Published · By the Aesparrow Security Research Team
Short answer
PCI DSS explicitly requires penetration testing at least every 12 months and after significant changes, plus quarterly vulnerability scans. ISO 27001 and SOC 2 do not name penetration testing, but VAPT is the standard evidence for their vulnerability-management and security-testing controls. GDPR Article 32 requires regular testing of security measures, and NIST, CMMC and DORA all expect ongoing security testing.
Which frameworks require VAPT?
| Framework | What it asks for | Typical frequency |
|---|---|---|
| PCI DSS v4.0 | Internal and external pentest (Req. 11.4), segmentation testing, quarterly scans (Req. 11.3) | Annual + after significant change; scans quarterly |
| ISO/IEC 27001:2022 | Management of technical vulnerabilities (A 8.8), security testing (A 8.29) | Annual VAPT is common evidence |
| SOC 2 | Monitoring and risk-mitigation controls evidenced by independent testing | At least once in the audit period |
| GDPR (Art. 32) | A process for regularly testing and evaluating the effectiveness of security measures | Risk-based; periodic VAPT recommended |
| NIST 800-171 / CMMC | Vulnerability scanning and security assessment of CUI systems | Periodic, per the System Security Plan |
| DORA (EU financial sector) | Digital operational resilience testing, including threat-led penetration testing | Annual testing; TLPT at least every three years for in-scope entities |
| HIPAA | Risk analysis and technical safeguards under the Security Rule | Risk-based, commonly annual |
What happens if you do not comply?
Consequences range from failed audits and lost enterprise deals to regulatory penalties. Under GDPR, infringements can attract fines of up to €20 million or 4% of worldwide annual turnover, whichever is higher.

