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Who Should Be Outsourcing PCI Compliance
Superheroes are great (on screen or in graphic novels).
Inside a business though, heroic efforts come with a price. And when those heroics revolve around managing PCI compliance, the costs show up not just on the P&L but also as impediments to innovation: Product teams have to work under the shadow of security audits as they develop their roadmaps, and engineering teams carry the burden of sustaining legacy decisions that no one remembers making.
For years, this was simply “how things were done”, and the cost in resources, investment dollars, and constrained product development was considered baked in, but the landscape has changed, and the cost of maintaining this heroic effort is skyrocketing.
As they did during the shift from on-prem infrastructure to the cloud, legacy merchants are experiencing a fundamental modernization moment of truth: Do we still want to own and manage PCI compliance, or is it time to hand off these responsibilities to a third-party?
A decade ago, running your own servers felt responsible, controlled, secure, and mature.
Then, companies realized managing this infrastructure wasn’t creating value; it was just eating up time and effort that could be more valuable elsewhere.
Similarly, managing PCI compliance in-house is emerging as a prime candidate for outsourcing.
What does it mean to outsource PCI compliance?
Outsourcing PCI compliance means shifting ownership of cardholder data storage, security controls, and a majority of audit obligations to a third-party vault or tokenization provider. For merchants, that usually means retiring an existing PCI program and consolidating data into a single source of truth. For fintechs and platforms, it often means never building one in the first place.
What does managing PCI in-house actually cost?
As with the cloud shift, the moment companies realize the need to offload PCI isn’t random: It happens when a CTO or CISO joins, regulations change, or after a breach or near-miss occurs.
These moments reveal that owning PCI delivers no competitive advantage, just extracts a heavy tax on your team. A typical PCI program will consume:
- 1-2 data security team members.
- 1-2 engineers who rotate throughout the year.
- As-needed support from DevOps, QA, and other internal teams.
What are they doing?
- Audits that take up to six months.
- Security reviews of potential vendors, customers, and partners.
- Internal training on security best practices.
- Somehow, keeping up with core product development and deployment.
That final bullet point is the silent killer. While security shouldn’t have an adversarial relationship with product or engineering, when the product roadmap meeting revolves around “what we can ship without blowing up PCI,” things can get a little tense.
What causes a company to outsource PCI responsibilities?
Eventually, every organization hits a point where the internal costs of PCI become impossible to ignore. Companies will often offload PCI when one or more of these happen internally:
- A new head of security joins.
- A product initiative is blocked by PCI.
- A PSP contract expires.
- Reliability requirements increase.
- New regional compliance requirements are imposed.
PCI isn’t the problem: PCI ownership is.
For merchants, outsourcing PCI is about reclaiming a roadmap. For fintechs, it’s often about never blocking their roadmap in the first place.
A fintech issuing cards, moving money, or storing payment credentials doesn't have the luxury of a "someday" PCI program. Compliance scope appears on day one, before there is revenue to justify the headcount.
This is why fintechs are increasingly building on third-party vaults from the start, rather than absorbing PCI scope and then outsourcing it later.
Marble, an insurtech platform, took this approach to keep its underwriting and payments infrastructure PCI compliant. Without adding to its headcount, Marble worked with Basis Theory to maintain PCI compliance.
“We knew as we built our customer experience, we always needed to remain in PCI compliance,” explains Matt Donofrio, Head of Revenue at Marble. “It was much easier for us to offload those responsibilities to an organization that is already PCI compliant.”
Marble implemented Basis Theory in less than 30 days.
“We needed a solution that we could implement quickly and was not super operationally heavy,” Donofrio explains. “It was clear to me that Basis Theory was what we needed and I’d be hard-pressed to think there’s something more relevant to what we were trying to solve—which was to maintain PCI compliance.”
Where is your cardholder data going when you outsource PCI?
Storing raw cardholder data, even with strong controls, puts a target on your back.
Access permission management mistakes, audit gaps, misconfigurations, cloud drift…any one of these can create exposure with long-term consequences.
And for what? None of these risks are revenue-generating.
Even though you remain in compliance, staying competitive introduces a new challenge entirely: data quality.
Historically, six-digit BINs (Bank Identification Numbers) were enough for reliable identification. Today, BINs have grown to eight and even ten digits. Overlaps are occurring more frequently, and fuzzy matches are increasing.
Payment Service Providers (PSPs) often don’t expose the full data set, or provide real transparency into it, and the only way to be certain your transactions will be honored is to use the full PAN (Primary Account Number.)
Doing so, however, requires moving your payment systems into PCI scope, which most merchants cannot and should not do, given the cost in time and investment dollars.
This creates a turning point for merchants and fintechs who want accurate routing, improved authorization rates, fraud modeling, and payment optimization, but not the PCI scope.
And this is where a third-party token vault makes all the difference.
What do you get with a third-party vault instead?
Using a third-party vault can eliminate as much as 90% of PCI compliance requirements—much more than just audit relief. This isn’t outsourcing, it’s upgrading your capabilities.
- Multi-Processor Flexibility: Bring your own PSP, test new PSPs, and add and remove as many as necessary to meet demand and margin needs.
- Network-Level Capabilities: Network tokens, account updater services, and metadata directly from the card networks can be accessed without falling afoul of PCI rules.
- Product Velocity: Ship new features faster without engineers having to play superhero to satisfy PCI scope and the needs of legacy systems.
The vault becomes the reliability anchor for the entire payment stack. With that foundation in place, the biggest platforms in the world—be it a global merchant, fintech, or subscription platform—don’t have to rely on a single PSP or tie themselves to a specific processor’s infrastructure.
You get direct-to-network capabilities without storing raw card data within your own systems, yet enjoy reliability and flexibility that processors can’t match, while reducing your PCI burden.
FAQs About How a Fintech Can Outsource PCI Compliance
Do fintechs need to be PCI compliant?
Any company that stores, processes, or transmits cardholder data is in PCI scope, regardless of size or industry. Fintechs can avoid taking on that scope directly by routing card data through a compliant third-party vault instead of touching raw card data themselves.
Can a fintech avoid PCI scope entirely?
A fintech can eliminate most PCI scope by never storing or touching raw cardholder data. With a third-party vault provider, the raw cardholder data is tokenized at capture. Some scope may remain depending on how card data flows through the fintech's own systems.
How much of PCI scope can a third-party vault remove?
Using a third-party vault can eliminate as much as 90% of PCI compliance requirements.
In practice, that shows up in which Self-Assessment Questionnaire (SAQ) a company qualifies for. A company that never touches the raw Primary Account Number because card capture happens entirely within the vault can qualify for SAQ A, the shortest questionnaire, with around 20 to 30 requirements.
Compare that to SAQ D, which applies to companies storing or processing cardholder data directly and can run into several hundred requirements. Some scope may still remain depending on how card data flows through a company's own systems.
PCI will always exist, but it doesn’t need to live within your systems. Retiring PCI capes lets you reclaim your roadmap and give engineering teams the freedom to get back to building again.
See how fintechs like Marble stay PCI compliant without the operational lift. Talk with our team about your use case.
