Compliance · PCI DSS v4.0.1
Can Copilot approve pull requests under PCI DSS?
No. PCI DSS v4.0.1 requirement 6.2.3.1 says manual code reviews must be performed by individuals other than the originating code author who are knowledgeable about secure coding, and that the review is approved by management before release. It also says knowledgeable third-party personnel may perform the review. Copilot is not an individual, so its approval cannot satisfy the requirement even where GitHub counts it toward required approvals. A PSCO Officer is a qualified third-party reviewer; the Approved Review is the review; your release owner merging is the management approval.
The mapping row
| Framework | Control | What it asks | How PSCO satisfies it |
|---|---|---|---|
| PCI DSS v4.0.1 | 6.2.3, 6.2.3.1 Code review before release | Manual reviews by "individuals other than the originating code author" who know secure coding, approved by management; "knowledgeable third-party personnel" allowed | Officers are qualified third-party reviewers; the Approved Review is the review; the customer's release owner merging is the management approval |
Verify before quoting
The 6.2.3.1 wording here is from a third-party summary. Verify it against the PCI SSC standard text before quoting it to an assessor.
Suggested control wording
Name the approver. Name the standard.
Paste this into your control description. The first sentence is the control; the second names the reviewer and the standard they review against, which is what an auditor needs to accept an outside approver.
All changes to production code require approval from a qualified reviewer who is not the author. Reviewers are PSCO Officers, background-checked US-based engineers contracted by the company, who review each change against the company’s Security & Compliance Model before approval.
Paths that touch cardholder data handling, cryptography and payments are Deep Review by default, so the review of bespoke and custom software in the cardholder data environment is performed by a senior Officer reading the sensitive hunks in full.
What a PCI DSS auditor samples
Build the record so it is already there.
Auditors test change management by sampling. These are the facts they look for on each sampled change, and where PSCO puts them.
- 01A sample of changes to bespoke and custom software in scope, each reviewed by someone other than the author (6.2.3.1).
- 02Evidence the reviewer knows secure coding: the Officer Dossier lists credentials and training.
- 03Management approval before release: the merge by your release owner, after the Officer’s approval.
- 04The secure-coding rules the review used: your Security & Compliance Model.
Auditor Guide
Hand your auditor the design once. Then they recommend it.
Before public launch PSCO briefed audit firms that together cover most startup and mid-market SOC 2 reports on the control design, the Officer Dossier and the Evidence Pack. The Auditor Guide is their questions, answered, for your auditor to read before the first sample.
The control design, the Officer Dossier and the Evidence Pack, written for your auditor.
A short PDF that answers the questions audit firms asked when we briefed them: who the approver is, how they are qualified, what the attestation records, and how to sample it. Enter a work email and we send the guide.
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