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Penetration Testing Requirements by Regulation: A Matrix

By Owen Thurm Published 6 min read

Penetration Testing Requirements by Regulation: A Matrix

Quick answer. NYDFS, VARA, PCI DSS and Kenya require yearly pentests. DORA requires yearly tests of critical systems, and TLPT every 3 years for identified firms. MAS, SFC and HKMA expect them; SOC 2 and ISO 27001 mandate none.

Watch: Penetration Testing Requirements by Regulation: A Matrix 1:48
Video transcript

Licensed in two places? You may face two pentest calendars. Here is who requires pentests, and how often.

NYDFS, VARA, PCI DSS and Kenya require pentests at least yearly. DORA requires yearly tests of critical systems, with pentesting one listed test.

DORA also requires threat-led testing of live production systems, at least every three years, for firms their authority identifies.

The verb matters. MAS, the SFC and the HKMA say should, not must. SOC 2 and ISO 27001 mandate no pentest at all.

Some rules reach smart contracts. VARA asks for audits where relevant, the HKMA yearly and on every upgrade. MiCA applicants describe a third-party audit if available, and CCSS requires one even at Level I.

In several jurisdictions? Build one plan around the strictest rule. Test at least yearly and after significant change, with a qualified, independent tester. Scope in wallets and custody, and plan for TLPT if DORA or VARA may call for it.

Then keep one evidence file, from scope to retests, mapped to each provision so one report answers several.

Guardian's pentests cover infrastructure, apps, APIs and offchain automation, each closed with a retest. Its Regulatory and Compliance service maps each report to the provisions it answers. Guardian is not a law firm, and works alongside your counsel.

Read the full matrix, or talk to Guardian about one test plan for every rule.

A crypto firm licensed in two places can end up on two pentest calendars. The rules differ on who must test, how often, and how firmly they ask.

This matrix puts them side by side, checked against each text in November 2026.

This article explains the technical and security side of the penetration testing provisions compared below. It is not legal advice; confirm how it applies to you with counsel.

How to Read the Matrix

Each row is one provision. The columns:

  • Covers: who the provision reaches.
  • Testing: what it asks for, in short.
  • Frequency: the minimum cadence the text sets, if any.
  • Verb: how firmly the text asks, in its own words where quoted.
  • Status: what kind of text it is, and since when.

The verb matters. In the HKMA's guideline, "must" marks a statutory requirement and "should" a regulatory expectation.

Guidelines still count. MAS says the degree of observance of its TRM Guidelines is an area of consideration in supervision.

Europe and the United States

ProvisionCoversTestingFrequencyVerbStatus
DORA Arts. 24 and 25EU financial entities, including CASPsRisk-based program; pentesting is one listed testYearly, on systems behind critical functionsshallApplies since Jan. 17, 2025
DORA Art. 26 (TLPT)Entities their authority identifiesThreat-led test of live production systemsAt least every 3 yearsshallApplies since Jan. 17, 2025
MiCA RTS 2025/305 Art. 9CASP applicantsThird-party audit with pentests and contract code reviewWith the applicationshall, "if available"Delegated Regulation, in force
NYDFS 500.5(a)(1)Firms licensed under NY banking, insurance or financial services lawInside and outside, by a qualified partyAt least annuallyshallIn force; current text since Apr. 29, 2024
NYDFS 200.16(e)(1)BitLicenseesPentest, plus vulnerability assessmentPentest yearly; assessment quarterlyshallIn force

DORA does not name a yearly pentest. Article 24(6) requires "appropriate tests" at least yearly, and Article 25(1) lists penetration testing among them.

The yearly floor applies to financial entities other than microenterprises. For TLPT, the authority may raise or lower the 3-year frequency on the firm's risk profile.

MiCA's application rules ask for a third-party cybersecurity audit "if available". It covers "ideally" pentests and, where the applicant uses smart contracts, a source code review.

Part 500's limited exemption in 500.19(a) reaches 500.5. It covers firms with fewer than 20 employees and contractors, under $7.5 million in revenue in each of the last three years, or under $15 million in assets.

That exemption lists Part 500 sections only; Part 200's rule for BitLicensees is separate. Detail: DORA's testing rules and NYDFS 500.5.

UAE, Asia and Africa

ProvisionCoversTestingFrequencyVerbStatus
VARA Rule I.E.1VASPs licensed by VARA in DubaiIndependent pentests; smart contract audits where relevantYearly and before new systemsmustRulebook; current version since June 19, 2025
MAS TRM 13.2Financial institutions MAS supervisesBlackbox and greybox tests of online servicesInternet-facing: yearly or after major changeshould; "is expected to"Guidelines, January 2021
SFC VATP 12.13Licensed virtual asset trading platformsIndependent assessment with pentests and custody code reviewBefore launch and changes, then periodicallyshouldGuidelines, June 2023
HKMA 6.5.5, 6.5.17, 6.5.19Licensed stablecoin issuersPentests, attack simulation, contract auditsContract audit yearly and on upgrade; tests by riskshouldGuideline, August 2025
Japan FSA policyCrypto exchangesTLPT; the FSA will test several exchangesNone set; FSA pilot within 2026"need to"Policy, April 3, 2026
Kenya VASP Regs. 97(4)(a)VASPs licensed by the CBK or CMAVulnerability assessment, risk assessment, pentestTwice in year one ("bi-annual"), then at least yearlyshallLegal Notice 134, gazetted July 22, 2026

VARA can also require threat-led testing by notice, run by an external tester (Rules I.E.5 and I.E.6).

The SFC's assessment "should at least cover" user apps, wallets, physical security, and network and system security.

The HKMA also expects a qualified third party to audit a stablecoin's smart contracts at least yearly, and on every deployment or upgrade (6.5.5).

Japan's policy says exchanges "need to" find weak points through TLPT, but sets no cadence. Within 2026, the FSA will conduct TLPT on several of them; see Japan's exchange cybersecurity policy.

Kenya also asks for a pentest before licensing. The application must include an independent information systems audit, with a vulnerability assessment and pentest (regulation 6(2)(l)).

Our Kenya post maps the rest.

Standards and Certifications

ProvisionCoversTestingFrequencyVerbStatus
PCI DSS 11.4.2, 11.4.3Entities in scope for PCI DSSInternal and external pentestsEvery 12 months and after significant change"is performed"Standard, v4.0.1
SOC 2 (Trust Services Criteria)Firms that choose a SOC 2None required; CC4.1 point of focus names pentestingNot setNone2017 criteria; points of focus revised 2022
ISO/IEC 27001:2022Organizations certifying an ISMSNo named pentest; A.8.8 and A.8.29 cover testingNot set; risk-basedNone for pentests2022 edition
CCSS 2.01Systems seeking CCSS certificationLevel II: independent pentest. Level III: audit with pentestLevel II: regular. Level III: yearly"has been completed"Version 9

PCI DSS v4.0.1, as reproduced by Cloudaware, wants a qualified tester with organizational independence, who need not be a QSA or ASV.

SOC 2 leaves the choice to the firm. The AICPA says using the criteria "does not require an assessment of whether each point of focus is addressed."

More in does SOC 2 require penetration testing.

ISO/IEC 27001 never uses the term "penetration test", per ISMS.online and TCSA. Both place testing under A.8.8 (technical vulnerabilities) and A.8.29 (security testing in development and acceptance).

CCSS also reaches contracts. Even Level I requires an external audit of production smart contract code, with Medium and higher issues addressed before deployment.

Building One Test Plan

A firm licensed in several places faces several of these rows. Build one plan around the strictest of each.

  • Cadence: at least yearly; in Kenya, "bi-annual" in year one, which we read as twice.
  • Triggers: test after significant change (PCI DSS, MAS) and before new systems (VARA, SFC).
  • Perspective: from outside and inside the boundary (NYDFS, PCI DSS).
  • Tester: qualified and independent; a third party where VARA or CCSS applies.
  • Scope: wallets and custody systems, which the SFC names.
  • Contracts: a smart contract audit where VARA, the HKMA, MiCA or CCSS reach you.
  • TLPT: plan for it if DORA or VARA may call for it.

Then keep one evidence file: scope, dates, testers, findings, fixes and retests. Map it to each provision, so one report can answer several.

How Guardian Helps

Guardian's pentests cover infrastructure, web apps, APIs, browser extensions, SDKs and offchain automation, each closed out with a retest.

Its Regulatory & Compliance service maps each pentest report to the provisions it answers.

Its evidence ledger lists NYDFS 500.5 and 200.16(e), DORA Article 25, MAS TRM 13.2, SFC VATP 12.13, VARA Rule I.E.1 and PCI DSS 11.4, among others.

Guardian is not a law firm. It works alongside your counsel.

Frequently Asked Questions

Which regulations require annual penetration testing?

NYDFS Part 500 and Part 200, VARA Rule I.E.1, PCI DSS 11.4 and Kenya's VASP Regulations set pentests at least yearly. DORA requires yearly tests of critical systems and lists pentesting as one such test.

Do SOC 2 or ISO 27001 require a penetration test?

Neither makes one mandatory. SOC 2 names penetration testing in a CC4.1 point of focus, and points of focus are not requirements. ISO/IEC 27001 does not use the term, per ISMS.online and TCSA; they place testing under A.8.8 and A.8.29.

Who may perform a regulatory pentest?

NYDFS accepts a qualified internal or external party. PCI DSS needs a qualified tester with organizational independence. VARA requires a qualified, independent third party, as do CCSS Levels II and III. DORA allows independent internal testers for its yearly program.

Do any rules cover smart contract testing?

VARA covers them where relevant. The HKMA expects yearly contract audits, plus one per deployment or upgrade. MiCA applicants describe a third-party audit, if available, ideally with a code review. CCSS Level I requires external audits of deployed contract code.

Sources

One test plan, mapped to every rule

Guardian pentests your systems and maps each report and retest to the provisions that ask for them.