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Retail AI agent · PCI attestation

PCI Attestation Evidence AI Agent

Read the acceptance channels back to the tier they imply, hold the evidence and its currency behind each requirement, and put the open gaps in front of the officer before they sign.

Typical delivery
4–6 weeks
Deployment
Your stack
Officer signs
Before signing
After launch
Agent Care

What this agent does

Works the evidence, never the attestation

In

  1. 01

    A payment page changes, and the change is logged against the acceptance channel it sits on and the tier that implies.

  2. 02

    A channel is inventoried with what it sends, where it sends it and which systems touch it.

Reason

  1. 03

    An iframe stays an iframe: FAQ 1588 of 28 February 2025 holds the processor route to embedded forms.

  2. 04

    A processor confirmation is filed, and the solution it names is matched to the page as deployed.

  3. 05

    A requirement is answered, and the evidence and the date it was gathered ride with the answer.

Decide

  1. 06

    A quarterly ASV scan lands, and the failures and the rescans are kept too.

  2. 07

    An attestation falls due on the date your acquirer set; in Nevada NRS 603A.215 also makes it a duty.

Out

  1. 08

    A gap stays open, and it is carried on the pack as an open gap rather than closed by inference.

  2. 09

    Execute write actions only inside the approval boundaries agreed during implementation.

Product statement

The agent assembles the pack; a named executive officer signs. It never attests, never determines compliance, and never confirms the scope boundary.

Example workflow

One attestation year, channel to signature

  1. 1Acceptance channels receivedPayment stack, gateway config, checkout release notes or scope inventory
  2. 2Evidence gatheredRequirement evidence, scans, tests, third-party AOCs and the rationale behind each entry
  3. 3Pack draftedTier position, per-requirement evidence, open gaps and confidence
  4. 4Controls appliedEvidence-binding checks, eligibility-criterion checks, currency checks and confidence threshold

No human action required

Stages 1 to 4 run unaided, and nothing is attested at any of them — the agent is assembling, and the officer's lane opens at the confidence gate.

5DecisionBranches at the confidence threshold
High confidence

Goes to the executive officer to review.

Low confidence

Adds a QSA read first.

Officer approval

The pack is held with its open gaps, its evidence dates and the confidence.

Approve · Amend · Send to QSA

Approved — released to sign

  1. 6Compliance records updatedOnly where write access and approval policy allow it
  2. 7Outcome evaluatedEvidence coverage, gaps closed, acquirer acceptance and post-submission queries

Amendments

Officer amendments are counted in the evaluation.

What should not run autonomously

Human approval stays in control

Outside the boundary — human approval required

8 items

  • Signing the attestation of compliance.
    • Determining that the entity is compliant.
    • Confirming the cardholder data environment scope.
    • Deciding which questionnaire the merchant may use.

  • Automation boundary

    Agent acts unaided

    • ✓Map acceptance channels to the criteria each questionnaire sets.
    • ✓Carry each requirement with the evidence and date behind it.
    • ✓Track scan, penetration-test and third-party AOC currency.
    • ✓Report the requirements still open, and what each one is still missing.

    The officer signs. After a breach, Washington's shield needs an assessment under a year old.

    • Marking a requirement not applicable.
    • Accepting a compensating control as adequate.
    • Submitting the pack to the acquirer.
  • Changes to tier, scope or approval rules.

Example output

One requirement, annotated

What the agent records is attached to the evidence it came from.

Attestation output · single requirement

Illustrative example
Requirement
PCI DSS v4.0.1 · 11.3.2
What the evidence shows
Quarterly ASV scan passing; the failing scan it replaced and the rescan are both on file
Currency
Within the quarter
Source on file
ASV scan report
Confidence
88%
Disposition
Held for the executive officer

As received

Taken from the scan reports and the change record as filed — nothing on this side is asserted by the agent.

Evidence used

  • ASV scan report
  • Rescan and remediation
  • Change-record entry

Why this is held

The officer is promising controls will be maintained, not only that they were.

What the score decides

Below the configured threshold the pack adds a QSA read before it reaches the officer.

Action

ApproveAmendSend to QSA

Value

Where AI adds value

The same four claims, placed at the point in the workflow where each one applies.

Where the value lands

Value 01 – 04

Every acceptance channel

From the payment stack

03Assembly

Build the pack from the evidence

Draw on the scans, tests, AOCs and change records on file. The Council's note of 30 January 2025 replaced SAQ A Requirements 6.4.3, 11.6.1 and 12.3.1 with an eligibility criterion, in force 31 March 2025.

01Approved path

The tier is a consequence

Which questionnaire you may use follows from how the channels actually accept cards, and that criterion is met only by an implementation record or a written processor confirmation covering the solution as deployed.

02Human review

Not the transaction, the environment

The payment-fraud agent scores one transaction and leaves declines above the threshold to the fraud analyst. This one works an annual attestation about an environment, and a checkout change is a scope event it has to be told about.

04

Build an evidence trail

The channel, the requirement it pulls in and the officer who signed stay on the attestation.

Integrations

Typical integrations

Five system groups connect to the same agent. Which of them are in scope is decided in discovery.

  • Gateways and processors

    • Stripe
    • Adyen
    • Worldpay
    • Checkout.com

  • Commerce and checkout

    • Shopify
    • BigCommerce
    • Salesforce
    • custom checkout

  • Scanning and testing

    • Qualys
    • Tenable
    • ASV portals
    • test reports

Agent

PCI attestation evidence

  • Reads the channels
  • Assembles the pack
  • Holds for the officer

  • Evidence and GRC stores

    • Vanta
    • Drata
    • ServiceNow
    • Jira

  • Observability & evaluation

    • OpenTelemetry
    • Langfuse
    • Supported monitoring/evaluation sources

Integration availability depends on the client's existing systems and API access.

Agent controls

Six layers between the model and the attestation

Six layers, each tighter than the last. What the whole stack misses is drawn in the map below.

L6 · Outermost — last line of defence

Inward → L1 · closest to the model

L6Rollback / safe modeHold the pack at unattested when evaluation or production signals degrade.Roll back
L5Version monitoringTrack model, prompt, eligibility-rule and tier-configuration changes.Track
L4TraceabilityRecord the evidence, its date, the open gaps and what the officer was shown.Record
L3Officer approvalHold packs for the named officer; it governs release, not whether the position is right.Gate
L2Policy guardrailsTest each entry against the criterion as written and the evidence cited; a failure returns it.Restrict
L1Confidence thresholdsRoute low-confidence packs to a QSA read before the officer sees them.Require review
Model corePack assembled — tier position, per-requirement evidence, open gaps and confidence
L1 – L2
Test whether an entry may stand
L3
Puts the release in an officer's hands
L4 – L5
Keep the channel and the requirement behind it
L6
Holds the pack at unattested when signals degrade

How Nestack evaluates it

Evaluate the whole assembly — not only the finished pack.

Coverage runs the whole depth of the workflow, and every layer is cut by slice.

Surface — the pack the acquirer reads

  1. E1Final-output evaluationDid each requirement entry cite evidence that actually supports it?
  2. E2Step-level evaluationDid the agent use the right criteria, scope inventory and change records?
  3. E3Tool evaluationDid it read and write the correct requirement and the correct channel?
  4. E4Confidence calibrationDo low-confidence entries actually attract more officer amendments?
  5. E5Slice evaluationHow does performance change across acceptance channels and entity types?
  6. E6Business outcomeHow many entries needed an amendment or a correction after the pack went in?

Floor — the outcome the officer answers for

Failure modes

Where each failure originates in the agent

Seven failure modes, each pinned at the stage where it first arises.

Agent lifecycle

Direction of processing →

  1. 01 · Retrieval

    1 mode

    • HF-03

      Stale channel inventory

      A checkout change never reaches the scope record.

    Stage gathers

    Channel inventory, evidence, scans and change records

  2. 02 · Reasoning

    2 modes

    • HF-04

      Criterion read too widely

      A processor letter is read as covering a solution it does not name.

    • HF-06

      Rationale restates the answer

      A not-applicable entry repeats its conclusion instead of the flow evidence.

    Stage proposes

    Tier position, evidence, gaps and confidence

  3. 03 · Tool / write

    2 modes

    • HF-02

      Connected systems omitted

      Systems that merely connect to the environment are left off.

    • HF-05

      Passing scan kept alone

      The failing scan and its remediation record are dropped.

    Stage writes

    Only where write access and approval policy allow it

  4. 04 · Output

    1 mode

    • HF-01

      Entry without evidence

      A requirement entry cites nothing on file.

    Stage returns

    The pack the executive officer reads before signing

  5. 05 · Change / Version

    1 mode

    • HF-07

      Silent eligibility regression

      A model or rule change loosens what counts as eligible.

    Stage tracks

    Model, prompt, eligibility rules and tier config

  • Sev-1 · agent acts outside the boundary
  • Sev-2 · a wrong entry reaches the pack
  • Sev-3 · source degrades, pack goes to review
See the complete Retail & E-commerce failure-mode catalogue

Affected slices

The estate reads clean until you split it by channel

An estate-level scope-boundary figure can look settled while one acceptance channel holds most of the unevidenced requirements. Nestack reports the gap rate by channel, not only in total.

Slice performance — reported separately, not only in aggregate

Illustrative example
SliceFailure rateLiftLift vs. thresholdStatus
Embedded iframe checkout6.6%3.7×Review
Acquired-brand checkouts4.8%2.7×Review
Mail order and telephone order3.0%1.7×Watch
Fully outsourced storefronts1.5%0.8×Normal

Bar: unevidenced-requirement lift vs. fully-outsourced baseline · scale 0–4.0× · tick marks the 2.0× review threshold

2 of 4 slices over threshold

Evidence-linked improvement

A cycle is not closed until it is a test

A cycle closes when the wrong tier is a regression case. That suite is what the next attestation packed is measured against.

Improvement cycle · five stages

Switchback — the path turns at Improve and returns at Learn

  1. 01

    Detect

    The unevidenced-requirement rate rises in one channel.

  2. 02

    Diagnose

    The one page that stopped being an iframe in a sprint nobody logged is read back through its change record until the cause narrows to one.

  3. 03

    Improve

    The change goes out with a number, and the channels behind it travel with it.

  4. 04

    Verify

    Nothing signs while one touched channel case is still red.

  5. 05

    Learn

    It is kept for good, and the eligibility rules are amended in the same commit.

  6. Learn → Detect

    The return edge. The next detection runs against a suite this one made longer.

Typical build scope

Twelve workstreams across six weeks

The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, pack assembly, evaluation, integration, then production validation and handover.

Workstream

Week 1Week 2Week 3Week 4Week 5Week 6

  1. 01Attestation scope discovery and boundary definition.Week 1
  2. 02Payment-stack and evidence-source review.Week 1, Week 2
  3. 03Tier eligibility and scope-boundary rule mapping.Week 1, Week 2
  4. 04Channel inventory and evidence intake.Week 2
  5. 05Pack assembly and evidence binding.Week 2, Week 3
  6. 06Confidence scoring and open-gap routing.Week 3
  7. 07Officer approval workflow.Week 3, Week 4
  8. 08GRC and scan-portal integration.Week 5
  9. 09Eligibility and scope cases.Week 4, Week 5
  10. 10Guardrails and attestation controls.Week 4
  11. 11Channel-trail instrumentation.Week 5, Week 6
  12. 12Deployment, documentation and Agent Care handover.Week 6

12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallel

Final scope and sequence confirmed in discovery

Engagement tiers

What each tier includes

Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.

Capability✓ in scope · — not at this tierPilotOne channel, one entityProductionProduction evidence systemsAdvancedMultiple entities / brands
Introduced at Pilot
Assembly to your channels and rules✓✓✓
Officer approval✓✓✓
Scope-boundary baseline✓✓✓
Introduced at Production
Reporting by channel—✓✓
Approval workflow in your systems—✓✓
Approved write-back—✓✓
Payment-stack integration—✓✓
Introduced at Advanced
Multi-questionnaire tier rules——✓
Multi-stage attestation approvals——✓
High channel count——✓
Multi-entity attestation controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build price
Confirmed after discovery based on integrations, workflow complexity, transaction volume, approval controls and deployment requirements.
Separate from build
Build pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.

What we need from you

What you bring, and what we build with it

Each input maps to a piece of build scope and a week in the delivery timeline.

  1. 01Your acceptance channels and payment stack

    Channel inventory and evidence-record intake

    Week 1

  2. 02Representative evidence from last year

    Coverage baseline, evidence binding and gap handling

    Week 2

  3. 03Your tier, scope and eligibility rules

    Tier eligibility and scope-boundary rule mapping

    Week 1

  4. 04Access to relevant APIs, feeds or exports

    Payment-stack and evidence-source review, then integration setup

    Week 2

  5. 05Attestations you would not want tested

    Tier-eligibility cases and failure testing

    Week 4

  6. 06What no attestation may promise

    Confidence scoring, gap routing, guardrails and approval controls

    Week 3

  7. 07A named executive officer to review packs

    Officer approval workflow, then pilot and production validation

    Weeks 5–6

Nothing else is required

Deployment, documentation and Agent Care handover are ours.

Delivery timeline

Four phases across six weeks

The plan runs on the weeks that were genuinely worked, so the pair sitting in week five is honest.

Phase

W1

W2

W3

W4

W5

W6

  1. DiscoveryW1
  2. BuildW2 – W3
  3. EvaluateW4 – W5
  4. Pilot & LaunchW5 – W6

Week focus

W1Attestation scope discovery, tier mapping and the automation boundary

W2Payment-stack integration and the evidence baseline

W3Pack assembly, currency logic and approval controls

W4Evaluation suite, gap handling and failure-mode testing

W5GRC integration, pilot requirements and targeted corrections

W6One attestation year run under the executive signer, then Agent Care handover

Reading the band
Each bar spans the weeks its own work is named in, and no more. The week 5 overlap is real.
At the end of W6
Validation closes on live channels, and Agent Care picks up monitoring.
Duration
Six-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.

Next step · Retail AI agent

Build an attestation-evidence agent around the pack your officer signs.

It does not attest, determine compliance or confirm your scope, and Minnesota is not the PCI state it is widely called — § 325E.64 bans retained security codes and mandates no standard. Show us your channels and who signs, and we hand your officer the gaps.

Typical delivery
4–6 weeks
Deployment
Your payment stack
Officer signs
Before signing
After launch
Agent Care available

Nestack Agents · PCI attestation evidence

AGT-RT-22 · Agent Care available after launch

Build an attestation-evidence agent

Four questions so the call starts from your actual setup — then pick a time that suits you.

About you
Your channels

No obligation. We’ll map the workflow, name the automation boundary and tell you if an agent is the wrong answer.