PCI DSS Internal Assessment Outcomes: Audit Findings vs Fines

SY0-701 By islever Editorial Last updated

Explain compliance and privacy considerations for security.

Short answer

B Failing an internal PCI DSS compliance assessment results in audit findings, which document the specific security gaps identified during the review process.

Question

Which of the following is the most likely outcome if a large bank fails an internal PCI DSS compliance assessment?
  1. Fines
  2. Audit findings Correct Answer
  3. Sanctions
  4. Reputation damage

Key Takeaways

The main trap is confusing the immediate documentation of errors (audit findings) with the punitive actions (fines/sanctions) that occur later due to external non-compliance.

This page explains why failing an internal PCI DSS compliance assessment primarily results in audit findings rather than immediate fines or sanctions. Learn the distinction between internal reviews and external enforcement.

Common mistake: Many candidates choose 'Fines' because they associate PCI DSS non-compliance with monetary penalties. However, fines are imposed by card brands after external audits or breaches, not as the direct output of an internal self-assessment.

Expert Analysis

The question asks for the most likely outcome of failing an internal PCI DSS compliance assessment. It is critical to distinguish between the immediate procedural result of an internal review and the downstream consequences of non-compliance.

  1. Internal vs. External Assessment: An internal assessment (often a Self-Assessment Questionnaire or internal audit) is conducted by the organization itself or its internal audit team. The direct output of any audit or assessment is a report detailing discrepancies, which are termed audit findings or non-conformities. This is the immediate, factual result.
  2. Fines and Sanctions: Fines and sanctions are imposed by payment card brands (Visa, Mastercard, etc.) or acquirers. These penalties typically apply after a merchant or bank fails an external Qualified Security Assessor (QSA) audit, is found non-compliant during routine monitoring, or suffers a data breach. While prolonged failure to remediate internal findings can eventually lead to fines, the fines are not the direct outcome of the internal test itself.
  3. Reputation Damage: This is a potential secondary effect, especially if news leaks, but it is not a guaranteed or procedural outcome of an internal document. Internal failures are often kept within the organization to be fixed before external scrutiny.
  4. Analysis of Options:
  • A (Fines): Incorrect as the immediate outcome. Fines come from external enforcement bodies.
  • - B (Audit Findings): Correct. The definition of an assessment's output is findings. Whether internal or external, the first step is documenting what was wrong.
  • - C (Sanctions): Similar to fines, these are external punitive measures.
  • - D (Reputation damage): Speculative and indirect.

Therefore, the most direct and inevitable outcome is the generation of audit findings that must be remediated.

Exam Strategy

When answering questions about compliance assessments, always check if the scenario specifies 'internal' or 'external'. Internal assessments yield findings and reports for remediation. External assessments or regulatory inspections trigger fines, sanctions, or legal action. Look for keywords like 'self-assessment', 'internal audit', or 'QSA' to determine the correct consequence.

Frequently Asked Questions

What is the difference between an internal and external PCI DSS assessment?

An internal assessment is performed by the organization's staff or internal auditors to identify gaps before an official review. An external assessment is conducted by a third-party Qualified Security Assessor (QSA) and is required for formal compliance validation.

Can a bank be fined for failing only an internal PCI DSS assessment?

No, payment card brands do not directly fine organizations based on internal assessments. Fines are levied when a bank is found non-compliant through external audits, transaction monitoring, or after a data breach occurs.

What should a bank do after identifying non-compliance in an internal assessment?

The bank must create a remediation plan to address the audit findings. These issues must be resolved before the next external QSA audit to ensure the bank achieves and maintains full PCI DSS compliance.

More SY0-701 FAQ →

Community Votes

B
86%
A
14%

86% of anonymous learners picked answer B. Votes are pick records left by other test-takers — they are not the verified answer.

Discussion 50 contributions

Compiled from public community threads and reader submissions, lightly edited for clarity. Handles and vote tallies are shown as recorded, and comments reflect the views of individual contributors.

From public community threads 30 of 50

  1. Etc_Shadow28000 👍 21 Answered B
    B. Audit findings While fines, sanctions, and reputation damage can be potential consequences of failing to meet PCI DSS compliance, the most immediate and likely outcome of failing an internal PCI DSS compliance assessment is the generation of audit findings. These findings will detail the areas of non-compliance and typically result in the organization needing to take corrective actions to address the identified issues. If the findings are not addressed, this could lead to further consequences such as fines, sanctions, or reputation damage. Therefore, the correct answer is: B. Audit findings
  2. kambam 👍 13
    Internal is keyword here. You are not going to report yourself and cause yourself to be fined. External audit would have to report and therefore fines would be more applicable. Audit findings is correct.
  3. Zoots_1 👍 5
    B. Audit findings would be correct if this was done externally by a third party, however internal audits produce findings right away, meaning that the organization has immediate access to these results. For that reason, audit findings can indeed seem less impactful than fines if we’re focusing on the actual consequences of failing to meet PCI DSS requirements. Correct answer is A. Fines
  4. Marc_s 👍 4
    For options A., C., and D. to happen, the findings have to be available to EXTERNAL agencies that would impose those results. This was completed INTERNALLY, so no one outside (external) of the agency would know.
  5. AriGarcia 👍 4
    How can it be Fines if it is an internal assesment? The correct answer is B.
Show 25 more comments
  1. nyyankee718 👍 4 Answered B
    key word INTERNAL audit.
  2. YokuDoku 👍 3 Answered A
    Audit findings. Audit findings are the results of an external PCI DSS compliance assessment that is performed by a QSA or an approved scanning vendor (ASV). An external assessment is required for certain entities that handle a large volume of cardholder data or have a history of non-compliance. An external assessment may also be triggered by a security incident or a request from the payment card brands. Audit findings may reveal the gaps and weaknesses in the bank’s security controls and recommend corrective actions to achieve compliance. However, audit findings are not the outcome of an internal assessment, which is performed by the bank itself. References: 1. CompTIA Security+ Study Guide (SY0-701), Chapter 8: Governance, Risk, and Compliance, page 388. 2. Professor Messer’s CompTIA SY0-701 Security+ Training Course, Section 8.2: Compliance and Controls, video: PCI DSS (5:12). 3. PCI Security Standards Council, PCI DSS Quick Reference Guide, page 4. 4. PCI Security Standards Council, PCI DSS FAQs, questions 8-30
  3. braveheart22 👍 3 Answered A
    The right answer is A (Fines) and NOT B (Audit Findings) Explanation If you look at the question closely, It says "outcome" which is also "consequence" in other words. Yes, Audit Findings would be a likely REASON for failing an internal PCI-DSS compliance assessment, but would NOT be the OUTCOME. The Payment Card Industry Security Standards Council (PCI SSC) and the payment card brands (e.g., Visa, MasterCard) can impose fines on organizations that fail to meet PCI DSS compliance standards. These fines can be significant, especially for large organizations like banks, which are expected to comply fully with these standards to ensure the protection of customer data. These fines are generally imposed by payment card brands or acquiring banks when an entity is found non-compliant, especially after a formal audit or a data breach.
  4. Valen2259 👍 3 Answered B
    B. Audit findings (though a rally bad question/answer in reality) Internal PCI DSS assessments are typically conducted to identify gaps before an official external audit or regulator review. Failing an internal assessment would primarily result in audit findings — documented issues that need to be addressed before the next official evaluation. However, in reality if the report is leaked which inevitably occurs (and the worry impact of the board) would be D. Reputation damage as this would lose the public trust and impact key stakeholders.
  5. Russell15 👍 3 Answered B
    I at first thought A: fines, as the assessment is an audit and the findings are what cause it to fail, but after you submit your configurations, UARs, etc. for the audit. If you fail they will tell you why you failed and what you need to fix it to be complaint. Failing multiple times or having a breach due to being non-compliant can result in the fines as they are not the first outcome of an audit.
  6. 93bdd7c 👍 3 Answered A
    f a large bank fails an internal PCI DSS compliance assessment, the most likely outcome is that the bank will face fines from the payment card brands. Audit findings, while important, are typically the result of an external assessment and not the direct consequence of an internal assessment. The bank must address these findings to avoid further penalties.
  7. 1ohndc923 👍 3 Answered A
    It's actually A (Fines) because the internal PCI DSS assessment results must be sent to the bank's payment card brands or their agents. The payment card brands will then issue a fine because again, even though it's an internal assessment, it must be submitted to the other party - hence resulting in being fined.
  8. ExamCowboy 👍 3
    Answer A: 'Sanctions and Reputation' damage happen after an external audit. 'Audit Findings' are what is found during an internal or external audit. 'Fines' are the penalty for not doing things correctly in an internal audit, whereas 'Sanctions' are what is imposed during an external audit.
  9. 7d6fad2 👍 3 Answered B
    B. Audit Findings. Keyword is "Internal." Whoever chooses a different option, you mean to tell me the company will fine or impose actions on themselves? The Internal Audit will result in Audit Findings that they can later use to rectify the issue.
  10. tsummey 👍 3 Answered B
    The answer is audit findings. The question references an "internal" compliance assessment. An internal compliance assessment is a tool used to identify and address any gaps that must be closed before the actual PCI assessment.
  11. 475a567 👍 3 Answered A
    internal assessment, not external. can allow time to fix before a governmental audit
  12. Bimbo_12 👍 3 Answered B
    A company won't fine itself for the outcome of an internal audit. The answer is B.
  13. Cyber_Texas 👍 3 Answered B
    B because its an INTERNAL investigation. the company will not fine itself.
  14. bufffalobilll 👍 3 Answered B
    No sure you'd fine yourself after an internal probe
  15. adderallpm 👍 3
    Audit findings Internally excite me
  16. YokuDoku 👍 2 Answered A
    If a large bank fails an internal PCI DSS compliance assessment, the most likely outcome is that the bank will face fines from the payment card brands. An internal PCI DSS compliance assessment is a self-assessment that the bank performs to evaluate its own compliance with the PCI DSS requirements. The bank must submit the results of the internal assessment to the payment card brands or their designated agents, such as acquirers or qualified security assessors (QSAs). If the internal assessment reveals that the bank is not compliant with the PCI DSS requirements, the payment card brands may impose fines on the bank as a penalty for violating the PCI DSS contract. The amount and frequency of the fines may vary depending on the severity and duration of the non-compliance, the number and type of cardholder data compromised, and the level of cooperation and remediation from the bank. The fines can range from thousands to millions of dollars per month, and can increase over time if the non-compliance is not resolved.
  17. noragami 👍 2 Answered B
    Failing an internal PCI DSS compliance assessment typically results in audit findings, which are documented issues that need to be addressed to achieve compliance. These findings highlight areas where the bank's security practices do not meet the required standards and must be remediated. While fines, sanctions, and reputation damage are potential consequences of non-compliance, they are more likely to occur if the bank fails to address the audit findings and remains non-compliant, especially after an external audit or if a data breach occurs due to non-compliance. The immediate outcome of failing an internal assessment is the identification of compliance gaps through audit findings.
  18. dbrowndiver 👍 2 Answered B
    You would think fines bc fines can be a consequence of prolonged non-compliance, they are typically imposed by external parties (e.g., payment card brands) after failing to address compliance issues. The immediate outcome of an internal assessment is audit findings, not fines. The most immediate outcome of a compliance failure is the generation of audit findings that outline the specific deficiencies. These findings are critical for understanding compliance gaps and planning remediation efforts. Also, Audit findings help the bank's internal compliance and security teams prioritize areas for improvement and guide them in implementing necessary changes to meet PCI DSS standards.
  19. YokuDoku 👍 2 Answered A
    PCI DSS is the Payment Card Industry Data Security Standard, which is a set of security requirements for organizations that store, process, or transmit cardholder data. PCI DSS aims to protect the confidentiality, integrity, and availability of cardholder data and prevent fraud, identity theft, and data breaches. PCI DSS is enforced by the payment card brands, such as Visa, Mastercard, American Express, Discover, and JCB, and applies to all entities involved in the payment card ecosystem, such as merchants, acquirers, issuers, processors, service providers, and payment applications.
  20. d91fc7d 👍 2 Answered A
    If a large bank fails an internal PCI DSS (Payment Card Industry Data Security Standard) compliance assessment, the most likely outcome would be fines. PCI DSS compliance is crucial for banks and financial institutions that handle payment card information. Failing to comply with PCI DSS requirements can result in substantial fines imposed by payment card brands such as Visa, MasterCard, and others. These fines are meant to enforce adherence to security standards and protect consumers' payment card data from breaches and unauthorized access.
  21. pedrwc7 👍 2 Answered B
    A. Fines (If an external entity finds out or somone will report it with a solid proof) B. Audit findings (Company mistakes will stay inside the company) As an example, you work in a company and you made a mistakes that will lose your job. Are you going to tell them or are you just going to keep it to yourself? Its kinda same scenario as the question. C. Sanctions (If an external entity finds out or somone will report it with a solid proof) D. Reputation damage (If an external entity finds out or somone will report it with a solid proof)
  22. Abcd123321 👍 2 Answered A
    What are the consequences of not being PCI DSS compliant? The fines imposed by the Card Brands and Acquiring Banks on merchants for non-compliance can range from $5,000 to $100,000 per month. These fines, along with credit monitoring fees, can impose substantial financial strain on businesses, underscoring the necessity of abiding by the PCI DSS requirements.
  23. darpanne 👍 2 Answered B
    Audit findings indicate specific areas of non-compliance or gaps in security controls that need to be addressed to meet PCI DSS requirements other options are for external assessment
  24. e5c1bb5 👍 2 Answered B
    answer is B Reason: the compliance assessment is INTERNAL. it isn't released to the public and is done within the organization. they would audit the findings.
  25. ErichenriJoachim 👍 2 Answered B
    The keyword here is "internal" that is why the Audit finding is for certain the correct answer

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