'Best practice until a future date' requirements
If you have not yet implemented a future-dated new requirement and are completing a PCI DSS document prior to the effective date of the new requirement, you can mark it as "Not Applicable."
If you rely on a third-party service provider (TPSP) to meet PCI DSS requirements on your entity’s behalf, and:
The TPSP has not yet been assessed against the new version of the standard,
or
The TPSP has been assessed to the new version of the standard, but the assessment was prior to the effective date of new requirements, and did not include those new requirements,
Then, providing that the TPSP has a valid PCI DSS assessment, the entity’s assessor may mark those requirements upon which the entity relies as “Not Applicable.”
If an entity or TPSP has implemented a future-dated requirement prior to its effective date and wants to include it in its PCI DSS assessment, they may choose to do so by marking it ‘’Yes’’.
In all cases, starting from the effective date, all new PCI DSS requirements applicable to an entity’s assessment (including those met by a TPSP on the entity’s behalf) must be fully considered as part of the entity’s PCI DSS assessment.