It looks like the PCI Security Standards Council has posted their update to Requirement 6.6 (available here). They have provided information above and beyond what I mentioned last week. They have also provided a great deal of clarification around Web Application Firewalls.
Some interesting notes:
- Reviews can be performed by qualified internal or external individuals. However, internal auditors should not fall into the same organizational unit as the developers.
- There is text that identifies examples of where reviews will meet or exceed the quality of Web Application Firewalls. The two provided examples are:
- Security reviews of source code during the development process.
- Testing for the presence of web application vulnerabilities either manually or via a specialized tool
- Testing must occur prior to the Web Application going live (Note: Of course this doesn't mean testing should stop there, on going testing is key. As Braden Williams put it today, "You have to MAINTAIN what is assessed")
Trey Ford has a great write-up and answers some additional questions that people may have... I highly recommend reading it.