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PCI DSS compliance checklist for small online stores (v4.0.1)

If your shop takes card payments, PCI DSS applies to you — even if a payment provider handles the card details. Here is what the standard asks of a small online store, which questionnaire you are likely to fill in, what changed in 2025, and a checklist you can work through this month.

By Alex Martyushin, founder & risk consultant · Updated 30 October 2026 · 13 min read

PCI compliance means meeting the Payment Card Industry Data Security Standard (PCI DSS), currently version 4.0.1, which applies to every business that accepts, stores, processes or transmits payment card data. Small online stores usually prove it once a year with a Self-Assessment Questionnaire and Attestation of Compliance sent to their acquirer, plus quarterly external vulnerability scans where required.

This is general guidance, not a Qualified Security Assessor (QSA) assessment. Which requirements apply to you depends on how your checkout is built and on your merchant agreement — confirm your level, questionnaire and deadlines with your acquirer.

What is PCI compliance and who enforces it?

PCI DSS is a set of security requirements for protecting payment card data: the card number (PAN), cardholder name, expiry date and, above all, the sensitive authentication data such as the CVV and PIN. It applies to any entity that stores, processes or transmits that data, or that can affect its security. For an online store, the website that sends a customer to the payment page is in scope even if the card number never touches your server.

Three parties are involved, and it helps to keep them apart:

Current version: PCI DSS v4.0.1

The PCI SSC published PCI DSS v4.0 in March 2022 and a limited revision, v4.0.1, in June 2024. v4.0.1 corrected and clarified wording but added no new requirements. Version 3.2.1 was retired on 31 March 2024 and v4.0 was retired at the end of 2024, so v4.0.1 is the only active version.

v4.0 introduced 64 new requirements. Most of them — 51 — were “future-dated”: best practice until 31 March 2025, mandatory from that date. Any assessment you complete now is against the full set, including the new e-commerce controls on payment page scripts (6.4.3 and 11.6.1), targeted risk analyses and stronger authentication rules.

PCI compliance levels 1–4

Card brands sort merchants into levels by annual transaction volume. The level decides how you validate compliance, not which security requirements apply — the standard is the same for everyone. The thresholds below are Visa’s; Mastercard uses broadly similar ones, and other brands differ. Your acquirer assigns your level.

LevelVisa transactions per yearTypical validation
Level 1Over 6 million across all channels, or any merchant the brand designates (for example after a breach)Annual Report on Compliance (ROC) by a QSA or qualified internal assessor, plus quarterly ASV scans
Level 21 to 6 million across all channelsAnnual SAQ (some acquirers and brands ask for more), plus scans where the SAQ requires them
Level 320,000 to 1 million ecommerce transactionsAnnual SAQ and AOC, plus scans where required
Level 4Fewer than 20,000 ecommerce transactions, or up to 1 million in totalAnnual SAQ and AOC as required by the acquirer, plus scans where required

Most small online stores are Level 4, and many are Level 3. A merchant that suffers a card data compromise can be moved up to Level 1 regardless of volume — one more reason not to treat Level 4 as “PCI-lite”.

Which SAQ applies to an online store?

A Self-Assessment Questionnaire is a cut-down version of the standard for one way of taking payments. Picking the right one is the biggest decision in your PCI work. For ecommerce there are three main options:

SAQWhen it appliesTypical checkoutEffort
SAQ AAll card data functions fully outsourced to PCI DSS compliant providers; you do not store, process or transmit card data on your systemsFull redirect to a hosted payment page, or a payment form served entirely by the provider in an iframeLowest
SAQ A-EPCard data is passed to the provider, but your website controls how the payment page or form is delivered and could affect the transactionYour page hosts the form fields and posts card data straight to the provider (“direct post”) or uses provider JavaScript on your own pageMedium
SAQ DAnything else, including storing card data or card numbers passing through your serverSelf-built or self-hosted gateway integrationHighest

The 2025 change to SAQ A

When the future-dated requirements arrived, SAQ A briefly included the script controls 6.4.3 and 11.6.1. In January 2025 the PCI SSC published a revised SAQ A. It removed requirements 6.4.3, 11.6.1 and 12.3.1 from SAQ A and added a new eligibility criterion: the merchant confirms that its site is not susceptible to attacks from scripts that could affect its e-commerce systems.

A PCI SSC FAQ published in February 2025 (FAQ 1588) explains how to meet that criterion: either by using techniques such as those in 6.4.3 and 11.6.1, or by getting confirmation from your PCI DSS compliant payment provider that its embedded payment form includes protection against script attacks when implemented as instructed. The criterion matters most where your page embeds the provider’s form in an iframe. The protection still has to exist; only the paperwork moved. If you cannot support the claim, you are not eligible for SAQ A.

The 12 PCI DSS requirements in plain English

PCI DSS is organised into six goals and twelve principal requirements. On SAQ A you will answer only a handful of sub-requirements from a few of them; on SAQ D you answer almost all. This table shows what each one means for a small online store.

#RequirementWhat this means for a small online store
1Install and maintain network security controlsFirewalls or cloud security groups around anything in scope; only the ports you need open. With hosted checkout this is mostly your provider’s job.
2Apply secure configurations to all system componentsNo default passwords on your store admin, hosting panel or database; remove unused plugins, accounts and services.
3Protect stored account dataDo not store card numbers at all. Never store CVV codes, even encrypted. Check that no card data sits in emails, support tickets or spreadsheets.
4Protect cardholder data with strong cryptography during transmissionHTTPS with current TLS everywhere on the site; never ask customers to send card details by email or chat.
5Protect all systems and networks from malicious softwareAnti-malware on staff computers and servers you manage; awareness of phishing, which is how most store admin accounts are stolen.
6Develop and maintain secure systems and softwareKeep your platform, theme and plugins patched; manage scripts on payment pages (6.4.3); protect public web apps against common attacks.
7Restrict access by business need to knowStaff, agencies and freelancers get only the admin rights they need; remove access when work ends.
8Identify users and authenticate accessNamed accounts, no shared logins, strong passwords and multi-factor authentication on admin and hosting accounts.
9Restrict physical access to cardholder dataUsually minimal online. Do not write card numbers on paper; secure any card terminals if you also sell in person.
10Log and monitor all accessKeep admin and server logs and someone actually looks at alerts. Mostly relevant on SAQ A-EP and D.
11Test security of systems and networks regularlyQuarterly external ASV scans where your SAQ requires them; penetration tests on A-EP and D; payment page tamper detection (11.6.1).
12Support information security with policies and programmesA short security policy, an incident response plan, an annual check of your providers’ PCI status and a written list of who does what.

Requirements 6.4.3 and 11.6.1: payment page scripts

These two requirements exist because of web skimming, often called Magecart after the groups that made it common. Attackers do not need to break into the payment provider. They inject a few lines of JavaScript into the merchant’s checkout — through a compromised plugin, an analytics tag, a chat widget or a stolen admin password — and the script copies card details as the customer types them. The payment still succeeds, so these breaches can run for months unnoticed.

On SAQ A, ask the eligibility question honestly: if a tag manager on your product pages were compromised tomorrow, could it reach your checkout? If “possibly”, record it as a risk and fix it.

PCI compliance checklist for a small online store

Work through these in order. Each unticked box is a gap to record with an owner and a target date (see below).

Scope and validation

Card data

Website and checkout

Access

Testing and monitoring

Providers and policy

ASV scans and penetration testing

An ASV scan is an external vulnerability scan run by an Approved Scanning Vendor listed by the PCI SSC. Requirement 11.3.2 asks for one at least every three months, and after significant changes, with a passing result. Since v4.0 this requirement appears in SAQ A as well as SAQ A-EP and SAQ D, so most online merchants need quarterly scans of their public-facing website. A failing scan means fixing the issues and rescanning. Some acquirers bundle scanning into their PCI programme — ask before buying separately.

PCI penetration testing (requirement 11.4) is a manual attempt to break in, done at least once a year and after significant changes. It is part of SAQ A-EP and SAQ D but not SAQ A. For the day-to-day work of finding and fixing weaknesses, see our guide to building a vulnerability management process.

Hosted checkouts: Stripe, Shopify Payments, PayPal

The fastest way to shrink PCI scope is to keep card numbers off your systems entirely. Hosted payment pages and provider-served payment fields do that, which is why most small stores using them qualify for SAQ A.

What these services do not do for you:

What PCI compliance costs

There is no single price. For a small online store, the cost of PCI compliance is driven mainly by:

PCI non-compliance fees are separate. Many acquirers charge a monthly fee to merchants that have not submitted a valid SAQ and AOC, or pass on a PCI programme fee. The amounts are set in your merchant agreement and vary widely, so check your statements and contract rather than relying on published averages. After a breach the costs are of a different order: forensic investigation, card brand assessments, card reissue and fraud recovery charges, and possible loss of card acceptance.

Recording PCI gaps in your risk register

A checklist shows where you fall short today; a risk register makes sure the gaps get closed. Record each material gap as a risk with an owner, a target date and the evidence that will close it:

RiskGapOwnerAction and due dateEvidence
Card data skimmed from checkout by a malicious scriptNo inventory of checkout scripts; marketing tags load on payment pageHead of ecommerceRemove non-essential tags, set CSP, enable change alerts — 30 daysScript inventory; CSP header; alert test
Store admin account taken overMFA not enforced for agency accountsOperations managerEnforce MFA for all admin users; remove stale accounts — 14 daysAdmin user export showing MFA status
Acquirer non-compliance fees and loss of SAQ A eligibilityQuarterly ASV scans missed twiceFinance leadSchedule scans; fix findings — next quarterPassing ASV reports

Score each risk on your usual risk matrix, and track the residual score once controls are in place.

Common mistakes

Frequently asked questions

Do I need to be PCI compliant if I use Stripe, Shopify Payments or PayPal?

Yes. A compliant provider reduces your scope, often to SAQ A, but does not remove it. You still validate each year, secure your website and the page that loads the payment form, and submit what your acquirer asks for.

What are the PCI compliance levels?

Four levels based on annual transactions. Under Visa’s scheme: Level 1 over 6 million; Level 2 1–6 million; Level 3 20,000 to 1 million ecommerce; Level 4 fewer than 20,000 ecommerce or up to 1 million in total. Your acquirer confirms your level.

What is a PCI attestation of compliance?

The signed form declaring the result of your assessment. Smaller merchants complete it with their SAQ; larger ones receive it with a QSA’s Report on Compliance. You submit it to your acquirer and should ask your providers for theirs.

What happens if I am not PCI compliant?

Acquirers typically charge non-compliance fees set in your merchant agreement. After a breach you may face forensic costs, card brand assessments, fraud recovery charges, a higher validation level or loss of card acceptance.

Turn PCI gaps into tracked risks

In Risk Samurai each PCI gap becomes a risk with an owner, a deadline and the evidence that closes it — so the annual questionnaire is a summary of work already done, not a scramble. AI drafts the first version of your register.

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