹.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails in PCI testing	Fix
Asset inventory is incomplete or stale	You can’t prove you “identify” vulnerabilities if you don’t know what exists 1	Reconcile scanner targets against authoritative inventories and network ranges 1
Scans run, but remediation is ad hoc	The requirement includes “remediate,” and assessors test closure 1	Enforce ticketing, owners, due dates, retest evidence 1
Patching depends on local admins	Creates inconsistent coverage and weak evidence 1	Centralize patch reporting; require exceptions with approvals 1
Anti-malware deployed but not monitored	You can’t show malware risk is managed without alert handling evidence 1	Route detections to incident workflow; retain investigation notes 1
Too many undocumented exclusions	Exclusions become silent risk acceptance without governance 1	Create an exclusions register; require review and expiry dates 1

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat enforcement context as “assessment risk” rather than citing specific penalties or outcomes ¹. Practically, weak vulnerability and malware management drives two kinds of exposure:

• Compliance failure risk: inability to produce evidence that vulnerabilities are identified and remediated, or that malware protections are effective in scope ¹.
• Incident risk: unpatched vulnerabilities and unmanaged malware detections increase the likelihood that an attacker can gain foothold in or near the CDE ¹.

Practical 30/60/90-day execution plan

Days 0–30: Stabilize scope and visibility

• Confirm the in-scope asset inventory for vulnerability scanning, patching, and anti-malware ¹.
• Validate tool coverage: scanner reachability, authenticated scan capability, EDR/anti-malware agent deployment status ¹.
• Stand up a single remediation workflow in your ticketing system with required fields (asset, finding, owner, due date, closure evidence) ¹.
• Build an exception register template and approval workflow ¹.

Days 31–60: Enforce repeatable remediation

• Run a full vulnerability scan cycle across all in-scope assets; remediate the highest-risk findings first based on your internal severity model ¹.
• Document and test patching mechanisms and reporting for each platform ¹.
• Centralize anti-malware policies, restrict exclusions, and route detections to incident response with documented closure ¹.
• Start a recurring governance review with minutes and action items ¹.

Days 61–90: Make it audit-ready

• Perform a “mock assessment” evidence pull: pick a sample of assets and produce scan results, tickets, patch proof, and EDR status ¹.
• Fix gaps: unmanaged assets, missing scan credentials, inconsistent patch reporting, undocumented exclusions ¹.
• Finalize written procedures that match how teams actually work; align naming conventions so reports and tickets tie out cleanly ¹.
• If you use third parties for hosting or managed security, collect their artifacts and map responsibilities so your evidence file is complete ¹.

Tooling and operational shortcuts that help (without weakening compliance)

• One system of record for findings. Multiple scanners are fine, but normalize into a single queue for remediation tracking ¹.
• Evidence automation. Daydream can help you standardize evidence requests, map artifacts to PCI requirements, and keep an always-ready evidence library so vulnerability scans, patch reports, and malware console exports don’t become a scramble during assessment ¹.

Frequently Asked Questions

Does this requirement mandate a specific vulnerability scanning frequency?

The provided PCI DSS v4.0 excerpt does not specify a frequency; it requires you to identify and remediate vulnerabilities and malicious software risk ¹. Set an internal cadence you can execute consistently and prove with retained reports and tickets.

Do we need anti-malware on servers as well as endpoints?

The requirement is outcome-based: you must manage malicious software risk in scope ¹. Document which system types require anti-malware/EDR, deploy centrally managed controls, and keep evidence of coverage and alert handling.

What counts as acceptable remediation evidence?

Auditors expect a chain: scan finding, ticket/work item, fix evidence (patch/change), and verification or retest output tied to the same asset ¹. Screenshots alone are weak if they can’t be attributed to scope and time.

How should we handle vulnerabilities we cannot patch?

Put them into an exception register with documented rationale, risk acceptance approval, compensating controls, and a planned review cadence ¹. Keep proof that the compensating control exists and is operating.

If a third party manages our infrastructure, are we still responsible?

You remain responsible for PCI outcomes for your environment and must retain evidence that vulnerability and malware risks are identified and remediated for in-scope systems ¹. Contract for evidence delivery and define who runs scans, who patches, and how closure is documented.

What is the fastest way to get ready for a PCI assessment on this requirement?

Build an “evidence packet” that includes: scope list, recent scan reports, a sample of closed remediation tickets, patch reports, and anti-malware console exports that prove coverage and detections handling ¹. Daydream can help keep this evidence organized and continuously updated ¹.

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control management

Footnotes

1. PCI DSS v4.0