PCI DSS 4.0 & VCC Security in 2026: The Compliance Playbook for Hotels and Travel Agencies

PCI DSS 4.0 & Virtual Credit Card Security in 2026: What Hotels and Travel Agencies Need to Know

Introduction

March 31, 2025, marked the final deadline for PCI DSS 4.0 implementation. For hotels and travel agencies, 2026 is the first full year of enforcement.... and this time, compliance is not a formality. With 64 new requirements, mandatory multi-factor authentication (MFA), continuous risk assessments, and strict controls on virtual card use, PCI DSS 4.0 has redefined what secure payment means in travel.

The reason is simple: card-not-present transactions dominate the industry. Roughly 80% of hotel bookings involve remote card payments, and 40% of B2B payments now rely on Virtual Credit Cards (VCCs). At the same time, data breaches in hospitality have surged, costing an average of $4.5 million per incident according to IBM’s 2025 report.

Yet, nearly one in three hotels still depend on manual PCI procedures, and fewer than 20% have full tokenization of virtual cards. The result? Unnecessary risk and not just of fines (which can exceed $100,000 per month) but also merchant account freezes and reputational damage from chargebacks and cardholder disputes.

Antravia Advisory explains what PCI DSS 4.0 means in practical terms for travel businesses. It highlights how to secure virtual card workflows, prevent compliance breaches, and maintain the guest trust your brand depends on.

What Changed with PCI DSS 4.0

PCI DSS 4.0 replaced version 3.2.1 in March 2022, introducing a risk-based model and continuous compliance requirements. The old annual audit cycle is gone. Now, security must be demonstrable every day of the year.

For hotels, that means every card transaction, so from an Expedia VCC to a manual entry at check-in, must meet current standards. For travel agencies, it extends to every booking page, every payment gateway, and every processor integration.

The most significant changes include:

• Continuous monitoring and quarterly testing. Businesses must now conduct regular penetration tests, not annual reviews.

• Mandatory multi-factor authentication. Every administrator with access to the cardholder data environment (CDE) must use MFA .

• Daily tamper checks. Websites that handle bookings or online payments must detect and report any unauthorized scripts or data injections.

• Enhanced tokenization. Full primary account numbers (PANs) can no longer be stored in spreadsheets, PMS exports, or unencrypted documents.

• Expanded scope. OTA integrations, GDS links, and cloud-based PMS systems are now explicitly covered.

In practice, PCI 4.0 turns payment compliance from a paperwork exercise into a continuous operational discipline.

But does this apply to the U.S.? YES - PCI DSS is a Global Standard - But U.S. Enforcement is the Toughest

The Payment Card Industry Data Security Standard (PCI DSS) was developed in the United States by the major card brands: Visa, Mastercard, American Express, Discover, and JCB. They operate under the Payment Card Industry Security Standards Council (PCI SSC), headquartered in Wakefield, Massachusetts.

That means any U.S. company that stores, processes, or transmits credit card data, whether directly or through a processor, must comply with PCI DSS. It applies regardless of size, industry, or whether payments are business-to-consumer (B2C) or business-to-business (B2B).

In practice, this includes:

• Hotels and travel agencies accepting card payments (including card-not-present transactions).

• Tour operators processing virtual credit cards (VCCs) from OTAs like Expedia or Booking.com.

• Payment gateways, booking engines, and reservation platforms based in the U.S.

It’s not a Law - But it’s Legally Binding through your Merchant Agreement

PCI DSS isn’t technically a government law, but it’s mandatory under all U.S. merchant agreements with Visa, Mastercard, Amex, and other acquirers. If a business doesn’t comply:

• The card networks can impose fines on your acquiring bank (up to $100,000 per month).

• The acquiring bank then passes those fines, chargeback penalties, and remediation costs down to the merchant (the hotel or agency).

• You can also lose your merchant account, which means you can’t process credit cards at all.

So, even though PCI DSS isn’t written into U.S. law like the IRS Code or state tax rules, it has contractual force, so breaking it can shut you down just as effectively as a legal penalty.

It applies to Virtual Cards and Online Bookings

In the travel industry, almost all transactions fall under PCI DSS because:

• 80% of travel sales are card-not-present (CNP), meaning you never physically see the customer’s card.

• Virtual Credit Cards (VCCs) issued by OTAs are treated the same as physical cards — they must be encrypted, tokenized, and handled within a PCI-compliant environment.

• Even if your OTA (e.g. Expedia) or PMS (e.g. Cloudbeds, Mews, Sabre) is compliant, you as the merchant are still responsible for how your team stores or accesses the card data.

Example:
If a U.S. hotel downloads VCCs into an Excel file or emails them to staff without encryption, that’s a PCI violation and even if Expedia itself is fully compliant.

There’s no “Small Business” Exemption

The U.S. PCI framework has four merchant levels:

Level 1 applies to businesses processing more than six million transactions a year, such as major hotel chains or airlines. These companies must complete a full annual audit known as a Report on Compliance (ROC).

Level 2 covers those processing between one and six million transactions, typically mid-sized OTAs or booking platforms. They are required to complete an annual self-assessment questionnaire (SAQ) and undergo regular network scans.

Level 3 applies to merchants processing between 20,000 and one million transactions annually, such as independent hotels or travel agencies. These businesses must complete the SAQ and perform quarterly vulnerability scans to verify compliance.

Level 4 includes small travel agents processing fewer than 20,000 transactions a year. They can usually validate compliance using the simplified SAQ A or SAQ A-EP forms, depending on whether they handle card data directly or via a hosted payment provider.

Even small U.S. travel agents who process a few thousand transactions per year must complete an annual Self-Assessment Questionnaire (SAQ) and quarterly vulnerability scans.

U.S. PCI DSS Enforcement Partners

In the U.S., PCI compliance oversight and enforcement come from:

• Card brands: Visa, Mastercard, Amex, Discover

• Acquiring banks: JPMorgan Chase, Wells Fargo, Elavon, etc.

• Processors: Stripe, Square, Global Payments, Worldpay

• Federal Trade Commission (FTC): Investigates deceptive security claims or data breaches under the Gramm–Leach–Bliley Act (GLBA) and FTC Safeguards Rule.

While there’s no “PCI police,” the penalties for data breaches or compliance failures are real, financial institutions have levied millions in fines following breaches at U.S. hotels and travel companies (e.g. Marriott, Hyatt, MGM Resorts).

Virtual Credit Cards in 2026

Virtual Credit Cards are now a critical part of B2B travel. They should make reconciliation easier and fraud harder but only when properly managed. But the same tokenization that makes them convenient also introduces compliance risk if data handling isn’t airtight.

Under PCI DSS 4.0, VCCs must be treated exactly like physical cards: encrypted, tokenized, and restricted to MFA-secured environments.

Common risk points include fake VCC issuance, ghost reservations, or declined cards that have already been used. The defenses are practical:

• Require issuer verification through authenticated APIs (e.g. Amex vPayment, Mastercard Easy PSP).

• Match each VCC to the booking reference automatically in your PMS.

• Use real-time authorization holds at check-in to prevent duplicate or expired charges.

• Capture digital folios and e-signatures at checkout to resolve future disputes.

In 2025, a 12-property boutique chain, adopted automated VCC tokenization and saw fraud incidents drop by 42%, dispute win rates rise 68%, and reconciliation time cut by 80%.

How to Build PCI 4.0 and VCC Compliance into Daily Operations

1. Define and Segment Your Data Environment

Start with a cardholder data flow map showing exactly where card data enters, moves, and is stored, from your PMS to OTA interfaces and payment gateways. Segregate card-processing systems from general networks like Wi-Fi or email servers.

If your system handles live card data, complete Self-Assessment Questionnaire (SAQ D). If it’s fully tokenized (e.g., Stripe or Adyen integrations), you may qualify for SAQ A or A-EP, significantly reducing scope.

2. Secure and Automate Core Processes

Enable MFA across all systems, including PMS, booking engines, and email platforms used for invoicing. Deploy tokenization for all virtual card transactions. Block unencrypted card storage at every level.

Automated tools can help:

• MFA providers such as Okta or Duo dramatically reduce credential attacks.

• Tokenized processors like Adyen, Stripe, or Basis eliminate PAN exposure.

• E-skimmer detection software prevents malware injection on booking pages.

• PMS integrations (e.g., Cloudbeds, Mews, Sertifi) can automate VCC capture and reconciliation, saving hours of manual entry each day.

3. Monitor and Test Regularly

PCI 4.0 requires ongoing testing, not annual certification. Hotels and agencies must:

• Run internal and external penetration tests every quarter.

• Perform daily tamper checks on payment pages.

• Conduct annual Reports on Compliance (ROCs) for Level 1 merchants.

• Reconcile VCC transactions monthly and investigate mismatches immediately.

These processes transform compliance from an audit cost into a proactive safeguard that reduces chargebacks and improves cash flow predictability.

Why Compliance is a Business Advantage

Tokenization and strong authentication can reduce interchange fees, lower chargeback rates, and improve merchant ratings with acquirers.

Antravia’s internal 2025 benchmarks found that tokenized, PCI 4.0-compliant travel businesses paid 1.8% average interchange fees, compared with 2.9% for non-compliant merchants. Chargebacks fell from 1.8% to 0.6%, and average audit costs dropped by two-thirds.

In a sector where reputation and trust directly drive bookings, compliance has become a competitive differentiator.

Antravia’s 2026 Compliance Accelerator

Antravia’s PCI DSS 4.0 and VCC Compliance Accelerator was built specifically for hotels, OTAs, and travel agencies handling card-not-present transactions. It includes:

• A 48-hour PCI 4.0 gap assessment

• Virtual card workflow redesign, integrated with your PMS

• Migration plan from SAQ D to SAQ A

• Staff security training and phishing simulations

• Quarterly mock audits to test controls before acquirer reviews

To start your audit-prepared compliance review, contact info@antravia.com for your PCI Scope Map and VCC Risk Score.

Conclusion

PCI DSS 4.0 is the foundation for secure travel payments in a digital-first world. In 2026, compliance is no longer optional. The winners will be the businesses that treat security as strategy, not paperwork. At Antravia Advisory, we help hotels and travel agencies turn compliance into confidence — combining financial discipline with technical control.

References

• IBM Cost of a Data Breach Report 2025 - https://www.ibm.com/reports/data-breach

• Visa Global Risk Report 2024 - https://usa.visa.com/partner-with-us/visa-consulting-analytics/economic-insights/global-risk-report.html

• Mastercard Risk Trends 2025 - https://www.mastercard.com/news/perspectives/2025/risk-trends-2025/

• PCI DSS v4.0 Requirements and Testing Procedures - PCI Security Standards Council - https://www.pcisecuritystandards.org/document_library?category=pcidss&document=pci_dss

• Global Business Travel Forecast 2026 - GBTA - https://www.gbta.org/research-insights/global-business-travel-forecast/

• Antravia Internal Benchmarking Report 2025

• Cloudbeds + Sertifi VCC Integration Case Study - https://www.cloudbeds.com/case-studies/sertifi-partnership

• Stripe Tokenization for Hospitality - https://stripe.com/use-cases/hospitality

• Sift E-Commerce Fraud Prevention 2026 - https://sift.com/resources/reports/ecommerce-fraud-prevention-2026

• PerimeterX Web Application Security for Travel - https://www.perimeterx.com/solutions/travel-hospitality

• Okta MFA for Hospitality Systems - https://www.okta.com/customers/hospitality/

• Antravia PCI Compliance Accelerator

Disclaimer:
Content published by Antravia is provided for informational purposes only and reflects research, industry analysis, and our professional perspective. It does not constitute legal, tax, or accounting advice. Regulations vary by jurisdiction, and individual circumstances differ. Readers should seek advice from a qualified professional before making decisions that could affect their business.
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