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Start with the scan report: confirm whether it is an internal scan or an external PCI DSS scan, verify the affected asset is in scope, then either fix the confirmed issue or submit a documented dispute through the ASV. For applicable external scans under Requirement 11.3.2, use a PCI SSC Approved Scanning Vendor (ASV), rescan as needed, and retain the evidence. A passing ASV scan is not proof of overall PCI DSS compliance.
First identify what kind of scan failed
The response depends on the scan’s purpose. PCI DSS Requirement 11.3.2 applies to external vulnerability scans performed by a PCI SSC ASV. Internal scans may be required by other controls or by an organization’s security program, but an internal scanner’s report is not a substitute for an applicable ASV scan.
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| Scan or finding | What to do |
|---|---|
| External scan intended to meet Requirement 11.3.2 | Work through the ASV’s process to remediate or dispute the finding, then obtain the required rescan evidence. |
| Internal vulnerability scan | Follow the organization’s vulnerability-management and change-control processes; confirm separately what evidence the assessor requires. |
| Target or scope appears incorrect | Ask the ASV or responsible compliance contact to correct the scope through the documented process. Do not silently remove a host from the scan. |
PCI SSC’s v4.0 SAQ C states that external scans occur at least once every three months, vulnerabilities are resolved, passing-scan requirements in the ASV Program Guide are met, and rescans are performed as needed. Confirm the standard, questionnaire, and validation path that apply to your organization; the exact applicability depends on its circumstances.
Check scope before changing systems
Match the report’s hostname or IP address to the system inventory and the approved scan scope. Establish who owns the affected asset and whether it is part of the cardholder-data environment or otherwise in scope. If an address is stale, shared, or assigned to the wrong system, resolve that with the ASV and the owner of the compliance scope rather than treating the finding as irrelevant.
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Outsourcing payment processing does not automatically remove every scanning obligation. PCI SSC’s 2024 ASV resource guide describes external ASV scan requirements in SAQ A for specified merchant e-commerce systems that host pages redirecting payment transactions to a compliant third-party service provider or embed that provider’s payment form. Check the current questionnaire against the actual payment-page architecture.
Work through the report from finding to resolution
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Capture the finding details
Record the report date and version, scan type, affected hostname or IP, finding identifier, affected service or software version, severity, scanner evidence, and any remediation instructions. Keep the original report so the final disposition can be traced back to the reported issue.
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Validate the evidence
Check the identified host, service, version, and configuration in a controlled manner. Compare the scanner’s proof with the actual system state. If the report does not make clear which component or evidence triggered the finding, ask the ASV for clarification before making a change.
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Fix a confirmed vulnerability
Determine the vendor-supported patch or upgrade, or whether removing an exposed service or correcting a configuration will resolve the issue. Consider dependencies and business impact, apply the change under your organization’s change-control process, and retain the change record and validation evidence. The correct technical fix depends on the specific finding and system; there is no universal patch for a failed scan.
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Rescan the affected target
For an applicable external Requirement 11.3.2 scan, request the ASV rescan needed to verify remediation against the ASV Program Guide’s passing-scan requirements. If the finding remains, use the new report to identify what is still exposed and repeat the fix-and-rescan process.
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Keep a complete evidence trail
Retain the original report, relevant correspondence, approved dispute or exception records, change documentation, and final rescan report. This lets an assessor follow the issue from initial detection to its documented disposition.
When a finding looks wrong, use the ASV dispute process
A scanner result can be disputed when the evidence supports a false positive, a different severity, an applicable compensating control, an exception, or a different report conclusion. PCI SSC’s ASV Program Guide recognizes these kinds of disputes, which must be handled under the ASV’s documented procedures and reflected in the scan reporting.
Send the ASV the evidence relevant to the specific result—for example, details that show the reported software or configuration is not present, or documentation supporting the control being relied on. Do not simply dismiss the finding, change its label, or assume that a compensating control automatically makes the scan pass. Ask the ASV what documentation it requires and how the dispute will appear in the final report.
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If a required scan was missed, do not backdate it
A later scan cannot recreate evidence for a missed period. PCI SSC says periodic controls cannot be performed retroactively or backdated. Complete the corrective action, resume the required cadence, and discuss the gap with the assessor and the entity that accepts your compliance evidence. A successful later scan may inform the assessment, but it is not proof that the missed scan occurred.
Choose an ASV for applicable external scans
PCI SSC describes an ASV as an organization whose scanning services and tools are tested and approved before the provider is added to its approved list. Verify a provider’s current listing when selecting one; approval and availability can change. Coordinate scope and remediation expectations with the ASV before scanning so that the targets and report process match the organization’s validation needs.
What a passing ASV scan does—and does not—show
A passing report is evidence about the scan results, not a finding that every PCI DSS requirement has been met. PCI SSC FAQ 1234, published in June 2025, puts it plainly: “The scan report is not an indication that any other PCI DSS requirements have been reviewed or are in place.” Ask the acquirer, payment brand, or other organization responsible for accepting your compliance validation what additional evidence it needs. For questions beyond the scan findings, consult the assessor responsible for the broader assessment.
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