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Risk Analysis Returns: The Targeted Risk Assessment Advantage

Risk Analysis Returns: The Targeted Risk Assessment Advantage

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Risk assessments are back, but with a new twist. Rather than one comprehensive assessment reflecting risks against your organization as a whole, PCI DSS compliance now requires targeted risk assessments (TRAs) to be performed at the individual control level. In the past, several PCI DSS requirements effectively allowed controls to be exercised at unspecified frequencies; now those frequencies must be defined as well as the rationale behind them. With the new TRA requirements fully in effect, organizations face a key challenge: how to best complete them effectively and ensure they support, as opposed to hinder, the organization’s security goals and compliance efforts. Because while TRAs might seem like a simple “check the box” exercise on the surface, the strategy and process an organization follows to complete them can dramatically impact the efficiency, accuracy and long-term value of its PCI compliance program.

Why Targeted Risk Assessments Matter for PCI DSS Compliance

Under PCI DSS 4.0.1, organizations are granted a welcome measure of flexibility in determining how often certain controls are exercised by allowing them to make risk-based decisions. The TRA’s role in that decision is to provide both control owners and the assessor the evidence needed to demonstrate that the decisions are intentional, well-documented and aligned with security requirements.

Therein lies the challenge: how to ensure the completed TRAs properly reflect what is best for the organization. In a word, our experience has taught us the best prepared organizations are strategic and intentional with their TRAs, rather than treating them as a mini “PCI project” or an afterthought.

Organizations that treat TRAs as an afterthought risk:

  • Confusion over what needs to be performed and/or how often.
  • Multiple, repeated requests for evidence due to incomplete documentation.
  • Frustration among internal teams and stakeholders.

In contrast, those that take a proactive, methodical approach position themselves for a more efficient and effective PCI assessment.

Common Approaches to Targeted Risk Assessments in PCI Assessments

Organizations typically fall into one of two categories:

  1. The “Check-the-Box” Approach
    Some teams complete the TRA mechanically, simply accepting and documenting the PCI SSC’s recommendations and guidance without deeper engagement with internal teams or control owners. While this generally satisfies the requirement on paper, it often leads to incomplete or incorrect risk assessments and often results in missed frequencies.
  2. The Intentional, Collaborative Approach
    A more effective approach involves circulating the TRA with internal teams, control owners and other stakeholders as appropriate, engaging management early and thoughtfully documenting risk-based decisions. This requires more effort upfront but ultimately improves both the assessment experience as well as the security posture of the organization overall.

Benefits of a Proactive Approach

When organizations invest in thoughtful TRA preparation, they see measurable advantages:

  • Simpler Assessments: Clear documentation and stakeholder alignment reduce ambiguity and streamline the QSA review.
  • Reduced Remediation: Early identification of gaps minimizes corrective actions after the assessment.
  • Less Back-and-Forth: Evidence is ready and accurate, reducing repeated requests from the QSA.
  • Lower Internal Frustration: Teams understand their responsibilities, which reduces stress and miscommunication.

Much like organizations that successfully navigated the PCI DSS 4.0.1 transition by engaging QSAs early, dedicating internal resources and pre-validating evidence, those who approach TRAs thoughtfully are better positioned for success.

Best Practices for Managing Targeted Risk Assessments

To maximize the value of your TRA:

  1. Engage Subject Matter Experts Early: Involve IT, security, operations and compliance teams to ensure the analysis is complete and accurate.
  2. Secure Management Buy-In: Leadership engagement ensures accountability and adequate resources for ensuring the controls are exercised at the defined frequency.
  3. Document Thoughtfully: Include references to policies, procedures and technical controls. Clear documentation saves time later.
  4. Plan for Updates: Like all PCI DSS compliance efforts, completing TRAs is not a one-time “one and done” exercise. TRAs must be reviewed at least once per year to reflect changes in systems, processes or regulations as well as to ensure they remain accurate and effective.

Lessons from PCI DSS 4.0.1

The recent PCI DSS 4.0.1 transition reinforced an important principle: proactive preparation pays off. Organizations that prepared early, dedicated resources and engaged their QSAs avoided last-minute surprises and minimized risk. The same principle applies to TRAs—thoughtful planning reduces frustration, streamlines assessments and strengthens your overall PCI security program.

For organizations still refining their PCI program, our recent article on PCI DSS 4.0.1 readiness explores how early engagement, internal expertise and proactive collaboration set teams up for success. Many of the lessons learned there apply directly to TRAs as well.

Conclusion

TRAs are more than just forms—they are a critical component of demonstrating compliance with PCI DSS when making risk-based decisions. Organizations that approach TRAs intentionally and proactively benefit from smoother assessments, reduced remediation and a stronger security posture. Taking the time to engage stakeholders, clarify responsibilities, and maintain accurate documentation ensures your completed TRAS reflect effective and defensible risk-based conclusions.

Ready to simplify your PCI compliance process and strengthen your security program? Our team can guide you through thoughtful TRA preparation, documentation and assessment readiness. Schedule a consultation today to ensure your organization is fully prepared.

Contributors

Mindy Milliet, Partner, Frazier & Deeter Advisory, LLC

Scott Davis, Manager, Frazier & Deeter Advisory, LLC

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