PCI compliance is an essential safeguard for payment card data and a cornerstone of stakeholder trust. A critical component in demonstrating your compliance is the Report on Compliance (RoC), an extensive assessment conducted by a Qualified Security Assessor (QSA) that measures how well an organization meets PCI Data Security Standard (PCI DSS) requirements. This evaluation not only validates the organization’s compliance status but also provides a roadmap for enhancing data security practices. By prioritizing the RoC process, organizations meet the requirements of their financial institutions and demonstrate their commitment to mitigating risks and maintaining stakeholder trust in the face of increasing cyber threats. Let’s explore the RoC’s components, significance, and processes so you can confidently achieve and maintain PCI compliance.
Key Elements of the RoC
The RoC is a crucial document for PCI DSS compliance, offering a detailed evaluation of how well an organization adheres to rigorous data security regulations. The RoC must be completed by a QSA or team of QSAs designated by the PCI Security Standards Council (PCI SSC), who will conduct an onsite assessment equipped with interviews with company personnel to determine what PCI requirements are in place and where remediation is required. From there the QSA will summarize their findings regarding the controls in place and the evidence collected during the audit process. Once the RoC is completed, the assessor will present their findings to the client which will include an “Assessment Overview” and a “Summary of Findings”, and the appropriate certification documentation will be submitted to various credit card brands.
RoC Assessment Overview
The Assessment Overview within the Report on Compliance (RoC) concisely summarizes the entire assessment report. Its primary purpose is to delineate the scope of the assessment along with comparing policies and procedures against the PCI DSS. This section typically includes critical details such as the organization’s network segmentation, specifics regarding the payment applications scrutinized, the version of PCI DSS utilized for the assessment, the timeframe of the assessment period, and other pertinent contextual information relevant to the evaluation.
RoC Summary of Findings
The Summary of Findings provides a granular view of the organization’s compliance status, pinpointing areas that require further attention or remediation through services like vulnerability and penetration testing. This detailed analysis enables stakeholders to understand precisely where the organization stands in terms of PCI DSS compliance, facilitating targeted efforts to strengthen data security practices and effectively uphold regulatory standards.
Understanding your Summary of Findings is critical to meeting PCI DSS standards as it categorizes findings into several key classifications:
- In place – indicates that all requirements have been thoroughly tested and successfully met.
- Not applicable – applies to situations where specific obligations do not pertain to the organization.
- Not tested – signifies requirements that were not evaluated during the assessment process.
- Not in place – indicates that some or all requirements still need to be fulfilled, are currently being implemented, or require further testing.
Resolving any outstanding issues is essential, as PCI compliance validation operates on a binary basis—all requirements must be fully met to achieve compliance. To help achieve compliance, Drummond tracks all remediation efforts and provides weekly status reports to the client to help with remediation steps.
PCI Levels Impact on RoC Requirements
While a RoC can be extremely helpful in maintaining compliance and safeguarding consumer data, its intensive scope is not required for every organization impacted by PCI compliance. Moreover, whether an organization needs to complete a RoC depends on its PCI compliance category. The organization’s annual transaction volume primarily determines this variation in protocol. As a result, there are two categories of service providers and four categories of merchants, which gives way to six different categories of PCI compliance.
The table below delineates the compliance categories that must complete a RoC to become PCI DSS compliant. While the delineated requirements are typically accurate, PCI DSS certification requirements are dependent on the level of the service provider as determined by their acquirer or the payment brands. Merchants and service providers should contact their acquirer or the payment brands to identify their specific validation and reporting requirements:
| Merchant Level | Certification Required |
| Level 1 (> 6 million transactions annually) | ROC AOC |
| Level 2 (1 million to 6 million transactions annually) | SAQ AOC |
| Level 3 (20k to 1 million transactions annually) | SAQ AOC |
| Level 4 (< 20k transactions annually) | SAQ AOC |
| Service Provider Level | Certification Required
|
| Level 1 – (More than 300k transactions annually) | ROC AOC |
| Level 2 – (Less than 300k transactions annually) | SAQ AOC |
Final Thoughts
The Report on Compliance (RoC) is a critical step for any impacted merchants or service providers working toward PCI compliance. And for merchants and service providers who do not have a mandatory RoC requirement, it can be a beneficial process in the advancement of their data security efforts. However, selecting the right QSA to conduct your PCI assessment and put together a RoC is critical for organizations aiming to achieve and maintain PCI DSS compliance effectively. A reputable QSA brings expertise and rigor to the assessment, they also understand that remediation is often required and offer flexibility to help ensure the outcome of your RoC is a positive one. By partnering with the right QSA you can ensure the RoC process strengthens your overall data protection measures while elevating market trust. With years of hands-on experience and rigorous training, Drummond’s QSAs possess a deep understanding of the PCI DSS regulatory framework. Contact Drummond today to access our experienced and reputable QSAs, proficient in streamlining your RoC process while also fortifying the security of your business.