Skip to content

QSA · QPA · 3DS Assessor

PCI DSS

Choosing the right SAQ

Ask two questions before you pick a questionnaire. In what capacity do you handle the payment, and what actually touches the card? Four engagements where the obvious answer was the wrong one, in both directions.

Updated 24 Oct 20264 min read

The right SAQ depends on how you accept card payments and in what capacity. It does not depend on your size, your revenue, or what your payment provider’s onboarding email asked for. The picker below gives you the usual answer. The four stories after it are the exceptions we meet most.

Every SAQ at a glance

QuestionnaireFor
SAQ ACard-not-present merchants who have outsourced every card data function to PCI DSS compliant providers.
SAQ A-EPE-commerce merchants whose website does not receive card data but controls how it reaches the provider.
SAQ BMerchants using only imprint machines or standalone, dial-out terminals.
SAQ B-IPMerchants using only standalone, PTS-approved terminals with an IP connection to the processor.
SAQ C-VTMerchants who key transactions one at a time into a provider’s web-based virtual terminal.
SAQ CMerchants with payment application systems connected to the internet, and no electronic storage.
SAQ P2PEMerchants using only hardware terminals from a validated, PCI-listed P2PE solution.
SAQ D for MerchantsEvery merchant the shorter SAQs do not cover, including any electronic storage of card data.
SAQ D for Service ProvidersThe only SAQ for service providers the payment brands allow to self-assess.

The Level 1 merchant that did not need 300 requirements

A vending operator takes roughly a million card transactions a week, which makes it a Level 1 merchant, which means a Report on Compliance signed by a QSA. Everyone assumed that meant the full standard. The only path a card takes in that business is through terminals leased from the acquirer, approved under the Council’s terminal standard with encryption at the reader, where the vending machine’s controller does nothing more than pass the traffic along.

The merchant level decides the form of the validation: a report rather than a questionnaire. It does not decide the depth. The scope decides which requirements apply. We wrote to the acquirer under the Council’s published guidance for exactly this case and asked it to agree that the report could focus on the requirements of SAQ B-IP, the questionnaire for standalone terminals on a network. It agreed, on conditions: approved terminals only, no card data anywhere beyond the terminal, and a reassessment on any change. The work then moved to where the risk actually is: the terminal inventory, tamper inspections, staff training, and the responsibility matrix with the acquirer.

Same website, two different SAQs

A digital agency built and hosted a gift-card site for a large retailer. Payments went through a payment provider’s iFrame; all processing was outsourced to a compliant third party. The agency started filling in SAQ A.

Only merchants can use SAQ A. Every questionnaire except SAQ D is for merchants only. Here the retailer was the merchant, and the agency was its service provider. For exactly the same environment, the retailer would validate with a short SAQ A, while the agency, running that same site on the retailer’s behalf, had to take the SAQ D path for service providers, including the requirements about protecting the integrity of the page that carries the payment form. The work is the same. The role, and therefore the form, is different. Before you choose an SAQ, ask “in what capacity?”. Most people stop at “we use an iFrame”.

The hotel that had been filling in SAQ D for nothing

A large hotel validated with SAQ D every year, the longest questionnaire, with all the requirements. Its terminals were part of a point-to-point encryption solution listed by the Council, and its property management system had been tokenised. Card numbers never reached anything the hotel ran. The only thing left touching card data was the handful of PCs where agents keyed numbers into a virtual terminal for phone bookings, which points at SAQ C-VT, a fraction of the length. The team had been answering two hundred questions a year about systems that were no longer in scope, because nobody had re-asked the question after the terminals changed.

The provider asked for SAQ A, so it must be SAQ A

A healthcare platform received a request from its payment provider for an SAQ A, and asked us to help fill it in. In the first conversation the client mentioned that it stored card data. That single fact rules SAQ A out until it is cleared up: SAQ A exists for merchants that never touch the card. The provider’s request was a default, sent to every merchant on that integration. It was not an assessment of this one.

What people get wrong

They let the level decide the depth. The level decides whether you file a questionnaire or a report. Scope decides what is in it.

They let outsourcing decide the form. Outsourcing the payment page takes most requirements away from a merchant. It takes nothing away from a service provider, because the service provider is the one being outsourced to.

They let the provider’s email decide. Your acquirer and your payment provider send the questionnaire they expect for a typical customer. You are the only one who knows whether you are typical.

They never re-ask. Terminals change, systems get tokenised, a new channel appears. The questionnaire that was right three years ago describes an environment that no longer exists, in either direction.

The level decides whether you file a questionnaire or a report. Scope decides what is in it.

Want a straight answer about your PCI scope?

Talk to a QSA, not a salesperson. First conversation, real answers.

Talk to a QSA

Or reach us directly

QSAQPA3DS AssessorAuthorised to assess across Europe & CEMEA