Platform Programmes

SP-API DPP Reassessment: Need a New Pentest?

Clause 2.7.2 runs a 365-day clock, so a reassessment needs a recent test. What changed since your last one, and the half a pentest cannot evidence.

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Yes, if your application holds a restricted role. Clause 2.7.2 of Amazon’s Data Protection Policy requires penetration testing at least every 365 days, and that clock runs on the test rather than on the submission. So a reassessment needs a test performed inside the previous 365 days. The report you filed last time stops satisfying the clause once it is older than that.

Two conditions decide whether any of this binds you, and they are worth checking before you buy anything. Clause 2.7.2 sits inside section 2 of the policy, headed “Additional Security Requirements Specific to Personally Identifiable Information”. Section 1, the General Security Requirements every Solution Provider must meet, contains no penetration testing clause at all. So the obligation follows the restricted roles. And Amazon never asks you to submit the report: section 3 requires you to hold records and to certify compliance in writing when asked.

Which restricted roles, and the full clause text, are set out on our SP-API DPP pentest pillar. This page is about the renewal specifically: what has changed under you since you were last assessed, and which parts of it a test cannot evidence.

What changed under you

Amazon restructured clause 2.7 and rewrote parts of the policy on 25 November 2025, then revised it again effective 25 August 2026. Put that beside a 365-day clock and a specific group has a problem nobody has told them about:

If your last DPP penetration test ran before 25 November 2025, your next one is against a policy that has materially changed twice since.

The arithmetic is worth doing explicitly. A test on 20 November 2025 falls due around 20 November 2026. A test in March 2025 fell due in March 2026. Anyone whose previous assessment predates the rewrites is renewing against requirements that did not exist when they were last assessed.

What the 25 November 2025 revision added or tightened, per Amazon’s own changelog:

AreaWhat was added or tightened
Network protectionControls to prevent anti-virus and anti-malware software being disabled
Access managementAccount lockout after ten unsuccessful login attempts
CredentialsPassword history retention for the last ten passwords, and API key rotation
EncryptionTLS 1.2 or higher, and Key Management System implementation
Incident responseA designated, readily available Incident Management Point of Contact
Data retentionNon-PII retained only as long as strictly necessary, with the business purpose documented
Log retentionMinimum raised to 12 months
Vulnerability managementCritical in 7 days, high-risk in 30, plus geographically dispersed backup requirements
Third partiesSubcontractor risk assessments now required
Terminology”Developer” renamed “Solution Provider” throughout

🔴 One note on the retention row, because two Amazon sources word it differently. Amazon’s changelog summarises the non-PII change as an 18 month cap. The policy text itself does not use that figure: it requires retention “only for as long as, and to the extent, retention is strictly necessary” with the business purpose documented. We have stated it as the policy states it, because the policy is what binds and the changelog is a summary of it. If you are scoping against a number, read the live clause rather than the announcement.

The 25 August 2026 revision then added a further set, covering endpoint and device hardening, credential handling, a deletion window, a named incident contact, and an expansion of the scanning and penetration testing requirements. The pillar sets that revision out in Amazon’s own words, together with the only available way to tell which revision you are holding: the second revision, effective 25 August 2026.

🔴 The one line from it that changes a renewal scope is the testing clause. The expansion names Application Programming Interfaces explicitly inside the application-layer category. So the question to ask of your previous engagement is narrow: was the API in scope, or was it treated as part of the web application? If it was the latter, that is a scope gap on renewal rather than a finding, and it is cheaper to fix at scoping than after a reviewer raises it.

Roughly half the list is not findable by a penetration test

This is the part that catches renewal buyers, and it is the single most useful thing on this page.

What a test can evidence, because it is observable in a running system: TLS 1.2 or higher in use, account lockout behaviour after failed attempts, Key Management System usage, the presence and configuration of a web application firewall, and the application, API, cloud and network controls clause 2.7.2 names.

What a test cannot evidence, because it is a record rather than a behaviour: password history retention, the 12-month log retention minimum, the designation of an Incident Management Point of Contact, documented business purposes for non-PII retention, and the annual third-party risk assessments of vendors and subcontractors that clause 2.8 requires before granting them access to Amazon data.

A tester can observe that a control appears to be present. A tester cannot evidence that your organisation maintains it.

So a renewal handled as “book the same test as last year” can produce a clean penetration test report and still leave the assessment short. The sequence that works is a gap review against the current policy text first, and the test scoped from that. Our SP-API DPP evidence checklist sets out the eight areas Amazon asks a Solution Provider to evidence and marks which ones a penetration test produces for you: one of the eight fully, three partly, and four that are not testing problems at all.

The clock you are actually working against

Work backwards from the date your current test was performed, not from the date you submitted last time.

Then allow for three things that sit between a kickoff and a finished report. Testing and reporting take time: we quote 6 business days per scope, 5 testing and 1 writing the report, so a four-category scope is not a one-week job. Remediation usually takes longer than testing, and clause 2.7.3 sets its own windows of 7 days for critical findings and 30 days for high. And Amazon’s vulnerability management guidance requires a second test after remediation to validate the findings are closed, which makes the retest part of the work rather than an optional extra.

A reassessment started a month before the anniversary is tight. Started three months before, the remediation window stops being the binding constraint.

The scanning clock runs separately, and monthly

Clause 2.7.1 is a different obligation on a different cadence: vulnerability scanning at least every 30 days, change-triggered scanning after significant network, application or infrastructure changes, and code scanning before each release. An annual test cannot satisfy a 30-day cadence, and the two clauses need two different activities. We cover that separately in what the 30 day scanning requirement actually asks for.

Where we fit

Cybersecify performs the clause 2.7.2 penetration test and produces the report and the Letter of Engagement a submission takes. Our Amazon SP-API DPP penetration testing page maps the four scope categories to what we test, with the price and the business days for a three and a four scope engagement.

What no vendor can do, including us: there is no Amazon-issued certificate for DPP compliance, no approved assessor list to be on, and no pass or fail letter for the pentest control. Amazon decides submissions and we are not in that room. What exists is a records obligation and an audit right, and the job is to be able to answer it.

Request the SP-API DPP evidence checklist. It sets out all eight evidence areas, who produces each one, and which a penetration test evidences for you. Sent on request, read by a founder first.

Corrections and updates

We publish corrections rather than editing them away, so a reader who acted on an earlier version can see what changed. Some entries record a change in the source document itself, others record our own error. Dates are our review dates, not the source's change date.

Errors in this page are corrected in place with a dated note. If you believe something here misreads the policy, tell us at errors@cybersecify.com and we will check it against the source and publish the outcome either way. Our corrections policy sets out how.

Sources. Amazon Data Protection Policy clauses 2.7, 2.7.1, 2.7.2, 2.7.3, 2.8 and section 3 at sellercentral.amazon.com/solution-provider/policy?policyType=DPP&locale=en_US, read 17 October 2026 against the revision effective 25 August 2026. Amazon’s SP-API changelog entry “Updates to the Data Protection Policy and Acceptable Use Policy”, effective 25 November 2025. Amazon, “Announcement for Policy Update”, developer.amazonservices.com/policy-update-for-sp-api. Restricted role list at developer-docs.amazon/sp-api/docs/roles-in-the-selling-partner-api, five roles, read 17 October 2026. Second-test-after-remediation requirement at developer-docs.amazon/sp-api/docs/vulnerability-management. The live policy page carries no version number and no effective date, so save a dated copy of the text you relied on.

Frequently Asked Questions

Do I need a new penetration test for my annual Amazon SP-API DPP reassessment?

Yes, if your application holds a restricted role. Clause 2.7.2 of Amazon's Data Protection Policy requires the Solution Provider to perform penetration testing at least every 365 days. That is a rolling clock on the test, not on the submission, so a reassessment needs a test performed within the previous 365 days. The report you filed last time does not satisfy this year's requirement once it is older than that. Two points decide whether the clause binds you at all. Clause 2.7.2 sits inside section 2 of the policy, headed Additional Security Requirements Specific to Personally Identifiable Information, and section 1, which every Solution Provider must meet, contains no penetration testing clause. So the obligation follows the restricted roles: Direct-to-Consumer Shipping, Professional Services, Selling Partner Support, Tax Invoicing and Tax Remittance. And Amazon does not ask you to submit the report. Section 3 requires you to keep records and to certify compliance in writing when asked. Source: sellercentral.amazon.com Data Protection Policy clause 2.7.2 and section 3.

Can I reuse last year's SP-API penetration test report for the reassessment?

Only while it is inside the 365-day window, and even then only if the scope still matches what you run today. Two things commonly break reuse. The first is the clock: a test performed in March of last year fell due in March of this year, so a report that satisfied one submission is out of date for the next. The second is scope drift. Clause 2.7.2 names four categories, network infrastructure, cloud environments, application-layer assets and other in-scope systems, and the live policy text now enumerates web applications, APIs, databases and storage systems inside the application-layer category. An integration that has added an API surface, moved a workload, or taken on a new restricted role since the last test has a scope gap that a valid-looking report does not close. The practical test is whether the scope statement on the report still describes the systems that handle Amazon data today.

What changed in the Data Protection Policy since my last SP-API penetration test?

That depends which revision you were last assessed against, and Amazon makes this harder than it should be because the live policy page carries no version number and no effective date. There have been two revisions worth knowing. The revision effective 25 November 2025 restructured clause 2.7 into four sub-clauses and added, among other things, account lockout after ten failed login attempts, ten-password history, API key rotation, TLS 1.2 or higher with a Key Management System, a designated Incident Management Point of Contact, a 12-month minimum on log retention, remediation windows of 7 days for critical and 30 days for high, geographically dispersed backups, and subcontractor risk assessments. The revision effective 25 August 2026 added a web application firewall for internet-facing endpoints, storage encryption on all devices, a 15-minute screen lock and a 30-minute lockout after ten failed attempts, and in Amazon's own words expanded the vulnerability scanning and penetration testing requirements to include Application Programming Interfaces explicitly. If your previous assessment predates either of these, you are renewing against requirements that did not exist when you were last assessed.

Which of the renewal requirements can a penetration test actually evidence?

Roughly half, and knowing which half is the difference between a clean submission and a short one. A penetration test can confirm what is observable in a running system: TLS 1.2 or higher in use, account lockout behaviour after failed attempts, Key Management System usage, the presence and configuration of a web application firewall, screen lock enforcement where it is technically observable, and the application, API, cloud and network controls clause 2.7.2 names. It cannot evidence policy, documentation or process. Password history retention, the 12-month log retention minimum, the designation of an Incident Management Point of Contact, documented business purposes for non-PII retention, and annual third-party risk assessments of subcontractors are records, not behaviours. A tester can observe that a control appears present. A tester cannot evidence that your organisation maintains it. So a renewal handled as book the same test as last year can produce a clean report and still leave the assessment short. The sequence that works is a gap review against the current policy text first, and the test scoped from that.

How early should I start the SP-API DPP reassessment?

Work backwards from the date your current test was performed, not from the date you submitted last time, because the 365-day clock runs on the test. Then allow for three things that sit between a kickoff and a finished report. Testing and reporting take time: we quote 6 business days per scope, 5 testing and 1 writing the report, and a four-category scope is therefore not a one-week job. Remediation takes longer than testing in most engagements, and clause 2.7.3 sets its own clocks of 7 days for critical findings and 30 days for high. And Amazon's vulnerability management guidance requires a second test after remediation to validate that the findings are closed, which means the retest is part of the work rather than an optional extra. A reassessment started a month before the anniversary is tight. Started three months before, the remediation window stops being the binding constraint.

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