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A PCI DSS Approved Scanning Vendor (ASV) scan and an internal vulnerability scan serve different purposes. Where PCI DSS requires an external vulnerability scan, it must be performed by a PCI SSC-listed ASV using that vendor’s ASV scan solution. Internal scanning helps an organization identify and manage weaknesses inside its environment; having an internal scanner does not replace the required ASV scan, and neither activity by itself proves overall PCI DSS compliance.
What’s the difference between an ASV scan and an internal vulnerability scan?
“ASV” describes a PCI SSC qualification and service role for applicable external vulnerability scanning. “Internal vulnerability scanning” describes an activity: checking systems within the organization’s internal environment and applicable PCI scope. It may be performed by qualified internal staff or an appropriate external provider; ASV status is not what defines an internal scan.
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| Comparison | External ASV scan | Internal vulnerability scan |
|---|---|---|
| Scope | Internet-facing systems included in the applicable PCI DSS external-scan scope. | Systems inside the organization’s internal environment and applicable PCI scope. |
| Who performs it | A PCI SSC-listed ASV, using that vendor’s ASV scan solution for Requirement 11.3.2. | Qualified internal resources or an appropriate external provider. The cited PCI SSC distinction does not require the provider to be an ASV. |
| Purpose | Produces scan results and evidence for the applicable external-scan requirement. | Provides findings used in vulnerability management and risk-ranking. |
| Frequency | PCI SSC describes the external scan requirement as at least once every three months. Confirm the applicable PCI DSS version and assessment context. | PCI DSS includes internal scanning requirements. The applicable frequency depends on the requirement and version that apply to the entity. |
| What the result establishes | Results of the external vulnerability scan; it does not establish that other PCI DSS requirements have been reviewed or met. | Findings for internal vulnerability management; it does not establish full PCI DSS compliance. |
PCI SSC states that scans used to satisfy Requirement 11.3.2 must use a listed ASV and its ASV scan solution. See the PCI DSS standards overview and FAQ 1604.
Do I need an ASV if I already run an internal vulnerability scanner?
If an external ASV scan applies to your assessment, yes: an internal scanner does not fulfill that requirement. The activities cover different scopes and produce different evidence. Keep internal vulnerability scanning and remediation in your security process, and arrange the applicable external scan through a listed ASV.
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To choose an ASV for the compliance scan, check the PCI SSC program listings and verify that the engagement uses the listed provider’s ASV scan solution. A generic vulnerability scan, an internal tool, or a vendor’s marketing claim is not a substitute for checking those details.
How often are external ASV scans required?
PCI SSC describes applicable external ASV scans as required at least once every three months. This is a compliance frequency, not an estimate of how often organizations scan. Requirements can depend on the applicable PCI DSS version and assessment type, so confirm the current wording and scope for your environment. PCI SSC’s Resource Guide on vulnerability scans and ASVs and FAQ 1572 explain the external-scan context.
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Does SAQ A still require ASV scans if payment processing is outsourced?
Outsourcing payment processing does not by itself settle the question. PCI SSC FAQ 1604, marked June 2026, says PCI DSS v4.x SAQ A can require external ASV scanning for qualifying merchant e-commerce webpages that redirect customers to a third-party payment provider or contain that provider’s embedded payment page or form. Check the current SAQ A eligibility and wording against your actual website and assessment.
Does passing an ASV scan mean I’m PCI compliant?
No. An ASV report documents the vulnerability scan results; it is not a review of every PCI DSS requirement. PCI SSC explains in FAQ 1234 that the report does not indicate that other requirements have been reviewed or are in place. Treat it as evidence for the applicable scan requirement, not as a compliance certificate.
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Does an ASV count as a third-party service provider?
PCI SSC says a company providing ASV services only is not considered a third-party service provider for Requirements 12.8 and 12.9. The entity should still apply its own third-party due diligence process, and other services provided by the same company may change how it is classified. See PCI SSC FAQ 1598.
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