When the PCI SSC released version 1.2 of the standard, some people were concerned that earlier promises that the new version would address server, network and desktop virtualization was not fulfilled in the content of the release. Some merchants, assessors and especially technology providers want to see some clarification of when and how virtualized servers can be PCI compliant. But before the server and security geeks start lighting their torches and getting all “vigilante” on the card brands, let me tell you why I don’t think this will matter.

Virtualization saves money. As a technology, virtualization, particularly server virtualization, is saving retailers money on hardware and IT management. In a down economy, cost reduction trumps compliance. Where virtualized servers and PCI compliance come to blows is PCI DSS 2.2.1, which says only one primary function per server. Because some merchants, assessors and acquirers think “physical server” when they read this standard, some merchants have limited the deployment of server virtualization to the dev/test environment.  Other merchants are making sure not to deploy server virtualization in the cardholder environment.  Still others are deploying virtualized servers for applications with credit card, SSNs and other confidential data, but they are careful not to put applications with different “trust levels” for different levels of access controls on the same physical server. The point is, that if you want to use virtualization to reduce your IT costs, you just need to be careful about what applications you put on what types of servers.

Proof that virtualization is secure. We recently did a webinar on the topic of how do you prove that virtualized servers are secure enough to pass PCI assessments. Based on interviews with over a dozen PCI assessors for the, it’s clear that in over 75 percent of the cases we’ve reviewed, the retailers can prove that their virtualization is sufficiently secure to also be compliant. What is lacking in some cases is the documentation of their procedures. In other cases, the merchants will need to upgrade their other controls, such as their intrusion detection systems and their audit and logging tools. But we’re not talking about wholesale security upgrades. Bottom line, you can prove that virtualization is secure enough to pass PCI audits. But, is it worth the money to do so?

The cost of secure virtualization. One of the issues with virtualization of servers is that many applications and management software tools have not yet been “upgraded” to work with virtualized environments. While security software is the issue for PCI compliance, the actual problem is even broader. Despite how long virtualization has been around, we’re finding that some retailers are being told by their application software vendors that the vendors will not warrant the security and certain functionality of their products in virtualized environments. So the issue is more than just PCI compliance. The issue becomes about reliability, performance and data integrity. The point is that whether to deploy virtualized servers broadly throughout the enterprise should not hinge on PCI compliance. Once the larger application and management issues are addressed to the satisfaction of the head of IT infrastructure, and the controls documentation is put in place, then PCI compliance becomes a minor issue by comparison.

Don’t wait for the standards committee. The fact is, technology always changes faster than standards can be developed and updated.  Does anyone remember the seven layer ISO model?  I do. As a Gartner analyst in the 1980’s and 90’s I still remember how many companies put off making networking changes and keep their internal networks secure, because they wanted to stay in line with the standards. At the same time, the companies that embraced the Internet’s technology “one-upmanship” approach won the day. Focus on providing a reliable, cost-effective IT infrastructure, document your controls, and PCI compliance can be achieved, regardless of what the current version of the standard says.

By the way, if you're a retailer, we want to get you involved in the best practices study we're doing for the National Retail Federation. If you'd like to participate, send me an E-mail at This e-mail address is being protected from spambots. You need JavaScript enabled to view it .