PCI DSS PENETRATION TESTING

Requirement 11 network, application, and segmentation testing plus ASV scan support, with deliverables built for your QSA.

If your organisation stores, processes, or transmits payment card data, PCI DSS applies to you, and so does the testing it requires. Requirement 11 of the standard, "Regularly test security systems and processes", exists because the environment around cardholder data never stands still: new systems are deployed, firewall rules change, wireless networks appear, and vulnerabilities are published daily. A control that was effective at last year's assessment may have broken since, so the standard requires testing on a schedule, with evidence. Most organisations know they must test; the harder part is producing testing that their QSA (Qualified Security Assessor) will accept: correctly scoped to the cardholder data environment (CDE), performed with a recognised methodology, and documented in a form that maps cleanly to the requirement. A report that never mentions segmentation, ignores the CDE boundary, or arrives without retest evidence sends you back for another round, on the assessor's clock, close to your compliance deadline. Our PCI DSS penetration test performs the testing Requirement 11 calls for and delivers the evidence in the shape your QSA needs.

Incognito Lab is your penetration testing partner, not a QSA, and we do not issue your Report on Compliance; your assessor does that. We provide testing scoped the way the standard expects, findings your team can fix, and deliverables an assessor can take at face value. For a plain-language walkthrough of how the standard is structured and who the parties are, our team wrote a primer: an introduction to PCI DSS.

What Requirement 11 asks for

Under the current PCI DSS v4.0.1 standard, Requirement 11 drives four distinct testing activities, each with its own cadence. Our service covers all four:

Wireless access point testing

Testing for the presence of both authorised and unauthorised (rogue) wireless access points, on a quarterly basis. A rogue access point plugged into a CDE-connected network is a direct bridge past your perimeter, which is why the standard insists on looking for them regularly rather than assuming the inventory is accurate.

Network vulnerability scans

Internal and external network vulnerability scans, at least quarterly and after any significant change. The external quarterly scan must be performed by a PCI-approved Approved Scanning Vendor (ASV); the next section covers how we support that. Internal scans verify that the systems inside your environment are patched and configured as the standard requires.

Penetration testing

External penetration testing and internal penetration testing at least annually and after any significant infrastructure or application upgrade or modification. This is where a human tester goes beyond what a scanner reports: chaining weaknesses, validating exploitability, and testing the applications and networks that touch cardholder data the way a real attacker would.

Segmentation testing

Where segmentation is used to isolate the CDE from other networks, the segmentation controls themselves must be penetration tested at least annually and after any change to them. The goal is to verify the segmentation is operational and effective: that systems you have declared out of scope genuinely cannot reach the CDE. Your entire scope-reduction argument, and the assessment cost that follows from it, rests on segmentation actually holding.

If you are unsure which of these applies to your environment, or on what schedule, that is a scoping conversation we have with you before any proposal is written, and anything left out of scope is agreed at that stage.

ASV scan support

The external quarterly vulnerability scan occupies a special position in the standard: it must be run by an Approved Scanning Vendor, a company certified by the PCI Security Standards Council to operate that specific scan. Incognito Lab is not an ASV. We support the process around the scan:

Coordination

We help you set up and schedule the ASV scans, define the external scope correctly, and manage the quarterly cadence so a missed window does not surface at assessment time.

How we work

Under the PCI-specific framing, the underlying tests are the same engagements we run every day: our infrastructure penetration test covers the internal and external network testing, and our web application penetration test covers the applications that store, process, or transmit cardholder data, both scoped to the CDE and its connected systems. Every engagement runs through the same phases:

  1. Scoping

  2. Testing

  3. Reporting

  4. Remediation support & retest

What you get

Deliverables are developed to address what the QSA needs: evidence an assessor can accept for the assessment. Every report contains, at minimum:

Executive summary

The business-level risk picture, suitable for management and your assessor.

Findings by Risk Level

Each issue rated Critical, High, Medium, or Low so remediation can be prioritised objectively.

POC for every finding

The exact steps to reproduce each finding, with requests and evidence.

Remediation guidance

Practical fixes for your environment.

Retest verification

Findings are re-checked after your fixes and the report is updated to reflect closed items, giving your assessor the corrected-and-verified trail the standard expects.

Segmentation test evidence

Where segmentation is in scope, explicit documentation that the controls were tested and that out-of-scope systems could not reach the CDE.

Team credentials

  • OSCP
  • OSCE
  • CREST CRT
  • CREST CPSA
  • GIAC GREM

Testing is performed by our in-house team, with certifications earned through hands-on practical examination. See the full list of certifications the team holds.

Our methodology follows NIST SP800-115 (Technical Guide to Information Security Testing and Assessment), with scope, cadence, and reporting aligned to PCI DSS Requirement 11 under the current v4.0.1 standard.

Infrastructure penetration test

Covers the internal and external network testing.

Web application penetration test

Covers the applications that store, process, or transmit cardholder data, scoped to the CDE and its connected systems.

Consulting

Penetration testing is one requirement among twelve. If you are earlier in the journey, still defining your CDE, or building the broader security programme the standard sits inside (policies, ISMS, ISO/IEC 27001), that work is handled by our consulting team.

Last reviewed: 12 Oct 2026

PCI DSS Penetration Test

Tell us which Requirement 11 activities apply to your environment. We map the CDE with you and propose a plan with a fixed timeline and price.

Frequently asked questions

Do you help us define our CDE scope?

Yes, scoping is where a PCI engagement is won or lost. We map the cardholder data environment (CDE) with you: which systems store, process, or transmit cardholder data, which connect to them, where the segmentation boundaries sit, and which of the four Requirement 11 activities the engagement must cover. We align with your assessment timeline too, so testing and retest both land before your QSA needs the evidence.

What does PCI DSS Requirement 11 require you to test?

Under PCI DSS v4.0.1, Requirement 11 drives four testing activities, each on its own cadence: wireless access point (rogue AP) testing quarterly; internal and external network vulnerability scans at least quarterly and after significant change; external and internal penetration testing at least annually and after significant change; and segmentation testing at least annually (every six months for service providers) where segmentation isolates the CDE. Our service covers all four, with the external quarterly scan executed by an approved ASV that we coordinate.

Will the deliverables be accepted by our QSA?

Deliverables are developed to address what the QSA needs: evidence an assessor can accept. Findings are framed against the requirement each one affects, and retest evidence shows that identified issues were corrected and re-verified, which is part of what your assessor expects to see.

Related articles

Tell us about your cardholder data environment

We map the CDE with you and propose a plan with a fixed timeline and price.

logologo

INCOGNITO LAB CO., LTD.

38 Soi Petchakasem 30, Pak Khlong Phasi Charoen, Phasi Charoen, Bangkok 10160

©2026 Incognito Lab Co., Ltd. All rights reserved

Terms & ConditionsPrivacy Policy