Scheduled testing that happens on an automatic basis, or that occurs whenever code is deployed or committed. For example, whenever you would run your unit tests or integration tests, you should also run security tests.
It's the difference between doing an automated or manual penetration test every 12 months and testing your application for vulnerabilities with every deploy.
It's 6.5.1-6.5.10 of PCI v3.1. That's all security testing. You can use a static analyzer like Brakeman to speed things along instead of doing it manually.
Train developers in secure coding techniques, including how to avoid common coding vulnerabilities, and understanding how sensitive data is handled in memory.
Develop applications based on secure coding guidelines.
It says nothing about automated testing, which is precisely my point. The requirement is that you attempt to follow security best practices and train your employees well. My point is that even the best-trained employees make mistakes.
The reason unit tests exist is to make sure you didn't accidentally break stuff when you write code. I'm arguing that automated security tests should exist for the same reason, and that's what we're trying to offer and build.
Incidentally, section 6.6 does state that you should use manual or automated testing at least annually; PCI 3 added a new clause which states 'after any changes.' Also, it explicitly specifies that you need /either/ automated or manual testing, /or/ a WAF. WAFs, as you're likely well aware, miss things very often. [2] WAFs are a good stopgap, but should not be relied upon to provide actual security; they should only be relied upon to attempt to prevent an attack while you are in the process of fixing the vulnerabilities underneath.
Because penetration testing is so expensive, typically, I suspect it will be more common for people to go with the WAF than to do a pentest with every deploy. I don't have stats to back that up, since PCI 3.1 hasn't actually been enforced yet, but I strongly suspect that will be true.
