How White-Label Payment Gateways Handle PCI Compliance and Data Security

Explore how white-label payment gateways address PCI compliance and data security, including certification, risk management, and the division of responsibilities between providers and clients.

June 19, 2025

White-label payment gateways must deliver uncompromising security and PCI DSS compliance for every transaction. This article breaks down the required certifications, ongoing audit obligations, and the concrete security measures these solutions use to protect sensitive cardholder data.

Circular lifecycle showing annual assessments, scans, remediation, and documentation for PCI DSS compliance
PCI Compliance in White-Label Payment Gateways

PCI compliance in white-label payment gateways is essential for secure transaction processing and protecting cardholder data. These solutions must meet strict PCI DSS requirements, offering certified infrastructure, ongoing validation, and compliance support for merchants and payment service providers.

Built-In PCI DSS Certification

White-label payment gateway solutions must possess PCI DSS Level 1 certification, the highest level of security when it comes to payment processing. Level 1 compliance applies to service providers that exceed 300,000 transactions per year, and the white-label service must undergo an annual on-site assessment with Qualified Security Assessors (QSAs). These detailed assessments include a review of the payment infrastructure from network architecture to application security to operational controls. Where sensitive cardholder data is concerned, payment gateways must use encryption technologies, tokenization systems, and fraud prevention mechanisms across the network each time a transaction takes place.

Annual Validation and Audits

To maintain this Level 1 status, white-label providers must submit annually a Report on Compliance (ROC) which includes vulnerability scanning and penetration testing. This documentation includes control testing of policies, procedures, and systems configurations. In addition to quarterly vulnerability assessments via Approved Scanning Vendors (ASVs), a compliant white-label must maintain its Attestation of Compliance (AOC). All these validation assessments of critical systems occur quarterly and year-round to maintain compliance standards.

Compliance as a Service

White-label payment gateway providers offer Compliance-as-a-Service whereby much of the PCI compliance burden transfers to clients. Since they possess PCI-compliant infrastructure, merchants and their selected PSPs can integrate without transmitting sensitive cardholder data through their systems. For instance, with tokenization services, merchants never see cardholder data since they only access tokenized values. With secure APIs supported by the white-label payment processor, fraud detection tools, and compliance guidance from industry professionals, integration should be seamless. While this provides clients with PCI-compliant integrations that minimize internal PCI compliance scope, clients must still possess API keys and ensure compliance with access control standards. A successful white-label minimizes the client's PCI compliance scope with PCI-compliant infrastructure including tokenization services, encryption technologies, and fraud detection tools. The white-label also assists clients with integration strategies that satisfy PCI compliance requirements.

Shared Responsibility Model in White-Label Solutions

The shared responsibility model in white-label solutions defines clear roles for payment gateway security and compliance. White-label providers and clients each have specific PCI DSS responsibilities for maintaining secure payment processing environments.

Provider Responsibilities

The white-label provider assumes the majority of responsibilities concerning the payment gateway operational back-end. White-label providers must maintain PCI DSS Level 1 certification and use technical measures including end-to-end encryption, tokenization systems, and fraud prevention mechanisms. They implement network firewalls, access control systems, and monitoring tools which create logs and analyze security events on a daily basis.

Furthermore, white-label providers must utilize vulnerability management systems, perform penetration testing and intrusion detection, use secure configurations for redundancy and high availability environments, perform internal risk assessments, and submit to external audits by third parties. White-label providers must possess current Attestations of Compliance (AOCs) and Reports on Compliance (ROCs) developed through quarterly compliance processes.

Client Responsibilities

Regardless of outsourcing their payment processing, entities using white-label payment processors still have compliance obligations. Merchants and PSPs as clients must maintain a strict third-party vendor inventory, conduct risk exposure assessment, and assess their white-label provider's compliance status annually. Merchants and PSPs are responsible for managing their own API credentials, using secure coding standards, and implementing user role-based access to reduce vulnerabilities.

Merchants are also responsible for any custom integrations that may lead to future vulnerabilities. Merchants must create and enforce internal security policies and provide ongoing security training and periodic risk assessments within their infrastructure. Clients' systems must adhere to PCI DSS controls for access management and data handling protocols; therefore compliance documentation is essential. Clients must protect their environments with robust access control measures, secure their API keys, use secure coding for customization efforts, and conduct annual provider compliance validation. Clients must train employees on compliance, engage in risk assessments, and maintain records of their vendor compliance status.

Radial diagram showing tokenization, encryption, fraud detection, access control, and updates in white-label gateway security
Core Data Security Measures

Core data security measures in white-label payment gateways are designed to safeguard sensitive cardholder information. These security protocols, including tokenization, encryption, and fraud prevention, are essential for maintaining PCI DSS compliance and protecting transaction data.

1. Tokenization Implementation

When white-label payment gateways utilize tokenization for transaction processing, cardholder data is replaced with a randomly generated, non-functional token that represents sensitive card details. Tokenization happens upon entry point with storage occurring in the PCI-compliant environment of the white-label provider. Thus, the merchant never sees the actual card numbers, leaving PCI compliance scope lessened and the potential for data compromises minimized. Merchants can use multi-use tokens for recurring billing or store cards, which allows for functionality without jeopardizing security.

2. Encryption and Network Security

Data is encrypted both at rest and in transit utilizing Advanced Encryption Standard (AES). These encryption standards fall under PCI DSS Requirements 3 and 4 and include strong key management practices. The Cardholder Data Environment (CDE) is protected through network segmentation with firewall systems, Intrusion Detection and Prevention Systems (IDPS), and redundant infrastructure in geographically distributed data centres which focus on uptime and security. These data centres undergo penetration testing and cryptographic reviews for compliance.

3. Fraud Detection and Prevention

Fraud detection occurs through the white-label payment gateway itself. Transactions are analyzed for irregularities using behavioural analytics, rule-based detection, and machine learning models. These real-time fraud detection systems collaborate with threat intelligence feeds to ensure updates regarding new threats. This corresponds with PCI compliance standards for fraud prevention to ensure unauthorized access and unauthorized charges do not occur.

4. Access Controls and Monitoring

Access controls are implemented whenever sensitive information is stored or transaction processing occurs. Role-based permissions ensure individuals see only what is necessary to fulfil their job duties. White-label providers utilize multi-factor authentication (MFA), centralized identity management, and fine-grained access rules. Access logs are produced and fed into Security Information and Event Management (SIEM) systems for real-time alerting. Daily log reviews occur, with weekly vulnerability scans and monthly control validations.

5. Regular Security Updates

White-label payment gateways utilize frequent security updates and transaction flow enhancements. Automated vulnerability detection assesses the infrastructure for current vulnerabilities and, if present, risk-based remediation is prioritized for PCI DSS Requirement 6 compliance through secure software development and system maintenance practices. White-label gateways maintain logs of security assessments and engage in simulated breach exercises for response protocol assessment.

Regulatory Compliance Framework

The regulatory compliance framework for white-label payment gateways brings together multiple industry standards and legal requirements. These frameworks ensure that payment gateways operate securely, maintain PCI DSS compliance, and align with global data security and privacy regulations.

Industry Standards Integration

The white-label payment gateway provider integrates various compliance requirements and standards aside from PCI DSS. These include ISO 27001 relative to Information Security Management Systems (ISMS), SOC 2 relative to third-party audits to determine the adequacy of data security controls, availability controls, and privacy controls, and industry standards relative to local and regional requirements such as the General Data Protection Regulation (GDPR). The ability to meet multiple compliance requirements ensures clients can work with this provider globally across various industries.

Integration is advantageous through a layered compliance strategy that creates efficiencies and higher security levels. Integration allows for control mapping and aligned controls so that requirements are not duplicated. Where compliance overlaps, gap analyses determine potential audit cost and time savings. This occurs via internal audits which identify new compliance gaps across different jurisdictions or regional differences over time.

Audit and Documentation Requirements

PCI compliance is a year-round endeavour requiring extensive documentation to support ongoing compliance. This includes system configurations, security procedures, access logs, vulnerability scan results, network diagrams, and data flow charts. White-label providers must document policies relative to key retention and network security requirements.

Annually, providers acquire Reports on Compliance (ROCs), which provide extensive narratives explaining particular steps undertaken, control mappings of assessed requirements, and evidence retrieved to prove compliance with each requirement. Quarterly compliance updates assess everything within three months, highlight outstanding requirements needing remediation efforts, and provide tracking. Evidence of completion is submitted for assessments by external Qualified Security Assessors (QSAs).