Earlier versions of PCI DSS often mandated fixed intervals for security activities such as daily log reviews or annual training. But one size doesn’t always fit all. PCI DSS v4.0 takes a more nuanced approach, allowing organizations to define activity frequencies based on their unique risk environment. This is where TRAs come in, they empower teams to align security practices with operational realities, without compromising on protection.
In this article, we’ll cover:
What TRAs are and why they matter
When you’re required to perform a TRA
How to implement TRAs in a way that supports both compliance and operational needs
What is a Targeted Risk Analysis?
A Targeted Risk Analysis (TRA) is a structured assessment used to evaluate specific risks and determine either the appropriate frequency of certain PCI DSS controls or to justify the use of customized controls.
TRAs are required in two key contexts under PCI DSS v4.0 and 4.0.1:
Defining Activity Frequency (Requirement 12.3.1)
Some controls do not have a predefined schedule. In these cases, organizations must define a reasonable frequency based on the results of a TRA.Customized Approach (Requirement 12.3.2)
When using the Customized Approach, a TRA is required to demonstrate that the alternate control provides protection equivalent to what the standard control would achieve.
Why it matters:
The TRA ensures that security decisions, like how often to review logs or rotate passwords, are based on actual risk, not arbitrary timelines. It also provides documented justification that your controls are appropriate and effective, which helps satisfy both compliance requirements and security objectives.
For a full list of TRA Requirements and Frequency Recommendations, click here: PCI DSS v4.x:Targeted Risk Analysis Guidance
When is a TRA Required?
A Targeted Risk Analysis (TRA) is necessary when explicitly required by the PCI DSS, most commonly under Requirements 12.3.1 and 12.3.2 of version 4.0. In these instances, a TRA justifies the frequency of security activities or supports a Customized Approach to meeting a requirement's objective.
Examples of Requirements Typically Requiring a TRA:
Malware evaluations (Requirement 5.2.3.1): Frequency defined by a TRA, but at least every six months.
Log reviews (Requirement 10.4.2.1): Frequency determined by a TRA, but no less than weekly.
Password changes for system accounts (Requirement 8.6.3): At least every 90 days, or more frequently if justified by a TRA.
Incident response training (Requirement 12.10.4.1): At least annually, or more often based on a TRA.
IMPORTANT NOTE: A TRA is not required for all PCI DSS requirements. Some activities have fixed schedules or specific implementation methods that must be strictly adhered to, without room for risk-based adjustments. Please see below.
Examples of Requirements Where a TRA is NOT Required:
Quarterly internal vulnerability scans (Requirement 11.3.1.1)
Annual risk assessments (Requirement 12.2.1)
Daily anti-malware signature updates (Requirement 5.3.3)
These examples do not necessitate a TRA because the PCI DSS standard clearly outlines the timing and implementation procedures.
How to Conduct a PCI DSS Targeted Risk Analysis
1. Identify Critical Assets and Threats
Start by listing your most critical assets (e.g. cardholder data, systems handling payments, credentials, etc.) and the threats that could affect them (malware, insider abuse, system misconfigurations). Categorize based on business impact and sensitivity. TRAs should take a broad view, and reflect both internal and external risks
Related Requirement: 12.2 (Risk Assessment Process)
2. Evaluate Risk Factors
For each threat, assess the likelihood of it occurring and the potential business impact. Think through:
Complexity of your systems
External exposure (e.g., internet-facing apps)
Data classification and sensitivity
Assess whether existing controls (like access restrictions or patching routines) are sufficient, or if you’re accepting too much residual risk.
Related Requirements: 5 (Malware Protection), 7 (Access Control)
3. Determine Control Frequency and Effectiveness
Decide how often controls need to be applied based on the criticality of the asset and the severity of the threat. Environments with frequent deployments, configuration changes, or elevated exposure levels should implement controls at shorter intervals. For instance:
Log reviews might be daily for high-risk systems.
Malware scans could move from weekly to daily if TRA identifies elevated threat levels or new vulnerabilities.
Related Requirements: 5.2.3.1, 10.6, 10.7, 12.8
4. Document the TRA
Capture all findings clearly, what you assessed, what threats you identified, how you evaluated risks, and how often you’ll apply controls. Assign owners to each control or action, and keep documentation audit-ready.
Related Requirement: 12.1 (Policy and Ownership)
5. Review Annually and Update for Significant Changes
Like any good risk analysis, a TRA isn’t one-and-done. Review it at least annually, and any time you experience major system changes, new threats, or changes in business operations.
Related Requirement: 12.3.1
6. Communicate Results and Reporting
Share your TRA results with relevant stakeholders such as security leaders, IT teams, executive sponsors, and auditors. This isn’t just about transparency; it’s about making sure that risk-based decisions are aligned across the board.
Related Requirement: 12.10 (Incident Response Training and Communication)
Sample Targeted Risk Analysis
PCI DSS Requirement Number: 10.6 - Review logs for all systems and processes that store, process, or transmit cardholder data
Date of Initial TRA: January 1, 2024
Date of Most Recent Review: March 1, 2025
TRA Components | Example |
1. Identify the asset(s) being protected. | [Describe system(s), data, or process at risk] Example: Cardholder data, payment systems, transaction logs. |
2. Identify the threat(s) that the requirement is protecting against. | [Describe specific threats, e.g., malware, unauthorized access] –
Example: Unauthorized access, data leakage, malicious activity (e.g., malware or insider threats). |
3. Identify the factor(s) that contribute to the likelihood and/or impact of the threat being realized. | [Detail contributing risk factors: public exposure, user behavior, system complexity, etc.]
Example: Public-facing systems, high-volume transactions, lack of user behavior monitoring, complexity of logging mechanisms. |
4. Describe the analysis of and justification for how frequently the requirement must be performed to minimize the likelihood of the threat being realized. | [Explain why you chose a certain frequency (e.g., weekly log reviews) and how it aligns with the risk level]
Example: Weekly log reviews are necessary due to high risk of data exposure, especially during peak transaction periods. Log analysis can detect anomalous behavior in near real-time. |
5. Is an updated analysis needed, based on an annual review? | [Yes/No. Add context if needed]
Example: Yes, the analysis is reviewed annually and adjusted as necessary based on evolving threats and system changes. |
6. Are there defined and documented policies and procedures for performing the entity’s TRAs consistently? | [Yes/No. Reference policy/document location if applicable]
Example: Yes. Refer to the Risk Assessment Policy (Document: [insert policy name or location]). |
Targeted Risk Analysis for Customized Approach (Appendix D)
If you’re using the Customized Approach for any control, Appendix D outlines how to conduct the required TRA. This includes:
A repeatable methodology
A strong justification for the alternative control
Clear documentation showing that your approach provides equivalent or stronger protection
Customized approaches can offer real value, but they require rigorous validation to ensure controls are effective as those defined in the standard. Document the risks, control effectiveness, and rationale thoroughly.
Sample TRA – Customized Approach (PCI DSS v4.0 Appendix D)
TRA Components | Example |
1. PCI DSS Requirement Number | [Insert applicable PCI DSS Requirement number]
Example: 2.4, 6.2 (for Secure Configuration and Change Management) |
2. Date of Initial TRA | [Insert date] Example: February 1, 2024 |
3. Date of Most Recent Review | [Insert date] Example: March 15, 2025 |
4. Identify the asset(s) being protected. | [Describe system(s), data, or process at risk] Example: Payment systems, databases, access control systems, etc. |
5. Identify the threat(s) that the requirement is protecting against. | [Describe specific threats, e.g., malware, unauthorized access, misconfiguration, etc.]
Example: Unauthorized access, data breaches, system misconfigurations. |
6. Identify the factor(s) that contribute to the likelihood and/or impact of the threat being realized. | [Detail contributing risk factors: system complexity, external exposure, user behavior, etc.]
Example: High user access levels, system exposure to external traffic, frequent configuration changes. |
7. Is this control alternative equivalent or stronger than the standard PCI DSS requirement? | [Yes/No – Explanation]
Example: Yes, the custom configuration control provides at least the same level of security through periodic automated reviews of configuration files and access logs. |
8. Describe the analysis of and justification for how frequently the requirement must be performed to minimize the likelihood of the threat being realized. | [Explain why you chose a certain frequency for this alternative control and how it aligns with the identified risk]
Example: Weekly configuration reviews to ensure ongoing secure system configurations. |
9. Is an updated analysis needed, based on an annual review? | [Yes/No – Explanation]
Example: Yes, annual reviews are required to ensure continued alignment with the intended security posture. |
10. Are there defined and documented policies and procedures for performing the entity’s TRAs consistently? | [Yes/No – Reference to policy/document location]
Example: Yes, refer to the “Custom Control Policies for PCI DSS Compliance” document. |
11. Does the customized control ensure equivalent protection as per the original PCI DSS requirement? | [Yes/No – Explanation]
Example: Yes, the control is evaluated to offer equivalent protection by verifying secure system configurations and limiting unauthorized access through system reviews. |
12. How are the custom controls tested for effectiveness? | [Describe testing methods]
Example: Custom controls are tested via penetration testing and automated vulnerability assessments conducted quarterly. |
Key Takeaways
TRAs give organizations flexibility to tailor control frequencies or alternatives, but they carry the responsibility to analyze and justify those risk-informed decisions.
Conduct TRAs when explicitly required, especially when defining how often a control runs or when customizing a control.
Keep documentation clear, detailed, and ready for audit.
Regularly review your TRAs to ensure they evolve with your environment and threat landscape.
Done right, a TRA isn't just a compliance checkbox, it’s a practical tool to align security controls with real-world risk.
For more details, refer to the PCI DSS v4.x Sample Templates for TRAs available in the PCI Security Standards Council Document Library.