Why Do Organizations Keep Failing Quarterly ASV Scans?

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During a recent investigation, we discovered that a major e-commerce company had a critical misconfiguration on its web server. This vulnerability enabled attackers to inject malicious code into the website, allowing them to intercept customer payment data during transactions. The root cause? It missed a quarterly ASV scan, which would likely have identified the issue before it was exploited.

Misconfigurations like this are not unique to one company; they may pose a serious risk to any organization handling cardholder data.

Unfolding PCI DSS Expectation vs Real-World Scenario

The Payment Card Industry Data Security Standard (PCI DSS) mandates that organizations carry out and document recurring security activities, which must be reviewed by a Qualified Security Assessor (QSA) during the annual compliance assessment. A key part of these activities is the ASV (Approved Scanning Vendor) scan that is performed quarterly. These scans are intended to protect cardholder data by periodically identifying and addressing vulnerabilities in internet-facing systems. They are a clearly defined requirement under the PCI DSS standard.

As per the payment security standard council, the expectation is straightforward, requiring organizations to conduct a scan using an ASV every 90 days, or after significant changes are done in the CDE environment, to identify and remediate any issues and submit a passing report. Additionally, it is necessary that organizations must pass the ASV scan activities to maintain compliance. A failed scan is not acceptable for compliance purposes; therefore, if the initial scan fails, the organization is required to perform remediation and conduct subsequent rescans until a passing result is achieved.

Despite these well-defined requirements, many organizations consistently fail to conduct these scans on time. Failure to perform these tasks results in non-compliance or an unsuccessful/invalid Report on Compliance (RoC).

This situation highlights a deeper disconnect between compliance intention and operational reality.

While PCI SSC enforces strict requirements, with assessors requiring clear evidence for PCI DSS v4.0.1 , many organizations struggle to keep up due to competing priorities. As per the PCI DSS Requirement 11.3.2, organizations are required to perform external ASV scan at least quarterly and after any significant changes are done to the cardholder data environment (CDE). However, we found many organizations not following this important requirement.

In addition, organizations lack streamlined processes because they did not fully understand the technical and logistical nuances of ASV scanning.

This results in:

• Missed scan windows
• Failed submissions
• Rushed remediation efforts with chances of missing some spots
• A scramble during audits to produce valid reports

This gap not only poses challenges for PCI DSS compliance but also heightens overall security risk, providing ample opportunity for attackers.

Common ASV Scan Mistakes That Organizations Make

Usually, ASV scans focus on:

• External-facing IP addresses
• Domains associated with your e-commerce environment
• Systems that could impact the security of payment transactions
• Web applications that facilitate payment processing

These help organizations detect vulnerabilities or weaknesses in applications, infrastructure, configurations, as well as software components.

However, the challenge arises when it comes to understanding them technically and their deeper issues. Eventually, this leads to failed ASV scans as well as recurring vulnerabilities.

Some of the common pitfalls are:

Use of insecure or legacy services	– Legacy protocols such as Telnet, FTP, RSH, or outdated SSL/TLS versions. – Unsecured ports left exposed to the internet. – Using default or weak credentials across accounts or services.
Unpatched vulnerabilities	– Leaving known CVEs unpatched. – Delaying in applying recommended security patches. – Using OS or software that has reached end-of-life support.
False positives	– Incorrect vulnerabilities flagged due to unauthenticated scans. – Cached or outdated scans.
Incomplete scan scope	– Missing IPs or subnets – Misunderstanding the scope requirement – Required assets not accounted for.
Recurring issues not remediated	– No formal tracking or validation of fixes before the next review. – Repeated vulnerabilities showing up in multiple quarters.
Improper scans	– Incorrect scans that miss critical checks. – Poorly scheduled scans that miss PCI’s quarterly deadline.

The need to balance a strict compliance schedule with daily operational demands and technical missteps often leads to missed or failed quarterly ASV scans.

Choose the Right ASV to Navigate the Challenges

For organizations aiming to maintain PCI DSS compliance, selecting the right ASV is more than a checkbox. The right ASV not only helps the organization meet PCI DSS requirements but also acts as a strategic partner by eliminating the hassle of quarterly scans and providing in-depth expertise.

When evaluating potential ASVs, organizations must look beyond basic scanning capabilities. These include:

• They are certified by the PCI SSC.
• They offer a deep level of experience and expertise in conducting external vulnerability scans.
• Their ability to streamline the scanning process.
• Their ability to identify and guide the common scanning mistakes/failures.
• Their ability to have a full understanding of the scanning scope, including the timeline within an organization.
• Their ability to respond & remediate vulnerabilities.
• Their ability to interpret and remove false positives.

How Does Ampcus Cyber as an ASV Stand Out?

Maintaining PCI DSS compliance can be overwhelming, especially when it comes to managing quarterly ASV scans. Ampcus Cyber offers a comprehensive and partner-driven ASV service, helping organizations avoid common pitfalls, streamline compliance, and strengthen their overall security posture.

Here’s how the Ampcus Cyber ASV solution stands out:

• End-to-end scan management: Ampcus Cyber simplifies the entire quarterly scanning process, starting from scheduling to report generation and remediation tracking, thus eliminating guesswork and reducing administrative overhead.
• Accurate and actionable scanning: Ampcus Cyber offers the right ASV scan solutions through authenticated scanning (where applicable) and up-to-date vulnerability signatures, thus minimizing false positives. This provides clear and prioritized remediation guidance for organizations to act on what truly matters to them.
• Guided scope definition: Ampcus Cyber works closely with the organization to ensure all external-facing assets are accurately included in the scan scope. This helps avoid incomplete or non-compliant scans.
• Remediation support & rescans: Ampcus Cyber doesn’t stop at detection. Our best-in-class experts guide organizations with interpreting results, resolving vulnerabilities, and validating fixes before the next assessment cycle. This ensures no issues are left lingering across quarters.
• Quarterly scheduling: Organizations don’t have to worry about missing a scan. Ampcus Cyber takes away that burden by scheduling the scans and providing support to align the organization’s cadence with PCI DSS timelines. This prevents rush-minute compliance gaps.
• Expert Support & Dispute Assistance: If a vulnerability is misclassified, Ampcus Cyber’s qualified experts help collect and submit dispute evidence quickly and correctly. We act as a compliance ally and not just a scan provider.

With Ampcus Cyber as your ASV partner, you gain more than a compliance tool. You gain a cybersecurity advisor focused on helping you pass every scan with confidence, while also boosting your real-world security.

Contact Ampcus Cyber today to schedule your next ASV scan or request a consultation. Let us help you stay secure, stay compliant, and stay ahead.

Frequently Asked Questions About ASV Scan

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