Is PCI DSS "Too Prescriptive"?

I did this fun panel on PCI compliance at SecureWorld Bay Area the other week. What is interesting is that almost every time there is a discussion about PCI DSS, somebody crawls out of the woodwork and utters the following: "PCI is too prescriptive!", as if it is a bad thing (e.g. I mentioned it before here)

I used to react to this with "Are you stupid?! PCI being prescriptive is the best thing since sliced cake :-) Finally, there is some specific guidance for people to follow and be more secure!" BTW, in many cases end users who have to comply with PCI DSS still think it is "too fuzzy" and "not specific enough" (e.g. see "MUST-DO Logging for PCI"); and they basically ask for  "a compliance TODO list." (also see this and especially this on compliance checklists)

But every time it happens, I can't stop but think - why do people even utter such utter heresy? :-) And you know what?  I think I got it!

When people say "PCI is too prescriptive," they actually mean that it engenders "checklist mentality" and leads to following the letter of the mandate blindly, without thinking about WHY it was put in place (to protect cardholder data, share risk/responsibility, etc). For example, it says "use a firewall" and so they deploy a shiny firewall with a simple "ALLOW ALL<->ALL" rule (an obvious exaggeration - but you get the point!) Or they have a firewall with a default password unchanged... In addition, the proponents of "PCI is too prescriptive" tend to think that fuzzier guidance (and, especially, prescribing the desired end state AND not the tools to be installed) will lead to people actually thinking about the best way to do it.

So the choices are:

1. Mandate the tools (e.g. "must use a firewall") - and risk "checklist mentality", resulting in BOTH insecurity and "false sense" of security.
2. Mandate the results (e.g. "must be secure") -  and risk people saying "eh, but I dunno how" - and then not acting at all, again leading to insecurity.

Take your poison now?! Isn't compliance fun? What is the practical solution to this? I personally would take the pill #1 over pill #2 (and that is why I like PCI that much), but with some pause to think, for sure.  I think organizations with less mature security programs will benefit at least a bit from #1, while those with more mature programs might "enjoy" #2 more...

BTW, this post was originally called "Isn't Compliance Fun?!"  I had a few fierce debates with some friends and all of them  piled on me to convince me that "compliance is boring, while security is fun!" The above does illustrate that there are worthy and exciting intellectual challenges in the domain of regulatory compliance. It is not [only] a domain of minimalists (who just "want the auditor to go away") and mediocrity, as some think. What makes security fun - the people aspect, the ever-changing threat landscape, cool technology, high uncertainty, even risk - also apply to compliance ...

So, need a cool marketing slogan BUT hate "making compliance easy"?  Go for "Making Compliance Fun!" :-)

All posts on PCI - some are fun:-)