This is page 2 of:

PCI Self-Assessment Questionnaires Need Some Major Updates

July 21st, 2010

For SAQ B I would like some clarification for the merchants. For example, terminals that “dial out” with an IP line use the Internet. Therefore, in my opinion, they are ineligible for this SAQ (see SAQ C, below). I would like this fact spelled out explicitly in the SAQ instructions, because many small merchants may not understand this distinction.

My other clarification deals with the “terminal data capture” situation where the terminals retain cardholder data after authorization. At a prescribed time, an employee “batches out” the terminal and transmits a file with the day’s (or weekend’s) card transactions to the acquirer for processing. To this QSA, the POS device–and, therefore, the merchant–is storing data electronically. Therefore, merchants with terminal capture would not qualify for a simplified SAQ of any kind under the present guidelines.

We have to understand that the decision on which SAQ a merchant should use is not up to the QSA; the acquirer makes that decision. I had an acquirer overrule me on this exact SAQ B situation–where the POS terminals were storing the card data–and I was fine with that decision.

In my heart of hearts, I agreed with the acquirer because the risk was pretty small. But as a QSA, I need to follow the letter of the PCI law and look out for my client (no matter how much they had trouble understanding it at the time). I think the people who developed SAQ B may well have intended to include terminal capture devices. Either way, a brief clarification on the SAQ instructions to merchants would be welcome.

SAQ C may be most in need of an overhaul. It was designed for merchants that have a payment application connected to the Internet, generally to authorize card transactions. The previous prohibition on storing electronic cardholder data applies to SAQ C merchants, but there is one particularly awkward requirement: “The payment application/Internet device is not connected to any other systems within your environment.”

The reason I call this “not connected to any other system” requirement awkward is that it almost never exists in the real world. Payment applications need to connect to other systems for antivirus and patch updates; they also need to connect to inventory and pricing systems. I can have a merchant segment the payment application behind a firewall, but how many holes does it have to punch in that firewall to allow for the other business services?

My experience is that almost every call center, and a few zillion retailers, thinks it qualifies for SAQ C. In reality, only a very small number do. Reading the instructions carefully, about the only situation where it applies is for those POS terminal merchants with an IP line for authorizations. I think the people who created SAQ C intended more.

The creators of the three simplified SAQs wanted to help merchants become compliant. To a great extent, they succeeded, and for that we should all thank them. The PCI Council and card brand staff who worked on these SAQs did a tremendous amount of work. Before SAQs A, B and C, there was only SAQ D with its 226 questions covering all of the DSS. And not all of these questions were relevant to a large number of merchants. In fact, that original, overwhelming SAQ probably scared some of these same merchants away from PCI compliance.

My hope is that as the PCI Council takes a fresh look and reflects on the merchant feedback, it will consider these ideas as well as the many others I’m sure it has received. It is neither wise nor realistic to go back to the “one SAQ fits all” approach. A few tweaks of SAQs A and B will go a long way; SAQ C is likely to need a more thorough overhaul.

Are you a Participating Organization on the PCI Council? You should be, by the way. And if you are, have you sent any suggestions for improvements on the SAQs? What were they? I’d like to hear your thoughts. Either leave a comment or E-mail me at


Comments are closed.


StorefrontBacktalk delivers the latest retail technology news & analysis. Join more than 60,000 retail IT leaders who subscribe to our free weekly email. Sign up today!

Most Recent Comments

Why Did Gonzales Hackers Like European Cards So Much Better?

I am still unclear about the core point here-- why higher value of European cards. Supply and demand, yes, makes sense. But the fact that the cards were chip and pin (EMV) should make them less valuable because that demonstrably reduces the ability to use them fraudulently. Did the author mean that the chip and pin cards could be used in a country where EMV is not implemented--the US--and this mis-match make it easier to us them since the issuing banks may not have as robust anti-fraud controls as non-EMV banks because they assumed EMV would do the fraud prevention for them Read more...
Two possible reasons that I can think of and have seen in the past - 1) Cards issued by European banks when used online cross border don't usually support AVS checks. So, when a European card is used with a billing address that's in the US, an ecom merchant wouldn't necessarily know that the shipping zip code doesn't match the billing code. 2) Also, in offline chip countries the card determines whether or not a transaction is approved, not the issuer. In my experience, European issuers haven't developed the same checks on authorization requests as US issuers. So, these cards might be more valuable because they are more likely to get approved. Read more...
A smart card slot in terminals doesn't mean there is a reader or that the reader is activated. Then, activated reader or not, the U.S. processors don't have apps certified or ready to load into those terminals to accept and process smart card transactions just yet. Don't get your card(t) before the terminal (horse). Read more...
The marketplace does speak. More fraud capacity translates to higher value for the stolen data. Because nearly 100% of all US transactions are authorized online in real time, we have less fraud regardless of whether the card is Magstripe only or chip and PIn. Hence, $10 prices for US cards vs $25 for the European counterparts. Read more...
@David True. The European cards have both an EMV chip AND a mag stripe. Europeans may generally use the chip for their transactions, but the insecure stripe remains vulnerable to skimming, whether it be from a false front on an ATM or a dishonest waiter with a handheld skimmer. If their stripe is skimmed, the track data can still be cloned and used fraudulently in the United States. If European banks only detect fraud from 9-5 GMT, that might explain why American criminals prefer them over American bank issued cards, who have fraud detection in place 24x7. Read more...

Our apologies. Due to legal and security copyright issues, we can't facilitate the printing of Premium Content. If you absolutely need a hard copy, please contact customer service.