For an ecosystem that processes billions of transactions a month, software security in Indian payments is no longer a back-office checklist. It is becoming the foundation on which scale, credibility, and even regulatory survival rest. As UPI expands into credit, SoftPOS chips away at traditional terminals, and tokenisation reshapes card acceptance, the software powering these layers is undergoing its own transformation.

At the centre of that shift is the PCI Software Security Framework (SSF) – the global successor to legacy standard PA-DSS, and a standard that many in India's payments industry are now being nudged toward by the regulator's tightening approach to cybersecurity and third-party risk management.

The Payment Card Industry Software Security Framework, or PCI SSF, doesn't merely replace its predecessor with updated requirements. Where PA-DSS offered vendors a checklist to validate finished applications, SSF demands that security permeate the entire development lifecycle. In a market as dynamic as India's, where payment innovations launch at breakneck speed and regulatory scrutiny intensifies quarterly, this shift carries profound implications.

A framework built for a new era of payments software

"The shift from PA-DSS to the PCI Software Security Framework is not a simple version update; it is a fundamental paradigm shift," says Satyashil Rane, chief operating officer at ControlCase, who has guided numerous Indian vendors through both regimes. PA-DSS, he notes, was highly prescriptive – a checklist focused primarily on the security of the deployed application. SSF is outcomes-based, technology-agnostic, supporting everything from traditional server-based applications to modern APIs, microservices, and cloud-native solutions.

For vendors, the SSF – comprising the Secure Software Standard (SSS) and Secure Software Lifecycle (Secure SLC) Standard – validation requires embedding security into the entire development pipeline, not just bolting it on at the end, Rane adds.

The objective-based approach of SSF, he believes, helps vendors secure applications that utilize UPI's deep linking, SoftPOS' COTS security, or tokenization, even if PA-DSS never fully contemplated these technologies.

Ramkumar Sekar, director, Yalamanchili Software Solutions, whose company recently completed its PCI SSF audit, experienced this firsthand. "Unlike PA-DSS, SSF emphasizes Secure Software Lifecycle management," Sekar explains. "This includes threat modelling, change management, and security gates within the SDLC, making it more relevant for today's agile development environments."

The Secure SLC also introduces something PA-DSS never enabled – which is faster release cycles without compromising security. "Once achieved, Secure SLC allows vendors to manage certain 'delta' changes with reduced assessor involvement," Rane explains. This is a critical advantage in a market where new features are pushed out weekly.

AVS Prabhakar, chief risk and compliance officer at Zeta adds that the support for cloud and SaaS models makes SSF compatible with the direction in which most Indian payment software is headed. "PCI SSF, including PCI DSS, MPoC/CPoC, helps in secure scaling in India's digital payments," he says.

Even in areas where SSF is not directly applicable – like UPI, which does not use card data – vendors see value. SSF's secure lifecycle requirements still strengthen development disciplines, reduce vulnerabilities, and improve audit readiness.

"For fintech software companies, PCI SSF acts as a standardization framework for security practices," Sekar notes. "It helps organizations scale securely while maintaining compliance and reducing vulnerabilities in fast-evolving payment ecosystems."

The framework's modularity proves particularly valuable. While core standards remain stable, specific modules address particular technology risks – existing ones for mobile payments or cloud deployments, potential future ones for SoftPOS-specific concerns or AI-driven payment decisioning.

In practical terms, a vendor with Secure SLC validation can roll out new features for instant UPI refunds or offline payment capabilities without triggering full-scale reassessment each time.

For Indian vendors eyeing international expansion, SSF carries additional strategic weight. "The framework provides globally recognized evidence of secure development maturity – increasingly essential for winning contracts with international clients and card brands. Secure scaling requires both speed and trust, and SSF delivers the framework for both," Rane says.

"The SSF’s mature validation programs and transparent product/vendor listings differentiate PCI SSC from other frameworks by giving stakeholders clear, practical insight into both software security and the processes behind it," Nitin Bhatnagar, regional director, PCI Security Standards Council, states. " These listings function like a 'nutritional label' for software, outlining what was evaluated, the scope, and high-level results – enabling stakeholders to use this information to make informed business decisions about the security of those products and vendors."

The awareness factor

The level of familiarity among Indian software vendors with SSF varies sharply across the ecosystem.

"Core application vendors – those building payment gateways, card management systems, or acquiring platforms – tend to be highly familiar," Rane says, particularly those offering payment gateways, card management systems, or acquiring platforms. These companies had to treat PA-DSS as a competitive necessity, and SSF is seen as the natural next step.

Ancillary or back-office software providers – such as fraud monitoring tools, loyalty systems, or specific back-office reporting applications – are catching up, often because their clients are now insisting on it. "Their adoption is often compliance-driven, mandated by large acquiring banks or card schemes who are their direct customers," he adds.

Echoing similar views, Prabhakar notes, "Several vendors have achieved validation and some would have implemented or aligned processes to PCI SLC or PCI S3."

The familiarity is already substantial, according to Sekar, "largely because the RBI guidelines on payment security and application development show significant alignment and overlap with PCI SSF requirements." He further notes that directives on cyber security, cyber resilience, and digital payment security controls strongly influence SSF adoption.

"These guidelines incorporate SDLC and SSF-related requirements, creating a natural synergy with PCI SSF standards."

Rane also believes that the constant regulatory push creates a floor of awareness; and a "top-down mandate" for financial institutions to demand security assurance from their vendors. No vendor in the payment space can afford to be completely ignorant of the standard, even if their operational understanding is shallow.

"An SSF validation – especially the Secure SLC – provides an auditable, PCI SSC recognized solution that may assist financial institutions to satisfy due diligence requirements," he adds.

Prabakhar emphasizes the practical overlap, "The RBI guidance and SSF aligns on design and development, zero trust architecture, TPRM, risk based approach, evidence based compliance etc. PCI SSF requirements provide a strong guidance and inputs for financial institutions and their vendors a robust and modern framework to meet regulatory expectations and defend against sophisticated threats."

Major acquiring banks, responding to the regulatory mandates, demand SSF validation from payment service providers. Those PSPs, in turn, require it from their software vendors. What began as a card industry standard has evolved into a de facto requirement for participating in India's digital payment infrastructure.

Enterprise merchants rewriting procurement rules

Although banks and card networks have been the traditional drivers of security certifications, the demand is shifting downstream.

"Recent audits indicate that major clients and enterprise merchants increasingly expect vendors to comply with PCI SSF guidelines, making SSF validation a competitive advantage," says Sekar.

The mandate flows through established channels. RBI regulatory requirements drive major acquiring banks, which pressure large PSPs and enterprise merchants, who embed SSF validation requirements into vendor contracts.

Large e-commerce platforms, airlines, and retailers increasingly view third-party software as a major security risk – particularly after a series of high-profile breaches globally. "Major retailers, e-commerce players and enterprises handling large volumes of payment data are pushing for PCI SSF validated software," Prabhakar confirms.

In many new RFPs (Request for Proposals), SSF validation has replaced PA-DSS validation as a non-negotiable prerequisite, Rane claims.

Does SSF reduce PCI DSS scope for merchants?

The answer, like much else in security, is – it depends.

Rane says mature merchants see clear benefits. "Using validated software can simplify validation with PCI DSS v4.0.1, reduce audit burden, and shrink the scope of environments that touch sensitive card data. More importantly, Secure SLC assurance significantly can reduce vulnerabilities introduced through software updates – one of the most common failure points.

The scope reduction operates through familiar mechanisms. Using Secure Software Standard validated applications can simplify a merchant's PCI DSS compliance effort, often enabling migration to Self-Assessment Questionnaires. This proves particularly valuable when validated software effectively removes the most sensitive data – unencrypted PANs – from the merchant's environment, as occurs with certain payment gateway integrations.

"PCI SSF strengthens security during software development, while PCI DSS focuses on cardholder data protection during processing, storage, and transmission," Sekar explains. "Both frameworks complement each other to reduce overall risk exposure. However, SSF alone does not eliminate PCI DSS scope…it works in tandem with DSS for comprehensive security."

Prabhakar agrees that the impact varies by architecture. "It depends on where the cardholder data is stored, processed or transmitted. It may or may not directly change the scope, however it can reduce burden, scope and exposure if implemented in their environment."

The path forward

SSF is no longer being seen as a replacement for PA-DSS. It is becoming a strategic framework – a way for vendors to future-proof their software pipelines, for PSPs to reduce operational risk, and for merchants to harden their environments amid rising fraud sophistication.

The domestic security guidelines, combined with the industry's rapid innovation cycle, is pushing SSF from "optional best practice" to "expected minimum standard."

It is clear that software security can't wait for the next audit cycle. It must be built in – and  built in continuously. And PCI SSF, for now, appears to be the framework shaping that future.

Feedback, according to Bhatnagar, plays a critical role in the ongoing maintenance and development of these resources for the payment card industry. "Dedicated Request for Comments (RFC) periods are one of several ways that PCI SSC solicits feedback from stakeholders."

- This story is brought to you in partnership with PCI Security Standards Council.