Explained: PCI Attestation of Compliance (PCI AoC)

A PCI Attestation of Compliance (AoC) is an official document that verifies your organization’s PCI DSS compliance for handling payment card data securely.

Think of it as your organization’s official security report card that proves to brands, banks, payment processors, and partners that you're following the required security measures.

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Why is it important?

• It proves your PCI DSS compliance to payment providers and brands.
• It reduces the risks of penalties, data breaches, and legal issues.
• It builds trust by showing your commitment to protecting customer payment data.

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Who Needs a PCI AoC?

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Any business or organization that stores, processes, or transmits payment cardholder data must comply with PCI DSS and obtain an AoC. This includes:

• Merchants, including e-commerce stores, retail shops, and subscription businesses.
• Payment processors and service providers.
• Financial institutions and fintech companies handling transactions.

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Why is a PCI AoC Important?

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A PCI AoC is required to demonstrate that your organization has implemented PCI DSS security measures to protect cardholder data. It’s important for the following reasons:

• Required to Stay PCI Compliant: It helps you avoid non-compliance penalties and restrictions.
• Improves Security: It reduces the risk of data breaches and fraud.
• Builds Trust: It reassures customers and partners that their payment data is safe.
• Required for Payment Processing: Many banks and payment networks require an AoC before allowing transactions.

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What’s Included in a PCI AoC?

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A PCI Attestation of Compliance (AOC) includes the following key sections:

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1. Scope of Assessment

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• Defines the systems, networks, and processes evaluated under PCI DSS.
  
• Outlines the Cardholder Data Environment (CDE), i.e. identifies all systems, networks, and processes that handle payment card data.
  
• For online businesses, the Scope of Assessment must also include compliance with PCI DSS 6.4.3 (script management) and 11.6.1 (tamper detection for payment pages).
  

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2. Compliance Status

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• Confirms if all PCI DSS requirements were met.
• Identifies any compliance gaps and necessary remedy efforts.
  

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3. Assessment Method

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• Explains how compliance was validated by a QSA (Qualified Security Assessor) or through an SAQ (Self-Assessment Questionnaire).
  
• Includes details on testing methods and the assessment date.
  

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4. Security Measures

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• Describes encryption, network security, and access controls used to protect payment data.
  
• Demonstrates how the organization maintains compliance.
  
  

5. Assessor Information

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• Identifies the QSA responsible for the audit or the SAQ details for lower-level merchants.

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How to Get a PCI AoC in 3 Steps

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1. Become PCI DSS Compliant

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• To obtain an AoC, your business must fully comply with applicable PCI DSS requirements.

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2. Determine Your PCI DSS Compliance Level

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Your PCI level depends on the number of transactions your business processes annually:

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Larger businesses (Level 1 & Level 2) must hire a QSA for a compliance audit and AoC.

Smaller businesses (Level 3 & Level 4) can self-assess with an SAQ and submit an AoC.

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3. Determine the Appropriate SAQ or Assessment Type

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You must determine which Self-Assessment Questionnaire (SAQ) applies to your business. If you are working with a Qualified Security Assessor (QSA), they will first verify whether your business qualifies for a specific SAQ type (e.g., SAQ-A, SAQ-A-EP, SAQ-D) before confirming that the applicable controls are in place. The SAQ you choose dictates the scope of your compliance validation and the specific security controls required. 

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4. Submit Your PCI AoC

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Once the assessment is complete, businesses must submit their AoC to relevant payment providers and banks to verify compliance.

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How Long is a PCI AoC Valid?

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• A PCI AoC is valid for one year from the issue date.
• Organizations must renew their AoC annually to maintain PCI DSS compliance.
• Payment processors and partners may require updated AoCs before contract renewals.

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Next Steps: Reduce Your Scope for PCI DSS Compliance

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Meeting PCI DSS requirements and obtaining an AoC can be complex, especially for businesses handling large volumes of payment data. The more systems and processes within your PCI scope, the more requirements you must follow (up to 329 controls in PCI DSS v4.0).

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How DataStealth Helps:

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At DataStealth, we offer solutions which accomplish the following:

• Minimizes PCI scope by removing payment card data from your environment before it ever enters, ensuring fewer systems are subject to compliance requirements.
  
  
• Eliminates the need for code changes, APIs, or changes to user behaviour, making implementation effortless and seamless.
  
  
• Reduces compliance workload by lowering the number of applicable PCI DSS controls up to 90%, helping you move from SAQ-D to SAQ-A where possible.
  
  
• Improves efficiency & security by using tokenization, ensuring that no sensitive data resides within your systems, even in the event of a breach.

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Frequently Asked Questions (FAQs)

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1. What is the difference between a PCI AoC and a PCI RoC?

A PCI Attestation of Compliance (AoC) is a summary document confirming that an organization has completed its PCI DSS compliance assessment, whereas a PCI Report on Compliance (RoC) is a detailed report that provides an in-depth breakdown of how the organization meets each PCI DSS requirement.

AoC can be shared with payment processors, partners and major clients who need to confirm compliance, whereas RoC must be kept confidential and should only be shared with payment processors who require full PCI validation.

2. Do small businesses need an AoC?

Yes. All businesses that handle, store, or process payment card data need PCI compliance, regardless of their size.

• Level 3 & 4 merchants (fewer than 1M transactions per year) can self-assess using a PCI SAQ (Self-Assessment Questionnaire) and submit an AoC.
  
  
• Level 1 & 2 merchants (processing 1M+ transactions) must undergo a formal audit by a Qualified Security Assessor (QSA) and receive an AoC along with a RoC.

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3. How long is a PCI AoC valid?

A PCI AoC is valid for one year from the date of issue. Businesses must renew it annually to maintain PCI DSS compliance.

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4. What happens if your business is not PCI DSS compliant?

Failure to comply with PCI DSS can result in:

• Hefty fines from payment providers, ranging from $5,000 to $100,000 per month.
  
• Suspension of payment processing privileges, i.e. losing the ability to accept payment cards.
  
• Legal liabilities in case of a data breach.
  
• Reputational damage and loss of customer trust.

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5. Can third-party service providers handle PCI AoC compliance for you?

Not entirely. Even if you use a third-party payment processor, you may still be responsible for PCI compliance.

Example: If you outsource your payments to a third-party payment provider, they handle PCI compliance for payment processing but your business is still responsible for securing customer data on your website.

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6. Does using tokenization or encryption remove your PCI compliance requirements?

No, but it can reduce PCI scope.

• Tokenization replaces sensitive card data with a non-sensitive token, reducing how much cardholder data your system handles.
  
  
• Encryption secures data in transit and at rest, minimizing security risks.
  
  
• PCI DSS still applies, but using tokenization can significantly reduce the number of PCI requirements you need to meet.

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Common PCI AoC & RoC Compliance Mistakes (And How to Avoid Them)

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Mistake #1: Assuming Third-Party Payment Providers Cover All Compliance

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Many businesses believe that using a third-party payment provider means they don’t need to worry about PCI compliance. However, even when outsourcing payments, merchants are still responsible for ensuring compliance with PCI DSS.

How to avoid it:

• Determine your PCI scope by checking whether you handle, store, or transmit cardholder data.
  
• Even if payments are outsourced, confirm with your provider whether you still need to complete an SAQ (Self Assessment Questionnaire).
  
  

Mistake #2: Not Defining the Right Scope of Assessment Correctly

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If your Scope of Assessment is too broad, you may end up applying PCI DSS controls to unnecessary systems, increasing costs and complexity. If it’s too narrow, you might overlook critical payment systems, leading to compliance gaps.

How to avoid it:

• Clearly define your Cardholder Data Environment (CDE), ensuring it includes systems that store, process, or transmit cardholder data.
  
• Use PCI DSS scope reduction techniques, like tokenization, to minimize compliance requirements. (See DataStealth Audit Scope Reduction Solution)
  
• Leverage Data Discovery and Classification Solutions to systematically scan structured and unstructured data sources, identifying where PAN is stored (See DataStealth Data Discovery and Classification Solution).
  
  

Many organizations unknowingly store Primary Account Numbers (PAN) in unauthorized locations, increasing their risk. By integrating such a solution, merchants can:

• Accurately detect and classify sensitive data across all systems, known and unknown.
  
• Reduce compliance scope by eliminating unnecessary PAN storage.
  
• Apply consistent data protection policies across all environments to prevent leakage and unauthorized access.

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Mistake #3: Overlooking PCI DSS Requirements 6.4.3 & 11.6.1 for Online Businesses

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Many online merchants don’t realize that PCI DSS requires them to track all scripts on payment pages (6.4.3) and monitor for tampering (11.6.1). Failure to comply can lead to serious security risks, including form-jacking or skimming attacks.

How to avoid it:

• Implement a script management solution to monitor third-party scripts running on payment pages.
  
• Use tamper detection tools to detect unauthorized changes to payment forms in real time.

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Mistake #4: Delaying PCI AoC Renewals

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A PCI AoC is valid for one year. If you fail to renew it promptly, your business faces the risk of non-compliance. This could result in substantial penalties from payment providers, the halting of card payment processing, and harm to your reputation if customers discover your business lacks PCI compliance.

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Mistake #5: Treating PCI Compliance as a One-Time Task

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Many businesses only focus on compliance once a year; however, PCI DSS requires ongoing controls and security measures, such as:

• Quarterly vulnerability scans to identify and address security weaknesses
  
• Regular penetration testing to simulate real-world attacks and strengthen defences.
  
• Employee security training to ensure staff understand and follow security protocols.
  
• Periodic system scans for PAN (Primary Account Number) data to detect and eliminate any unintended storage or leakage of sensitive cardholder information.

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For More PCI DSS Guidance, See:

• Why Payment Page Security Should Outweigh Compliance Checklists
• What QSAs Want to See for PCI DSS 6.4.3 and 11.6.1 Compliance

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