When a required PCI DSS control cannot be implemented due to technical limitations, the organization must apply acompensating control. A compensating control is an alternative safeguard that meets the intent and rigor of the original requirement.

Risk acceptance is insufficient under PCI DSS, as compliance demands enforceable safeguards. Privacy controls and protection levels may enhance data security but do not formally replace mandatory encryption requirements.

For example, a provider may use strict access controls, network segmentation, or monitoring to mitigate risks from unencrypted cardholder data. Documenting these compensating controls is essential during audits, ensuring compliance despite system limitations.