3 PCI DSS Clarifications Every Merchant Needs to Know About Cardholder Data Storage

For years, certain PCI DSS requirements left businesses guessing. How long can you store cardholder data? Can you store the CVV code? Do names and expiry dates need masking? The standard offered guidance, but left room for interpretation.

Recent clarifications from the PCI Security Standards Council (PCI SSC) finally settle these questions. And they matter, because misunderstanding these rules can lead to compliance gaps, unnecessary complexity, and serious security risks. Let’s dive into the three clarifications in more detail and what they mean for your business.

1. What is the maximum period of time that cardholder data can be stored?

Before we talk about retention, let’s clarify what “cardholder data” actually means.

PCI DSS defines cardholder data (CHD) as the primary account number (PAN) alone or combined with any of the following elements: cardholder name, expiration date, and service code.

Now, here’s the clarification about the retention period: PCI DSS does not set a fixed retention period for CHD. There is no universal time limit. Instead, the standard requires you to define and enforce a retention policy based on your legal, regulatory, and business needs. The guiding principle is simple: keep CHD only as long as you absolutely need it, and securely delete it when you don’t.

Why does this matter? Because every extra day you store CHD increases your exposure. Breaches don’t happen because data disappears. They happen because data lingers.

2. Can sensitive authentication data be stored before authorization?

Also here, before we talk about the storing principles for Sensitive Authentication Data(SAD), let’s define what SAD means. PCI DSS defines SAD as the card verification code, PIN blocks and magnetic stripe. The card verification code is also known as CVV/CVC.

With respect to SAD, PCI DSS requirement 3.3.1 prohibits storage of SAD after authorization, except as permitted for issuers and companies that support issuing services. That means, no other businesses are allowed to store SAD after authorization, without exceptions.

To answer the question, this means that you are allowed to store SAD before authorization. There are no specific rules in PCI DSS regarding how long SAD can be stored before authorization, but such data would need to be protected according to PCIDSS requirements.

This clarification gives businesses clarity, but it also raises the stakes. Storing SAD, even briefly, is high risk. If you choose this route, your security controls must be flawless.

3. Does cardholder name, expiration date, etc. need to be rendered unreadable if stored in conjunction with the PAN (Primary Account Number)?

If you store the Primary Account Number (PAN), you should already know the rule: it must be rendered unreadable in accordance with requirement 3.5.1. But what about other cardholder data, such as the cardholder name and expiration date? Do they need to be rendered too? The answer: no, they don’t.

Associated data like cardholder name and expiry date can remain readable, even when stored, processed, or transmitted with the PAN, as long as protected according to PCI DSS requirements. This includes network security controls, access controls, vulnerability management, and other security measures. Misinterpretation often leads to unnecessary complexity or worse, under-protection. The goal isn’t to make your data unusable; it’s to make it secure.

Conclusion

These clarifications from the PCI SSC don’t change the rules; they remove the ambiguity. And that’s good news. When you know exactly what you can store, for how long, and in what form, you can simplify your processes, tighten your security posture, and avoid compliance surprises.

The message for merchants and service providers is straightforward: be intentional with your data. Keep only what you need, protect everything you touch, and eliminate what no longer serves a purpose.

With clearer guidance and the right technical safeguards, PCI DSS compliance becomes less about navigating grey areas and more about building a secure, predictable, and resilient payment environment.