Reflectiz PCI DSS Module: Independent QSA Assessment by Integrity360
An independent PCI assessor tested Reflectiz against the new PCI DSS rules. Here is the verdict: See the full QSA assessment here →
When a customer types their card number into your checkout, their browser is running far more than your code. Analytics tags, a tag manager, a support widget, a payment iframe: a modern checkout loads dozens of third-party scripts, and any one of them can be turned into a skimmer.
This is how Magecart works. Sansec has counted more than 100,000 sites hit by web skimming and supply-chain attacks. The 2018 British Airways breach alone exposed 380,000 transactions and a fine that started at £183 million.
The dangerous part: the malicious code usually arrives through a script you already approved. Attackers compromise a third-party vendor, and the payload rides in on a script you have run for months. Nothing looks new. What changed is the script’s behavior, not its presence on the page.
PCI DSS v4.0.1 closes that gap with two requirements, now fully in force. 6.4.3 says inventory every payment-page script, authorize it, and prove its integrity. 11.6.1 says detect tampering with page content and HTTP headers as the browser receives them. Done by hand, across hundreds of scripts that change constantly, this does not scale. Reflectiz data shows roughly 30% of payment-page scripts change within any two-week window.
What the QSA Found
Integrity360 Europe, a PCI Qualified Security Assessor and member of the PCI SSC Global Executive Assessor Roundtable, reviewed the Reflectiz PCI DSS Platform against both requirements and found it can effectively support compliance. Three things stood out:
- It watches behavior, not just file hashes. A hash check misses a silent vendor-side swap. Reflectiz catches the script the moment it starts reaching for card data.
- It deploys agentless. No code changes, no snippets, live in days, and it keeps working through refactors and CMS migrations.
- It produces QSA-ready evidence in one click. Full audit trail per page, ready for assessment.
The SAQ A Catch
Since January 2025, merchants can drop 6.4.3 and 11.6.1 from SAQ A only if they confirm their site is not susceptible to script attacks. Full redirect to your processor? You are likely fine. Embed a payment iframe? A script on the parent page can still hijack the checkout before data reaches the secure frame, and you have to prove it cannot. PCI SSC FAQ #1588 points straight back to these same controls.
Get the Full Assessment
The complete Integrity360 Europe white paper breaks down both requirements line by line, the monitoring workflow, and exactly what SAQ A now demands of iframe merchants.
FAQs
How does the platform satisfy PCI DSS Requirement 11.6.1?
Requirement 11.6.1 requires tamper detection for HTTP headers and payment-page content as received by the consumer’s browser, at least every seven days. The platform monitors response headers each scan cycle, comparing them against an approved baseline and flagging any addition, deletion, or modification, including changes to Content-Security-Policy, Strict-Transport-Security, and X-Frame-Options. Because it observes headers as the browser receives them, it catches changes introduced by intermediate layers like CDNs or load balancers that server-side monitoring would miss. It runs more frequently than the seven-day minimum by default, is configurable per page to align with Requirement 12.3.1 targeted risk analysis, and integrates with Splunk, Jira, and any SIEM or SOAR supporting a JSON REST API.
How does the platform satisfy PCI DSS Requirement 6.4.3?
Requirement 6.4.3 has three obligations: maintain a script inventory with written justification, authorize each script, and assure each script’s integrity. The platform auto-builds a per-page inventory covering first-, third-, and fourth-party scripts, including those loaded dynamically by tag managers. It authorizes scripts through a structured approval workflow that stores a business justification against each script and page, timestamped and attributed to the approver. For integrity, its behavioral engine detects changes to what a script does at runtime, not just its file hash, so it catches a silent vendor-side replacement even when the new file’s hash looks legitimate. Smart Approval and Bulk Approval reduce repetitive review by auto-processing scripts that match approved behavioral baselines.
How does the Reflectiz PCI DSS Platform monitor payment pages?
It runs a continuous four-phase cycle. First, an agentless browser crawls designated payment pages, simulating real checkout and authentication flows, and maps every script, iframe, pixel, cookie, and HTTP header. Second, it performs deep behavioral analysis, recording JavaScript execution, DOM interactions, form-field access, network requests, and data transmission to answer what each component is, what it does, and where it sends data. Third, it cross-references behavior against reputation databases, vulnerability registries, and Reflectiz intelligence to assign an exposure rating. Fourth, it alerts on new scripts, behavioral changes, and header modifications, retains timestamped approvals, and exports QSA-ready evidence in one click.
Is the Integrity360 Europe assessment a PCI DSS compliance certification?
No. The exercise was a capability review of the Reflectiz PCI DSS Platform, not a PCI DSS compliance determination for any specific customer environment. The assessment confirms the platform can be effective in supporting Requirements 6.4.3 and 11.6.1 when properly deployed, configured, and integrated into a wider governance, risk, and compliance program. Actual compliance, SAQ eligibility, and any assessment outcome always depend on your own environment, payment flow, implementation, and confirmation from the relevant compliance-accepting entity.
What did Integrity360 Europe conclude about the Reflectiz PCI DSS Platform?
Integrity360 Europe, a PCI Qualified Security Assessor Company and member of the PCI SSC Global Executive Assessor Roundtable (GEAR), assessed the platform against PCI DSS v4.0.1 Requirements 6.4.3 and 11.6.1. Its finding: the platform provides automated, continuous monitoring of payment-page scripts and HTTP headers that can be effective in supporting compliance with both requirements when correctly deployed and integrated into an organization’s GRC program. Integrity360 Europe also noted that correct use of the platform may help merchants meet the SAQ A eligibility criteria confirming a site is not susceptible to script attacks.
What did the assessment say about SAQ A eligibility for iframe merchants?
Merchants who outsource payment processing may skip 6.4.3 and 11.6.1 from SAQ A only if they confirm their site is not susceptible to script attacks. The assessment notes that PCI SSC FAQ #1588 states one way to confirm this is by using techniques such as those detailed in Requirements 6.4.3 and 11.6.1. Integrity360 Europe’s opinion is that correct implementation of the Reflectiz PCI DSS Platform may help merchants meet that SAQ A eligibility criterion. This matters for iframe merchants, since a script on the parent page can still target account data before it reaches the secure frame.
Why does the assessment favor behavioral analysis over file hashing?
Because eSkimming attacks usually arrive through a script you already approved. Attackers compromise a third-party vendor, and the malicious payload loads via a legitimate script you have run for months. The change is in the script’s behavior, not its presence. A hash check confirms a file matches a known value, but it cannot tell you a vendor-side swap is malicious once the new hash becomes the baseline. The platform observes runtime behavior, so a script that begins reading card-data form fields or exfiltrating to an unfamiliar domain triggers an alert regardless of how the change was introduced.
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