Quick answer

Payment gateway security comes from architecture rather than add-on tools: card data is tokenized as early as possible, encrypted in transit and at rest, isolated in a segmented cardholder data environment, and monitored with tamper-evident logs. Every gateway that handles card data must meet PCI DSS. EU-facing gateways also fall under PSD2 and GDPR, and financial entities under DORA. Because the integration method decides PCI DSS scope, these requirements cost least when they are designed in before the build.

This guide maps payment gateway security from standard to system. It covers which standards apply and who enforces them, the technical controls each one mandates, how those controls fit into a security architecture, how to test them, how the integration method sets PCI DSS scope, and what changes when compliance is built in rather than retrofitted. Each standard governs a different layer of the gateway, with its own scope, audit cadence and technical trigger, so the same integration often has to meet several at once.

Payment Gateway Compliance Standards: Comparison Table

Depending on where it processes transactions and whose data passes through it, the same integration can fall under PCI DSS, PSD2, GDPR, DORA, SOC 2, ISO 27001, and PCI PIN/P2PE at once, each with its own scope, enforcement body, and technical requirement.

Standard
Full Name
Applies To
Key Gateway Requirements
Enforced By

PCI DSS v4.0.1

Payment Card Industry Data Security Standard (v4.0.1, published June 2024)

Any entity storing, processing, or transmitting cardholder data

12 requirements covering network security, encryption, access control, monitoring, and penetration testing; annual validation based on merchant/service provider level

Card schemes (Visa, Mastercard, Amex) via acquiring banks

PSD2

Payment Services Directive 2 (Directive (EU) 2015/2366, applies from 13 January 2018; SCA rules under Delegated Regulation (EU) 2018/389, from 14 September 2019)

Payment service providers operating in the EU/EEA

Strong Customer Authentication (SCA) for online card payments; 3DS2 implementation; SCA exemptions (low-value, transaction risk analysis); open banking API obligations for account-holding banks, not card gateways

EU national competent authorities; EBA guidelines

GDPR

General Data Protection Regulation (Regulation (EU) 2016/679, applies from 25 May 2018)

Any entity processing personal data of EU/EEA residents

Lawful basis for payment data processing; data minimisation; right to erasure (conflicts with transaction record retention under AML, tax and card scheme rules — must be architecturally resolved); data residency; breach notification within 72 hours

EU national data protection authorities (DPAs)

DORA

Digital Operational Resilience Act (Regulation (EU) 2022/2554, applies from 17 January 2025)

Financial entities and ICT service providers in the EU from 17 January 2025

ICT risk management framework; incident reporting; third-party ICT provider oversight; penetration testing (TLPT); digital operational resilience testing

EU national supervisory authorities; ESAs

SOC 2 Type II

System and Organization Controls 2 (AICPA 2017 Trust Services Criteria, revised points of focus 2022)

Service providers handling customer data (US-centric; increasingly required globally)

Security, availability, processing integrity, confidentiality, and privacy trust service criteria; annual audit by CPA firm; required by enterprise clients as contract condition

AICPA; required by enterprise customers, not regulators

ISO/IEC 27001

Global; particularly required for EU, UK, APAC enterprise clients

Information security management system (ISMS) covering risk assessment, security controls, incident management, and continuous improvement; complements PCI DSS

Accredited certification bodies; ISO

PCI PIN / P2PE

PCI PIN Security / Point-to-Point Encryption (current versions in the PCI SSC Document Library)

Card-present, PIN-accepting payment gateways and terminal integrations

Secure PIN entry device (PED) standards; encrypted PIN blocks; P2PE solutions reduce PCI DSS scope for merchants by encrypting card data at point of interaction

PCI SSC (Security Standards Council)

Full Name

Payment Card Industry Data Security Standard (v4.0.1, published June 2024)

Payment Services Directive 2 (Directive (EU) 2015/2366, applies from 13 January 2018; SCA rules under Delegated Regulation (EU) 2018/389, from 14 September 2019)

General Data Protection Regulation (Regulation (EU) 2016/679, applies from 25 May 2018)

Digital Operational Resilience Act (Regulation (EU) 2022/2554, applies from 17 January 2025)

System and Organization Controls 2 (AICPA 2017 Trust Services Criteria, revised points of focus 2022)

PCI PIN Security / Point-to-Point Encryption (current versions in the PCI SSC Document Library)

Applies To

Any entity storing, processing, or transmitting cardholder data

Payment service providers operating in the EU/EEA

Any entity processing personal data of EU/EEA residents

Financial entities and ICT service providers in the EU from 17 January 2025

Service providers handling customer data (US-centric; increasingly required globally)

Global; particularly required for EU, UK, APAC enterprise clients

Card-present, PIN-accepting payment gateways and terminal integrations

Key Gateway Requirements

12 requirements covering network security, encryption, access control, monitoring, and penetration testing; annual validation based on merchant/service provider level

Strong Customer Authentication (SCA) for online card payments; 3DS2 implementation; SCA exemptions (low-value, transaction risk analysis); open banking API obligations for account-holding banks, not card gateways

Lawful basis for payment data processing; data minimisation; right to erasure (conflicts with transaction record retention under AML, tax and card scheme rules — must be architecturally resolved); data residency; breach notification within 72 hours

ICT risk management framework; incident reporting; third-party ICT provider oversight; penetration testing (TLPT); digital operational resilience testing

Security, availability, processing integrity, confidentiality, and privacy trust service criteria; annual audit by CPA firm; required by enterprise clients as contract condition

Information security management system (ISMS) covering risk assessment, security controls, incident management, and continuous improvement; complements PCI DSS

Secure PIN entry device (PED) standards; encrypted PIN blocks; P2PE solutions reduce PCI DSS scope for merchants by encrypting card data at point of interaction

Enforced By

Card schemes (Visa, Mastercard, Amex) via acquiring banks

EU national competent authorities; EBA guidelines

EU national data protection authorities (DPAs)

EU national supervisory authorities; ESAs

AICPA; required by enterprise customers, not regulators

Accredited certification bodies; ISO

PCI SSC (Security Standards Council)

The most common conflict sits between two individually correct requirements: GDPR’s right to erasure assumes data can be deleted on request; AML laws, tax rules and card scheme dispute rules require transaction records to be retained. PCI DSS itself pushes the other way, requiring card data to be deleted once it is no longer needed. 

This is a data-modeling problem, as personal data and transaction records need separable structures so erasure on one doesn’t break retention on the other. Teams that skip this at the schema stage usually find out the hard way post-launch, see data security in fintech applications for how this plays out at the data layer.

Technical Security Requirements: What Each Standard Actually Mandates

Each payment gateway security standard in the comparison table above translates into specific technical controls at the gateway level — this section maps those controls to the requirement that mandates them.

Security Control
Technical Specification
Mandated By
Consequence of Non-Compliance

Encryption in transit

TLS 1.2 minimum; TLS 1.3 strongly recommended; all legacy SSL and TLS 1.0/1.1 disabled

PCI DSS 4.0.1 Req 4; GDPR Art. 32; ISO 27001

PCI DSS non-compliance; GDPR fine up to €10 million or 2% of global annual turnover for security failures under Art. 32

Encryption at rest

AES-256 for stored cardholder data; encryption keys managed separately from encrypted data; key rotation policy documented

PCI DSS 4.0.1 Req 3; ISO 27001; SOC 2

PCI DSS Level 1 audit failure; SOC 2 report qualification; loss of enterprise contracts requiring SOC 2

Tokenization

Full PAN replaced with token before any storage or logging; token vault isolated from application; network tokenization (EMVCo) for recurring payments

PCI DSS 4.0.1 Req 3 (scope reduction); card scheme network tokenization standards

Without tokenization, all application systems are in PCI DSS scope, multiplying compliance cost and complexity

Strong Customer Authentication (SCA)

3DS2 implementation for all CNP transactions in PSD2 scope; two-factor authentication combining possession + knowledge or inherence; exemptions for low-value and low-risk transactions

PSD2 RTS on SCA; EU national competent authority guidelines

Under card scheme rules, the merchant bears chargeback cost for fraud on unauthenticated transactions; PSP regulatory fine for systematic SCA bypass

Access control

Role-based access control (RBAC); MFA on all CDE access; least-privilege principle; quarterly access review; service account permission audit

PCI DSS 4.0.1 Req 7 & 8; SOC 2; DORA ICT risk framework

PCI DSS audit finding; SOC 2 trust criteria failure; DORA ICT risk management deficiency

Audit logging and monitoring

All payment events logged with timestamp, actor, action, outcome; tamper-evident logs; 12-month retention (3 months immediately available); real-time anomaly alerting

PCI DSS 4.0.1 Req 10; DORA incident reporting; GDPR breach notification

PCI DSS non-compliance; DORA incident reporting failure (staged reporting deadlines for major ICT incidents); GDPR breach notification failure

Penetration testing

Annual internal and external penetration tests by a qualified, organizationally independent tester, repeated after significant changes; payment-specific scope (API, business logic, 3DS2, tokenization); all critical/high findings remediated before next assessment

PCI DSS 4.0.1 Req 11; DORA TLPT (Threat-Led Penetration Testing) for in-scope financial entities

PCI DSS non-compliance; DORA TLPT deficiency for regulated financial entities in EU

Vulnerability management

Quarterly ASV scans (PCI DSS); internal vulnerability scanning; critical and high-security patches installed within one month; OWASP Top 10 coverage in application security testing

PCI DSS 4.0.1 Req 6 & 11; ISO 27001; SOC 2

PCI DSS quarterly scan failure; ISO 27001 nonconformity; open vulnerabilities found in SOC 2 audit

Technical Specification

TLS 1.2 minimum; TLS 1.3 strongly recommended; all legacy SSL and TLS 1.0/1.1 disabled

AES-256 for stored cardholder data; encryption keys managed separately from encrypted data; key rotation policy documented

Full PAN replaced with token before any storage or logging; token vault isolated from application; network tokenization (EMVCo) for recurring payments

3DS2 implementation for all CNP transactions in PSD2 scope; two-factor authentication combining possession + knowledge or inherence; exemptions for low-value and low-risk transactions

Role-based access control (RBAC); MFA on all CDE access; least-privilege principle; quarterly access review; service account permission audit

All payment events logged with timestamp, actor, action, outcome; tamper-evident logs; 12-month retention (3 months immediately available); real-time anomaly alerting

Annual internal and external penetration tests by a qualified, organizationally independent tester, repeated after significant changes; payment-specific scope (API, business logic, 3DS2, tokenization); all critical/high findings remediated before next assessment

Quarterly ASV scans (PCI DSS); internal vulnerability scanning; critical and high-security patches installed within one month; OWASP Top 10 coverage in application security testing

Mandated By

PCI DSS 4.0.1 Req 4; GDPR Art. 32; ISO 27001

PCI DSS 4.0.1 Req 3; ISO 27001; SOC 2

PCI DSS 4.0.1 Req 3 (scope reduction); card scheme network tokenization standards

PSD2 RTS on SCA; EU national competent authority guidelines

PCI DSS 4.0.1 Req 7 & 8; SOC 2; DORA ICT risk framework

PCI DSS 4.0.1 Req 10; DORA incident reporting; GDPR breach notification

PCI DSS 4.0.1 Req 11; DORA TLPT (Threat-Led Penetration Testing) for in-scope financial entities

PCI DSS 4.0.1 Req 6 & 11; ISO 27001; SOC 2

Consequence of Non-Compliance

PCI DSS non-compliance; GDPR fine up to €10 million or 2% of global annual turnover for security failures under Art. 32

PCI DSS Level 1 audit failure; SOC 2 report qualification; loss of enterprise contracts requiring SOC 2

Without tokenization, all application systems are in PCI DSS scope, multiplying compliance cost and complexity

Under card scheme rules, the merchant bears chargeback cost for fraud on unauthenticated transactions; PSP regulatory fine for systematic SCA bypass

PCI DSS audit finding; SOC 2 trust criteria failure; DORA ICT risk management deficiency

PCI DSS non-compliance; DORA incident reporting failure (staged reporting deadlines for major ICT incidents); GDPR breach notification failure

PCI DSS non-compliance; DORA TLPT deficiency for regulated financial entities in EU

PCI DSS quarterly scan failure; ISO 27001 nonconformity; open vulnerabilities found in SOC 2 audit

Payment Gateway Security Architecture

The technical requirements above describe what each standard demands. Payment gateway security architecture is how those demands become a system design. Most of a gateway’s audit scope, and most of its compliance cost, is decided by how a few layers are arranged: where card data enters, where it is replaced with a token, which systems can reach it, and how keys and logs are managed. Get these layers right at the design stage, and most controls in the table above follow from the architecture rather than being added afterward.

A secure gateway is typically built in five layers.

Tokenization

Tokenization is the layer that shrinks PCI DSS scope the most. The full card number (PAN) is replaced with a token as early in the flow as possible, ideally before it reaches any application server, so downstream systems such as order management, analytics, CRM and support tools only ever handle tokens. The token vault that maps tokens back to PANs is isolated in its own segment, with access restricted to a small set of services. For recurring and stored-credential payments, network tokens (EMVCo) issued by the card schemes can replace gateway-generated tokens, which also makes stored cards portable between providers.

Encryption

Card data and sensitive authentication data are encrypted everywhere they move or rest:

  • In transit: TLS 1.2 or higher on every connection, including internal service-to-service traffic inside the cardholder data environment (CDE).
  • At rest: strong cryptography such as AES-256 for any stored PAN.

Encryption doesn’t remove systems from PCI DSS scope on its own. Its value depends entirely on how the keys are managed, which is the next layer.

Network Segmentation

Segmentation separates the CDE from everything else. The perimeter sits at the outer edge: a web application firewall and API gateway filter traffic before it reaches payment services. Inside, firewalls and network policies allow only the connections the payment flow needs. PCI DSS doesn’t require segmentation, but without it, every connected system falls into scope. With it, the audit can focus on the segment that actually handles card data. Segmentation controls must be tested regularly to prove they work, as covered in the testing section below.

Key Management

Encryption keys are stored and used separately from the data they protect, typically in a hardware security module (HSM) or a cloud key management service backed by HSMs. Keys are generated, rotated, revoked and retired under documented procedures. No single person can access a complete key (split knowledge and dual control), and only the services that need decryption have permission to request it.

Monitoring and Logging

Every access to card data and every administrative action is logged with the actor, time, action and outcome, in tamper-evident storage. Logs feed a SIEM that alerts on anomalies in real time, alongside intrusion detection at the CDE boundary. This layer is what turns a suspected incident into evidence, and it supports the incident reporting deadlines under GDPR and DORA.

How the Layers Map to Requirements

Architecture layer
What it does
Effect on compliance scope
Key requirements

Tokenization

Replaces PANs with tokens before downstream systems see them

Removes most application systems from PCI DSS scope

PCI DSS Req. 3; EMVCo network tokenization

Encryption

Protects data in transit and at rest

Required for any system that still handles card data

PCI DSS Req. 3, 4; GDPR Art. 32

Network segmentation

Isolates the CDE; filters traffic at the edge

Limits audit scope to the CDE segment

PCI DSS Req. 1, 6.4, 11.4.5

Key management

Controls the key lifecycle in HSMs or a KMS

Determines whether encryption actually protects data

PCI DSS Req. 3.6, 3.7

Monitoring and logging

Records and alerts on all CDE activity

Provides audit evidence and incident detection

PCI DSS Req. 10, 11.5; DORA incident reporting; GDPR Art. 33

What it does

Replaces PANs with tokens before downstream systems see them

Protects data in transit and at rest

Isolates the CDE; filters traffic at the edge

Controls the key lifecycle in HSMs or a KMS

Records and alerts on all CDE activity

Effect on compliance scope

Removes most application systems from PCI DSS scope

Required for any system that still handles card data

Limits audit scope to the CDE segment

Determines whether encryption actually protects data

Provides audit evidence and incident detection

Key requirements

PCI DSS Req. 3; EMVCo network tokenization

PCI DSS Req. 3, 4; GDPR Art. 32

PCI DSS Req. 1, 6.4, 11.4.5

PCI DSS Req. 3.6, 3.7

PCI DSS Req. 10, 11.5; DORA incident reporting; GDPR Art. 33

Taken together, these layers are the payment gateway security features auditors and enterprise clients look for first. They’re also where most payment gateway security problems originate when one layer is designed in isolation from the others.

Payment Gateway Security Testing

Payment gateway security testing confirms that the controls a gateway is built with actually hold up against attack, and it produces the evidence auditors ask for. PCI DSS sets the minimum: quarterly vulnerability scans and annual penetration tests, repeated after any significant change. A gateway also needs testing for risks that generic scans miss, such as payment business logic, tokenization boundaries and authentication flows.

Testing typically covers six areas:

  • Vulnerability scanning. Internal and external scans at least every three months. External scans must be run by a PCI SSC Approved Scanning Vendor (ASV). Both are repeated after significant changes to the environment.
  • Penetration testing. Internal and external tests at least every 12 months and after significant changes, following a documented methodology. For a gateway, the scope should explicitly include APIs, payment business logic, tokenization and 3DS2 flows, not only network infrastructure.
  • Segmentation testing. This confirms that systems outside the cardholder data environment can’t reach it. PCI DSS requires this annually for merchants and every six months for service providers.
  • Application security testing. Static and dynamic testing in the development pipeline, covering the OWASP Top 10 and the OWASP API Security Top 10. This catches payment gateway security issues such as broken object-level authorization or injection before they reach production.
  • Payment page protection. Under PCI DSS v4.0.1, scripts on payment pages must be inventoried and authorized, and unauthorized changes to the page must be detected. This guards against card-skimming attacks that inject malicious JavaScript into checkout.
  • Authentication and resilience testing. This covers 3DS2 challenge, frictionless, exemption and fallback flows, tested in the card scheme or provider sandbox before release. EU financial entities under DORA also need a digital operational resilience testing program, and some are required to run Threat-Led Penetration Testing (TLPT) at least every three years.

Payment Gateway Security Testing Checklist

The payment gateway security testing checklist below maps each test to its frequency and the requirement behind it. Use it to plan the testing calendar and check that each payment gateway security control has evidence ready for audit.

Test area
What to test
Frequency / trigger
Required by

External vulnerability scan

Internet-facing systems in or connected to the CDE

Every 3 months and after significant changes; must be run by an ASV

PCI DSS Req. 11.3.2

Internal vulnerability scan

Internal systems in the CDE; high-risk and critical findings resolved and rescanned

Every 3 months and after significant changes

PCI DSS Req. 11.3.1

External penetration test

Perimeter, public APIs, payment endpoints

Every 12 months and after significant changes

PCI DSS Req. 11.4.3

Internal penetration test

CDE systems, lateral movement, privilege escalation

Every 12 months and after significant changes

PCI DSS Req. 11.4.2

Segmentation test

Isolation of the CDE from out-of-scope networks

Every 12 months; every 6 months for service providers

PCI DSS Req. 11.4.5, 11.4.6

API security test

Authentication, object-level authorization, rate limiting, input validation

Every release; included in pen test scope

PCI DSS Req. 6.2.4; OWASP API Security Top 10

Payment business logic

Amount tampering, replayed or duplicate transactions, refund abuse, currency manipulation

Every release affecting payment flows

PCI DSS Req. 6.2.4

Tokenization boundary

No full PAN in logs, databases, error messages or analytics; token vault isolated

Every release; annually in pen test scope

PCI DSS Req. 3

Payment page scripts

Inventory and authorization of scripts; tamper detection on the checkout page

Ongoing monitoring

PCI DSS Req. 6.4.3, 11.6.1

3DS2 / SCA flows

Challenge, frictionless, exemption and fallback paths

Before release; after any change to the authentication flow

PSD2 RTS on SCA; card scheme 3DS requirements

Resilience and TLPT

Failover, recovery, threat-led testing of critical functions

Per testing program; TLPT at least every 3 years where required

DORA Arts. 24–26

What to test

Internet-facing systems in or connected to the CDE

Internal systems in the CDE; high-risk and critical findings resolved and rescanned

Perimeter, public APIs, payment endpoints

CDE systems, lateral movement, privilege escalation

Isolation of the CDE from out-of-scope networks

Authentication, object-level authorization, rate limiting, input validation

Amount tampering, replayed or duplicate transactions, refund abuse, currency manipulation

No full PAN in logs, databases, error messages or analytics; token vault isolated

Inventory and authorization of scripts; tamper detection on the checkout page

Challenge, frictionless, exemption and fallback paths

Failover, recovery, threat-led testing of critical functions

Frequency / trigger

Every 3 months and after significant changes; must be run by an ASV

Every 3 months and after significant changes

Every 12 months and after significant changes

Every 12 months and after significant changes

Every 12 months; every 6 months for service providers

Every release; included in pen test scope

Every release affecting payment flows

Every release; annually in pen test scope

Ongoing monitoring

Before release; after any change to the authentication flow

Per testing program; TLPT at least every 3 years where required

Required by

PCI DSS Req. 11.3.2

PCI DSS Req. 11.3.1

PCI DSS Req. 11.4.3

PCI DSS Req. 11.4.2

PCI DSS Req. 11.4.5, 11.4.6

PCI DSS Req. 6.2.4; OWASP API Security Top 10

PCI DSS Req. 6.2.4

PCI DSS Req. 3

PCI DSS Req. 6.4.3, 11.6.1

PSD2 RTS on SCA; card scheme 3DS requirements

DORA Arts. 24–26

Compliance Scope by Payment Gateway Integration Type

The integration method is itself a compliance decision: the same payment gateway can land in a minimal-scope SAQ A or a full SAQ D assessment depending entirely on how card data flows through it.

Integration Type
PCI DSS SAQ
Scope
Key Compliance Implication

Hosted Payment Page (redirect)

SAQ A

Minimal

Card data never touches your servers; the provider handles PCI DSS. Easiest compliance path. GDPR still applies to user data collected at checkout.

iFrame / Embedded Form

SAQ A (provider-hosted iFrame) or SAQ A-EP (merchant-created form)

Minimal–Low

If the iFrame is fully hosted by a PCI DSS-compliant provider, the merchant is generally SAQ A-eligible, provided its site is protected against script-based attacks on the payment page. If the merchant’s own page creates or posts the payment form (direct post or JavaScript form), SAQ A-EP applies and the page’s script security is in scope.

Server-to-Server API

SAQ D or Level 1 ROC

Full

Card data passes through your servers. Full PCI DSS scope applies: all 12 requirement domains. Highest compliance cost and complexity. Network tokenization can reduce scope post-integration.

Mobile SDK Integration

SAQ A (if tokenized SDK) or SAQ D

Low or Full

Depends on the tokenization model. If SDK tokenizes before data reaches the app server: SAQ A equivalent. If the app handles raw PAN: full SAQ D scope. Clarify with the SDK provider before architecture design.

Payment Orchestration Layer

SAQ D or Level 1 ROC

Full + multi-provider

Each provider in the orchestration layer must be independently PCI DSS compliant (AOC required). The orchestration layer itself is in full scope. Token portability between providers must be architecturally solved.

Integration Type

Hosted Payment Page (redirect)

iFrame / Embedded Form

Server-to-Server API

Mobile SDK Integration

Payment Orchestration Layer

PCI DSS SAQ

SAQ A

SAQ A (provider-hosted iFrame) or SAQ A-EP (merchant-created form)

SAQ D or Level 1 ROC

SAQ A (if tokenized SDK) or SAQ D

SAQ D or Level 1 ROC

Scope

Minimal

Minimal–Low

Full

Low or Full

Full + multi-provider

Key Compliance Implication

Card data never touches your servers; the provider handles PCI DSS. Easiest compliance path. GDPR still applies to user data collected at checkout.

If the iFrame is fully hosted by a PCI DSS-compliant provider, the merchant is generally SAQ A-eligible, provided its site is protected against script-based attacks on the payment page. If the merchant’s own page creates or posts the payment form (direct post or JavaScript form), SAQ A-EP applies and the page’s script security is in scope.

Card data passes through your servers. Full PCI DSS scope applies: all 12 requirement domains. Highest compliance cost and complexity. Network tokenization can reduce scope post-integration.

Depends on the tokenization model. If SDK tokenizes before data reaches the app server: SAQ A equivalent. If the app handles raw PAN: full SAQ D scope. Clarify with the SDK provider before architecture design.

Each provider in the orchestration layer must be independently PCI DSS compliant (AOC required). The orchestration layer itself is in full scope. Token portability between providers must be architecturally solved.

SAQ type has to be determined before architecture is finalized, not discovered partway through the build. A team that starts a server-to-server API integration assuming SAQ A applies typically finds out mid-build that they’re actually in full SAQ D scope — at which point the fix isn’t a config change, it’s a rearchitecture.

See the PCI DSS compliance checklist for what each SAQ level actually requires to pass.

If you’re still choosing an integration method, our payment gateway integration services cover each option, and our payment gateway development team can help match the method to your compliance scope before the build starts.

Regional Compliance Requirements for Payment Gateways

Choosing the right payment gateway partner will help you navigate which of these obligations apply to your markets before they shape your architecture. Beyond PCI DSS, each market adds its own rules on authentication, personal data and operational resilience. The table below lists the frameworks that apply in the main regions and the gateway-specific obligations each one creates.

Region
Applicable Frameworks (beyond PCI DSS)
Key Gateway-Specific Obligations

European Union / EEA

PSD2 (2015/2366, from 13 January 2018), GDPR (2016/679, from 25 May 2018), DORA (2022/2554, from 17 January 2025)

SCA/3DS2 required for CNP transactions unless an exemption applies; open banking API obligations for account-holding banks; DORA ICT risk management and TLPT for financial entities; GDPR data residency and breach notification

United Kingdom (post-Brexit)

SCA required under UK PSRs (mirroring PSD2 SCA); UK GDPR data residency separate from EU GDPR post-Brexit; FCA authorisation required for payment service provision

United States

No federal payments data law; CCPA (in effect from 1 January 2020, amended by CPRA from 1 January 2023); FinCEN AML requirements under the Bank Secrecy Act; Reg E (12 CFR Part 1005)

PCI DSS is primary framework; CCPA applies to California residents’ data; FinCEN AML/KYC for money transmission; Reg E for consumer dispute rights; no federal equivalent to GDPR

Australia

Privacy Act 1988 (Australian Privacy Principles); APRA CPS 234 (effective 1 July 2019); ePayments Code (ASIC, current version from 2 June 2022)

Privacy Act governs payment data handling; APRA CPS 234 for financial institutions on information security; ePayments Code covers consumer liability for unauthorised transactions

Singapore / APAC

PDPA 2012 (Singapore); MAS TRM Guidelines (January 2021); local payment system acts by jurisdiction

MAS Technology Risk Management Guidelines mandate security controls for financial institutions; PDPA governs personal data; cross-border data transfer restrictions vary by country

Applicable Frameworks (beyond PCI DSS)

PSD2 (2015/2366, from 13 January 2018), GDPR (2016/679, from 25 May 2018), DORA (2022/2554, from 17 January 2025)

No federal payments data law; CCPA (in effect from 1 January 2020, amended by CPRA from 1 January 2023); FinCEN AML requirements under the Bank Secrecy Act; Reg E (12 CFR Part 1005)

Privacy Act 1988 (Australian Privacy Principles); APRA CPS 234 (effective 1 July 2019); ePayments Code (ASIC, current version from 2 June 2022)

PDPA 2012 (Singapore); MAS TRM Guidelines (January 2021); local payment system acts by jurisdiction

Key Gateway-Specific Obligations

SCA/3DS2 required for CNP transactions unless an exemption applies; open banking API obligations for account-holding banks; DORA ICT risk management and TLPT for financial entities; GDPR data residency and breach notification

SCA required under UK PSRs (mirroring PSD2 SCA); UK GDPR data residency separate from EU GDPR post-Brexit; FCA authorisation required for payment service provision

PCI DSS is primary framework; CCPA applies to California residents’ data; FinCEN AML/KYC for money transmission; Reg E for consumer dispute rights; no federal equivalent to GDPR

Privacy Act governs payment data handling; APRA CPS 234 for financial institutions on information security; ePayments Code covers consumer liability for unauthorised transactions

MAS Technology Risk Management Guidelines mandate security controls for financial institutions; PDPA governs personal data; cross-border data transfer restrictions vary by country

Compliance Built In vs Compliance Retrofitted: The Cost Difference

Compliance decisions are architecture decisions, and the timing of those decisions determine what they cost.

Compliance Decision
Built-In (at architecture stage)
Retrofitted (post-launch)

PCI DSS scope definition

SAQ type chosen before integration design; scope minimised by architecture (hosted page or tokenization from day one)

Scope discovered during first audit; architecture changes required to reduce scope; the API integration has to be rebuilt to add tokenization

GDPR vs PCI DSS data separation

Personal data and transaction records stored in separate schemas with separate access controls and retention policies from initial data model design

Data is co-mingled; separating post-launch requires data migration, schema redesign, and re-testing: 6–10 weeks

3DS2 / SCA implementation

3DS2 designed into payment flow from the start; exemption logic, challenge flows, and liability shift handling all tested pre-launch

3DS2 has to be added to a live payment flow, with a risk of breaking existing checkout conversion during rollout

Audit logging infrastructure

Tamper-evident logging of all payment events from first transaction; retention policy configured; SIEM integration in place

Retrofitting audit logs to cover historical transactions: impossible for past transactions; future coverage requires infrastructure work: 2–4 weeks plus historical gap in PCI DSS compliance

Built-In (at architecture stage)

SAQ type chosen before integration design; scope minimised by architecture (hosted page or tokenization from day one)

Personal data and transaction records stored in separate schemas with separate access controls and retention policies from initial data model design

3DS2 designed into payment flow from the start; exemption logic, challenge flows, and liability shift handling all tested pre-launch

Tamper-evident logging of all payment events from first transaction; retention policy configured; SIEM integration in place

Retrofitted (post-launch)

Scope discovered during first audit; architecture changes required to reduce scope; the API integration has to be rebuilt to add tokenization

Data is co-mingled; separating post-launch requires data migration, schema redesign, and re-testing: 6–10 weeks

3DS2 has to be added to a live payment flow, with a risk of breaking existing checkout conversion during rollout

Retrofitting audit logs to cover historical transactions: impossible for past transactions; future coverage requires infrastructure work: 2–4 weeks plus historical gap in PCI DSS compliance

Compliance work done at the architecture stage is part of the build. Done after launch, the same work means rebuilding live systems, migrating production data and re-testing payment flows, with the regulatory exposure and reputational risk left open during the gap. The how to build a payment gateway guide breaks down where these decisions sit in the broader build sequence.

Key Takeaways

  • Payment gateway compliance spans multiple overlapping frameworks: PCI DSS applies globally; PSD2, GDPR, and DORA apply in the EU; regional frameworks (UK PSRs, MAS TRM, APRA CPS 234) add jurisdiction-specific requirements.
  • PCI DSS scope is determined by integration method: a hosted payment page qualifies for SAQ A (minimal scope), while a server-to-server API integration requires full SAQ D or Level 1 ROC assessment.
  • The most common architectural conflict is GDPR’s right to erasure vs. transaction record retention required by AML, tax and card scheme rules — resolving this requires storing personal data and transaction records in separately governed schemas from the start.
  • 3DS2 is the technical implementation of PSD2’s Strong Customer Authentication requirement; under card scheme rules, authenticated transactions also shift fraud liability from merchant to issuer.
  • Compliance decided at the architecture stage is built in once; retrofitted after launch, it means rebuilding live integrations, migrating production data and re-testing payment flows while the compliance gap stays open.
  • SOC 2 Type II and ISO 27001 are not regulatory requirements but are increasingly mandated by enterprise clients as contract conditions for payment processing partnerships.
  • DORA (effective 17 January 2025) adds ICT risk management, incident reporting, and Threat-Led Penetration Testing requirements for EU financial entities — gateway providers serving regulated clients are affected through their clients’ contracts.

FAQ

  • What compliance standards apply to payment gateways?

    PCI DSS applies to every gateway that stores, processes or transmits card data. In the EU and EEA, PSD2 adds strong customer authentication, GDPR governs personal data, and DORA sets ICT resilience requirements for financial entities. SOC 2 and ISO/IEC 27001 are not legal requirements, but enterprise clients often make them a contract condition. Card-present integrations also fall under PCI PIN and P2PE. Regional frameworks such as the UK PSRs, MAS TRM Guidelines and APRA CPS 234 add jurisdiction-specific obligations on top.