PCI DSS guide
Which SAQ applies to you: PCI DSS self-assessment eligibility explained
How to match your payment channels to the right PCI DSS v4.0.1 Self-Assessment Questionnaire: the SAQ family, the condition that decides each one, why service providers use SAQ D or a ROC, who decides, and the mistakes that invalidate an SAQ.
Key points
- Each Self-Assessment Questionnaire (SAQ) fits one way of accepting cards, and you qualify only if you meet every one of its eligibility criteria.
- The v4.0.1 family runs from SAQ A for fully outsourced card-not-present payments to SAQ D, the default for merchants that fit nothing narrower. Self-assessing service providers have one option: SAQ D for Service Providers.
- Your acquirer decides whether you may self-assess, which SAQ it accepts and whether a QSA or ISA must be involved.
- Every SAQ goes with a signed Attestation of Compliance (AOC); without it there is no validation.
What an SAQ is, and why there are so many
An SAQ is a self-assessment tool from the PCI Security Standards Council for merchants and service providers allowed to validate without a full Report on Compliance. It lists the requirements that apply to one payment environment, asks whether each is in place, and ends with an attestation your organisation signs.
There are several versions because scope differs. A merchant whose website hands the whole payment to a compliant provider touches far less of the standard than one running its own payment application on an internet-connected network, so the Council publishes shorter questionnaires for narrower environments. The shorter the questionnaire, the stricter its eligibility conditions.
Whether you need to validate at all is covered in Do you need PCI DSS? Merchant levels, service providers and who decides; how the SAQ, ROC and AOC fit together in PCI DSS validation step by step: ROC, SAQ and AOC.
The SAQ family for PCI DSS v4.0.1
The table maps the questionnaires in use with v4.0.1 to the condition that most often decides eligibility. Each SAQ carries its own full list of criteria, and you must meet every item.
| How you take card payments | SAQ | The condition that decides eligibility |
|---|---|---|
| E-commerce, mail or telephone order, with every card data function outsourced | A | No account data on your systems; online, the payment page comes entirely from a compliant provider, and your site is confirmed not susceptible to script attacks |
| E-commerce where your website controls how the payment page reaches the customer | A-EP | Your site does not receive account data but can affect the transaction's security, for example by serving the payment form |
| Card-present with imprint machines or standalone dial-out terminals | B | No electronic storage; terminals not connected to other systems or the internet |
| Card-present with standalone approved terminals connected over IP | B-IP | Standalone PCI-approved terminals connected only to the processor; no electronic storage |
| Keyed entry into a provider's virtual terminal | C-VT | Keyed one at a time on a standalone computer; no electronic storage |
| Payment application systems connected to the internet | C | A limited, segmented environment; no electronic storage |
| Terminals within a validated point-to-point encryption solution | P2PE | Only terminals from a PCI-listed P2PE solution; no electronic storage |
| Off-the-shelf mobile device with a secure card reader | SPoC | A validated SPoC solution on the Council's list, used as its instructions require |
| Any merchant environment that fits none of the above | D for Merchants | All applicable requirements |
| Service providers the brands allow to self-assess | D for Service Providers | All applicable requirements, including service-provider-only ones |
Once account data is kept on your systems after authorisation, even in a spreadsheet, a call recording or an e-mail archive, the short questionnaires stop applying and SAQ D becomes the route.
E-commerce: SAQ A or SAQ A-EP, and the script question
Both SAQ A and SAQ A-EP assume you use a payment provider. The difference is who controls the page or form where the customer types the card number. A redirect to the provider's page, or payment fields in an embedded frame served entirely by the provider, may fit SAQ A. If your own site builds or serves the payment form, through direct post or scripts you host or load, it can change where the data goes, and SAQ A-EP is the questionnaire written for it.
What changed for SAQ A
PCI DSS v4.0 introduced requirements to manage payment page scripts and detect unauthorised changes to them, mandatory since 31 March 2025. In January 2025 the Council removed those requirements, and the targeted risk analysis behind one of them, from SAQ A and replaced them with an eligibility criterion: the merchant must confirm its site is not susceptible to attacks from scripts that could affect its e-commerce systems. You must be able to show how you reached it. A parent page that loads analytics, chat or tag-manager scripts alongside the frame deserves a close look before SAQ A is chosen.
Card-present and phone payments
For shops, hotels and contact centres the question is how card data travels from the terminal or keyboard to the processor, and what it passes on the way.
- Standalone terminals. A dial-out terminal, or one connected over IP straight to the processor and not linked to your till or other systems, points to SAQ B or B-IP. Connecting it to the till network can end that eligibility.
- Validated encryption. Where every terminal belongs to a listed P2PE solution, SAQ P2PE usually gives the smallest card-present scope.
- Virtual terminals. Phone orders keyed one at a time into a provider's web terminal on a standalone computer fit SAQ C-VT. Card numbers on notepads, in the CRM or in call recordings take you outside it.
- Integrated point-of-sale. A payment application on an internet-connected, segmented system with no storage points to SAQ C; otherwise SAQ D.
Scope reduction is what usually moves a merchant to a shorter questionnaire; see PCI DSS scoping and segmentation: shrinking the CDE.
Why service providers use SAQ D or a ROC
A service provider handles account data for other businesses or can affect its security: hosting companies, gateways, BPOs and contact centres taking payments for clients. The shorter questionnaires describe merchant environments, so none apply. The only SAQ open to a service provider is SAQ D for Service Providers, and only where the card brands allow it to self-assess.
The brands set separate service-provider levels, and the largest providers must validate with a ROC from a QSA. Your customers matter as much: merchants that rely on you must monitor your compliance, and many ask for an AOC resulting from a ROC plus a responsibility matrix. A self-assessed AOC can meet the brand minimum and still fall short of a bank's or a large retailer's contract.
Who decides, and who signs
You propose a questionnaire; the acquirer accepts it or not. Applying the card brands' programmes, it confirms your level, whether self-assessment is allowed, which SAQ it expects and when the AOC is due, and it can set a higher bar than the brand minimum. Confirm the choice with it before you start; that is the Council's own advice.
The acquirer may also require a QSA, or an Internal Security Assessor (ISA) trained and qualified by the Council, to complete or review the SAQ. Otherwise an executive officer of your organisation signs, stating that every answer is true.
The AOC that goes with every SAQ
Each SAQ has a matching Attestation of Compliance summarising the environment, the channels covered, the providers relied on and the result. It is the document the acquirer files and customers ask for; an SAQ without its signed AOC does not complete validation.
How Sterling supports SAQ validation
The right questionnaire, confirmed with your acquirer, with the evidence behind every answer.
Sterling's expert and experienced consultants trace each payment channel with your people, test it against the criteria of each candidate SAQ and put the recommendation to your acquirer before any answers are written. Where scope can be reduced to reach a shorter questionnaire, we plan it with you under Design™ (your team implements with our structure and coaching) or Drive™ (we take on the agreed work). Evidence and scan results are held in Effivity, included with the engagement at no additional cost, and Sustain™ keeps them current each year. What you receive is a questionnaire your acquirer has agreed to, answered with evidence you can show. Sterling does not validate compliance or sign the AOC.
Book a free discovery callThe mistakes that invalidate an SAQ
- SAQ A with a script-loaded payment page. A site that builds the payment form, or loads unmanaged scripts beside the provider's frame, cannot simply tick the script criterion; address and evidence the exposure, or use SAQ A-EP.
- Mixed channels. A website, a shop and a phone line are three environments. Some acquirers accept one SAQ per channel; others want one questionnaire covering all, usually SAQ D. Ask first.
- Hidden storage. Card numbers in e-mail, chat logs, call recordings or scanned forms break the no-storage condition.
- No provider AOC. Several SAQs depend on your provider being compliant; without its current AOC you cannot confirm the criterion.
- Yes without evidence. An SAQ is an attestation, not a survey; after a breach, the evidence behind each answer is what gets examined.
For the wider picture see PCI DSS common mistakes: the ten that fail assessments and PCI DSS checklist: the 12 requirements in the order you will meet them.
Which SAQ applies to you: questions buyers ask
Can we use two SAQs for two payment channels?
Sometimes. Where channels are separate environments some acquirers accept one per channel; others want a single SAQ for everything. Get the acquirer's answer in writing before you begin.
Our payment page is an embedded frame from our provider. Is SAQ A automatic?
No. The frame must come entirely from a compliant provider, and you must be able to confirm your own site is not susceptible to script attacks. Third-party scripts on the parent page or an unverified provider can rule it out.
Is SAQ D much more work than a ROC?
It covers the same requirements; the difference is who tests and reports. With SAQ D you assess and attest yourselves; a ROC is written by a QSA or ISA after testing. The control work and the standard of evidence are the same.
How often do we complete the SAQ?
At least annually with its AOC, plus quarterly ASV scans where your questionnaire requires them. See The PCI DSS annual cycle: quarterly scans, annual validation and business as usual.
Can a provider's compliance make us eligible for a shorter SAQ?
Often, because outsourcing card data functions removes them from your environment. Responsibility stays with you: keep the provider's current AOC and a written split of which requirements it covers.
More PCI DSS guides
Every guide in the PCI DSS series is written for one question and links back to the hub for the whole picture.
- The PCI DSS annual cycle
- PCI DSS assessor questions
- PCI DSS in Australia
- PCI DSS compliance cost: what moves the price
- Effivity for PCI DSS: the guide
- PCI DSS vs ISO/IEC 27001 and SOC 2
- PCI DSS requirements explained, requirement by requirement
- PCI DSS scoping and segmentation: shrinking the CDE
- PCI DSS training: who needs what
- PCI DSS v4.0.1: what changed and what your next assessment tests
- PCI DSS validation step by step: ROC, SAQ and AOC
- How to verify a PCI DSS AOC and check a provider's compliance
- Which SAQ applies to you: eligibility explained
Keep exploring
Explore more about PCI DSS
Watch a video on how to implement PCI DSS here.
Watch a video on PCI DSS requirements here.
PCI DSS resources
Services for PCI DSS
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