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No. Completing an external vulnerability scan through an Approved Scanning Vendor (ASV) does not, by itself, make an organization PCI DSS compliant. It is evidence for one applicable control. PCI DSS also requires recurring scans, remediation and rescan evidence, and compliance with all other requirements that apply to the organization.
External and internal scans are separate activities with different performance rules. The overview below focuses on PCI DSS v4.x; confirm the version, validation path, and requirements that apply to your environment.
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How do external ASV scans differ from internal scans?
PCI DSS v4.0 Requirement 11.3.2 covers external vulnerability scans, while Requirement 11.3.1 covers internal scans. Both are required at least once every three months when applicable, but they differ in who may perform them and how findings are handled.
| Requirement | Who performs the scan | Frequency | Resolution and evidence |
|---|---|---|---|
| External, 11.3.2 | A PCI SSC-listed ASV, using the scan solution associated with that ASV. | At least once every three months. | Meet the ASV Program Guide’s passing-scan requirements, resolve vulnerabilities, and rescan as needed to confirm the result. |
| Internal, 11.3.1 | Qualified personnel with reasonable organizational independence from the systems being scanned. An ASV or QSA is not required. | At least once every three months. | Resolve critical- and high-risk vulnerabilities under the entity’s risk-ranking process; rescan to confirm resolution. Keep the scanning tool’s vulnerability information current. |
PCI SSC says ASVs are technically tested for scan performance and reporting, and are subject to annual recertification. Because listing status can change, check the current PCI SSC ASV listing before engaging a provider.
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Who can conduct an internal scan?
A qualified employee or specialist firm may perform internal scanning. The tester must be reasonably independent of the systems being tested; for example, PCI SSC says an internal administrator should not be responsible for scanning their own network. The rules do not require a QSA or ASV for this work.
What findings must be fixed, and how quickly?
Use internal scan results as one input to the vulnerability identification and risk-ranking process under Requirement 6.3.1. Rank findings in light of their impact and your environment rather than automatically adopting an outside severity rating. Resolve critical- and high-risk vulnerabilities. Address lower-ranked vulnerabilities in line with a documented targeted risk analysis; addressing may mean fixing the issue or mitigating it another way, such as disabling a vulnerable service or applying a compensating control.
Requirement 6.3.3 sets a specific deadline for critical security patches and updates: resolve them within one month of release. Install other applicable updates within entity-defined timeframes aligned with risk, with higher-risk issues treated sooner.
What counts as passing scan evidence across four quarters?
PCI SSC FAQ 1152 (2024) explains that evidence across the previous four quarters may consist of a collection of scan results rather than one clean report covering the entire environment. Together, the records need to show that in-scope systems were scanned at least once every three months, vulnerabilities were addressed, and necessary rescans confirmed remediation. A rescan can demonstrate that earlier findings were fixed even if it identifies new findings.
Multiple reports do not make an incomplete scan, a missed schedule, or a finding that remains unresolved compliant. For external scans, FAQ 1152 describes a clean or passing scan in the context of the ASV Program Guide and identifies CVSS scores of 4.0 or greater as a failure threshold. Apply that guidance within the current ASV program requirements, not as a substitute for them. Internal findings follow Requirement 11.3.1’s resolution process.
Does SAQ A still require ASV scans if payment processing is outsourced?
It can. PCI SSC FAQ 1604 says PCI DSS v4.x SAQ A requires ASV external scans for specified merchant e-commerce pages even when payment processing is fully outsourced. The examples are a merchant page that redirects a transaction to a compliant third party and a page that embeds the third party’s payment page or form. The scans address the risk that the merchant page could be compromised and affect its connection to the payment process. Outsourcing does not remove the merchant’s responsibility for the SAQ A requirements that apply to it.
What if a quarterly scan was missed?
A later scan cannot be backdated to prove that scanning occurred during a missed period, and a compensating control cannot replace the required frequency. PCI SSC says periodic activity cannot be performed retroactively. An assessor considers corrective actions and subsequent performance under applicable assessment practices; do not treat a later scan as erasing the gap.
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An ASV report documents scan results and supports evidence for the applicable external-scanning requirement. It does not attest that other PCI DSS requirements were reviewed or are in place. PCI SSC FAQ 1234 (June 2025) states: “The ASV will produce a scan report that details the results of the vulnerability scan — this scan report is not an indication that any other PCI DSS requirements have been reviewed or are in place.” Acquirers, payment brands, or other entities that accept compliance validation may also set reporting expectations, so confirm what they require.
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