What to Do If PCI Compliance Goes Off Track: A Practical PCI DSS Remediation Plan

PCI DSS compliance failures happen more often than most organizations admit.

A missed control.
Incomplete documentation.
An unexpected audit finding.

Suddenly, you're asking:

What happens if we fail a PCI audit?
How do we recover from PCI non-compliance?
Can we still maintain compliance if a requirement isn't fully met?

The good news? Falling out of compliance isn’t the end — but it does require a structured remediation plan.

Why PCI Compliance Goes Off Track

Common causes of PCI DSS non-compliance include:

Incomplete logging or monitoring controls
Missing multi-factor authentication (MFA)
Outdated vulnerability scans
Unmanaged third-party risk
Lack of documented evidence
Poor internal ownership of requirements

Most failures aren’t technical incompetence.

They’re evidence management breakdowns.

And that’s a process problem — not just a security problem.

Step 1: Assess the Scope of Non-Compliance

Before reacting emotionally, document:

Which PCI DSS requirement failed
Whether it was a control failure or an evidence gap
Whether a Compensating Control Worksheet (CCW) is applicable
Whether the issue impacts your cardholder data environment scope

Clarity prevents panic.

A structured assessment turns chaos into action.

Step 2: Build a PCI DSS Remediation Plan

A strong PCI remediation roadmap should include:

Root cause analysis
Assigned control owners
Defined remediation timelines
Evidence tracking milestones
Stakeholder communication plan

Without documented tracking, remediation efforts quickly become reactive and fragmented.

A remediation plan isn’t just about fixing a gap — it’s about preventing repeat failures.

Step 3: Consider Compensating Controls (CCW)

PCI DSS allows for compensating controls when:

The original requirement cannot be met exactly as written
An alternative control reduces equivalent risk
There is documented justification

Properly documenting a Compensating Control Worksheet (CCW) requires:

Risk justification
Detailed control mapping
Evidence of implementation
Executive approval

Many organizations fail here not because they lack controls — but because they lack structured documentation.

Step 4: Centralize and Automate Evidence Collection

One of the biggest causes of PCI remediation failure is scattered evidence:

Screenshots in email
Logs stored in separate systems
Policies saved in different drives
Control ownership unclear

When evidence is fragmented, audits become painful.

Centralizing and automating evidence tracking significantly reduces compliance risk.

Platforms like episki support:

Real-time PCI control status tracking
Exception and compensating control documentation
Clear audit trails
Evidence timestamping
Cross-framework control mapping (PCI, SOC 2, ISO 27001, NIST CSF)

This transforms PCI compliance from a yearly scramble into an ongoing, manageable process.

What Happens If You Ignore PCI Non-Compliance?

Ignoring PCI gaps can result in:

Fines from acquiring banks
Increased transaction fees
Mandatory forensic audits
Loss of ability to process cards
Reputational damage

The longer remediation is delayed, the more expensive it becomes.

Proactive recovery is always less costly than reactive crisis management.

From Recovery to Resilience

The goal isn’t just fixing one failed audit.

It’s building a repeatable compliance system that:

Prevents evidence gaps
Tracks control ownership
Aligns IT, security, and compliance
Enables cross-framework reuse
Reduces manual compliance overhead

PCI setbacks are painful — but they expose weaknesses that, once addressed, create stronger governance foundations.

Start Your PCI Recovery Plan

If you're behind on PCI DSS or facing remediation pressure, the worst move is inaction.

A structured remediation roadmap — supported by centralized and automated evidence tracking — turns panic into process.

PCI compliance doesn’t fail because teams don’t care.
It fails when systems aren’t built for scale.

See how episki helps streamline PCI remediation and control tracking →
Request a demo