Each of these three regulatory frameworks serves a different purpose, but they share many things in common. Penetration testing requirements are one of the common threads linking these frameworks together, but with specific requirements.
Security leaders navigating compliance initiatives need to choose penetration testing partners that meet those requirements. Knowing exactly what auditors and regulatory authorities are looking for is vital to ensuring a smooth and predictable compliance journey.
PCI-DSS, SOC 2, and FedRAMP Explained
These three compliance frameworks all serve different purposes. Before comparing their penetration testing requirements, it’s important to define exactly what problems each framework is designed to solve.
- PCI-DSS is mandatory for all US businesses that process cardholder data. If your organization wants to process credit card transactions, it will have to demonstrate PCI-DSS compliance first.
- SOC 2 is a voluntary certification standard that focuses on five Trust Services Criteria. It comes in two forms: SOC 2 Type I compliance measures compliance at a specific point in time, while SOC 2 Type II attestation uses regular audits to show continuous compliance.
- FedRAMP is a regulatory requirement for Federal agencies and contractors that use cloud technology to store and process data. Cloud-enabled organizations that want to do business with the US federal government must demonstrate FedRAMP compliance.
How Penetration Testing Fits into Each Regulatory Compliance Framework
Security compliance frameworks serve the same broad goal — proving organizations maintain a secure IT environment, with documented policies and formal incident response workflows. They establish clear guidelines on how to improve overall security risk management.
However, they differ in the ways they meet these goals. Each regulatory framework has its own set of benchmarks, metrics, and verification processes. Security leaders pursuing compliance will have to model their processes around these requirements, especially when it comes to penetration testing.
PCI-DSS Penetration Testing Requirements
The Payment Card Industry Security Standards Council released PCI-DSS 4.0 in March 2022, with an effective implementation date of March 2025. The updated standard includes specific requirements for penetration testing, as defined in PCI-DSS 4.0 section 11.4:
“External and internal penetration testing is regularly performed, and exploitable vulnerabilities and security weaknesses are corrected.”I
It requires organizations to define and implement a documented penetration testing methodology that includes the following:
- Industry-standard penetration testing operations.
- Coverage for the entire cardholder data environment.
- Documented internal and external testing results.
- Application-layer testing to identify specific vulnerabilities listed in section 6.2.4 — like SQL injection, cross-site scripting, and others.
- Network-layer penetration tests for vulnerabilities IT assets and operating systems.
- Retention of penetration testing results and remediations for at least 12 months.
The framework also stipulates requirements about who can conduct penetration testing. While organizations are allowed to run penetration tests internally, the additional requirements make this a feasible option only for large enterprises with a dedicated Security Operations Center (SOC).
Small and mid-sized businesses will find it very difficult to meet PCI-DSS penetration requirements without relying on a managed security service provider. Delegating penetration testing to a dedicated vendor ensures the organization can pursue compliance without compromising its day-to-day security operations.
SOC 2 Penetration Testing Requirements
SOC 2 certification includes vulnerability management standards that revolve around the framework’s five Trust Services Criteria: Security, availability, processing integrity, confidentiality, and privacy.
There is no specific requirement for penetration testing under the SOC 2 framework. However, organizations do have to evaluate internal security controls, communicate deficiencies to stakeholders, and remediate vulnerabilities in a timely manner.
Penetration testing is a reliable and cost-effective way to do that. It gives security leaders the ability to satisfy multiple SOC 2 requirements without having to deploy and monitor different security controls for each one.
For organizations pursuing SOC 2 Type II certification, annual penetration testing offers an accessible solution for evaluating the design of security controls and their operating effectiveness over time.
FedRAMP Penetration Testing Requirements
FedRAMP requires cloud service providers to implement penetration testing or face steep penalties. Unlike many other regulatory frameworks, it doesn’t allow internal specialists to conduct tests and report results.
Instead, your organization must entrust FedRAMP penetration testing to a Third-Party Assessment Organization (3PAO). They are responsible for running tests, compiling results, and reporting them to the Project Management office (PMO).
The FedRAMP program outlines three threat model categories that must be tested for:
- Internet-based threats are typically external to the organization’s cloud infrastructure. They may launch attacks against network infrastructure, users, and applications.
- Corporate threats are tied to the organization’s business operations. These include insider threats, breaches of management, and ransomware attacks that spread from on-premises infrastructure.
- Internal threats come from inside the organization’s cloud computing deployments. These include access management misconfigurations, inadequate security architecture, and ransomware attacks that spread from connected government systems.
It also establishes a specific set of testing methodologies for different attack vectors. Because the framework has such specific requirements, it only recognizes a specific set of authorized 3PAOs. To achieve FedRAMP compliance, your organization must partner with one.
Streamline Compliance with Novawatch
Novawatch gives security leaders a clear roadmap to achieving PCI-DSS, SOC 2, and FedRAMP compliance. In addition to comprehensive penetration testing services, we leverage longstanding partnerships with PCI-DSS approved scanning vendors and FedRAMP 3PAOs to simplify challenging compliance initiatives. Talk to one of our compliance experts to learn more.
