Would older operating systems that are no longer supported by the vendor be deemed non-compliant with the PCI DSS?
Systems that use operating systems that are no longer supported with new security patches by the vendor, OEM, or developer are not necessarily out of compliance. Compensating controls could address risks posed by using older operating systems. Exploit of legacy code is the main risk posed by an older operating system. Since well-known exploits are typically included as signatures to anti-virus, IDS/IPS and firewall filtering, a compensating control to consider is performing an exhaustive search to ensure that all known exploits for that operating system are identified, and that anti-virus, IDS/IPS and firewall rules are all updated to address those exploits. Other compensating controls could include monitoring IDS/IPS and firewall logs more frequently than required (for example, the requirement is for daily log reviews, so more frequently may be continuously and automated), or isolating and segmenting their POS systems via firewalls from the Internet and other systems in the cardholder data environment. The eventual solution is to upgrade to a new and supported operating system, and the entity should have an active plan for doing so. For more help with compensating controls, and for questions about whether a specific implementation is consistent with the standard or is ‘compliant’, please contact a Qualified Security Assessor.