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VAPT requirements for compliance: PCI DSS, SOC 2, ISO 27001, HIPAA, GDPR and NIST

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?

FrameworkWhat it asks forTypical frequency
PCI DSS v4.0Internal and external pentest (Req. 11.4), segmentation testing, quarterly scans (Req. 11.3)Annual + after significant change; scans quarterly
ISO/IEC 27001:2022Management of technical vulnerabilities (A 8.8), security testing (A 8.29)Annual VAPT is common evidence
SOC 2Monitoring and risk-mitigation controls evidenced by independent testingAt least once in the audit period
GDPR (Art. 32)A process for regularly testing and evaluating the effectiveness of security measuresRisk-based; periodic VAPT recommended
NIST 800-171 / CMMCVulnerability scanning and security assessment of CUI systemsPeriodic, per the System Security Plan
DORA (EU financial sector)Digital operational resilience testing, including threat-led penetration testingAnnual testing; TLPT at least every three years for in-scope entities
HIPAARisk analysis and technical safeguards under the Security RuleRisk-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.

FAQ

Frequently Asked Questions

Clear answers about what we do — and what we don’t. If you have any other questions, feel free to reach out to our team.

Is VAPT mandatory for ISO 27001 certification?

ISO 27001 does not explicitly mandate VAPT, but certification auditors expect evidence that technical vulnerabilities are identified and managed, and VAPT reports are the most common evidence.

What is compliance penetration testing?

Penetration testing scoped and reported to meet a specific standard’s requirements, including methodology statements, control mapping and re-test evidence for auditors.

References & standards

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