Frequently Asked Question
Can SAQ eligibility criteria be used for determining applicability of PCI DSS requirements for assessments documented in a Report on Compliance?
Service providers cannot use SAQ eligibility criteria to determine applicability of PCI DSS requirements for assessments documented in a Report on Compliance. The only acceptable SAQ for service providers is SAQ D for Service Providers. All other SAQs are intended for merchant use only.
Merchants with environments that fully meet all the eligibility criteria defined in a particular SAQ may use that SAQ as a reference to identify the applicable PCI DSS requirements for that environment. This approach must be clearly documented in “Description of Scope of Work and Approach Taken” section of the ROC.
For PCI DSS v3.2.1, this includes the following:
Identify the eligibility criteria for the applicable SAQ,
For each criteria, document how the assessor verified that the merchant environment meets the criteria.
For PCI DSS v4.0, this approach is documented as specified in ROC Section 3.1.
The assessor will need to perform appropriate testing and validation to verify the non-applicability of any PCI DSS requirements. As an example: If an e-commerce merchant has a webserver using a URL redirect to a PCI DSS compliant third-party payment processor, the assessor will need to verify that the merchant environment, including redirection method and the configuration of the webserver, meets all the eligibility criteria for SAQ A before they can consider using that SAQ for guidance. This would include verifying that the merchant accepts only card-not-present transactions, does not electronically store, process, or transmit any account data on its systems or premises, that all processing of account data is entirely outsourced to PCI DSS validated third-party service providers, and that all the other eligibility criteria for SAQ A are met.
Any PCI DSS requirements verified by the assessor to be not applicable should be reported as “Not Applicable” in accordance with instructions in the Report on Compliance (ROC) Template. Assessors should refer to the ROC Template and ROC Template FAQs for the version of the standard being used for relevant guidance.
If an environment meets some but not all eligibility criteria for a particular SAQ, then the SAQ should not be considered a relevant guide for applicability of requirements.
Merchants and service providers should always consult with their compliance accepting entity—such as their acquirer (merchant bank), payment brand, or other entity—to confirm their PCI DSS validation and reporting method. If a detailed assessment and ROC is the appropriate method, merchants meeting the eligibility criteria from an SAQ should also confirm that the approach outlined above is acceptable. Contact information for the payment brands can be found in FAQ #1142 How do I contact the payment card brands?