Should You Complete a PCI SAQ on Your Own or Engage a QSA?

For organizations that accept, process, store, or transmit payment card data, PCI DSS compliance is a required but often misunderstood responsibility. One of the most common questions we hear is whether an organization should complete a PCI Self-Assessment Questionnaire on its own or engage a Qualified Security Assessor to attest and sign it.

As an active PCI Qualified Security Assessor that has supported merchants and service providers across industries for many years, CompliancePoint regularly helps organizations determine whether a self-signed SAQ is appropriate or whether QSA involvement provides a safer and more defensible outcome.

The right answer depends on the organization’s payment environment, risk tolerance, and the expectations of acquirers and processors for merchants, as well as customers or other third parties for service providers.

What Is a PCI SAQ?

A PCI Self-Assessment Questionnaire is a validation method defined by the PCI Security Standards Council for organizations with lower transaction volumes or simpler cardholder data environments.

There are multiple SAQ types, including A, A-EP, B, B-IP, C, C-VT, and D, each aligned to how payment card data flows through systems. Selecting the wrong SAQ type is one of the most common and costly mistakes organizations make.

As PCI DSS continues to evolve, including increased emphasis on documented responsibility, evidence, and ongoing validation under PCI DSS v4.0.1, accurate scoping and independent review are becoming even more important.

In practice, acquirers and processors, as well as customers and other third parties, frequently reject SAQs that are incorrectly scoped or do not accurately reflect the payment environment, sometimes months after submission. When that happens, organizations are often required to revalidate compliance under increased scrutiny and tighter timelines.

Option 1: Completing a Self-Signed PCI SAQ

A self-signed SAQ means the organization determines the appropriate SAQ type internally, completes all applicable PCI DSS requirements on its own, and signs the Attestation of Compliance without QSA involvement.

Organizations still receive an Attestation of Compliance when completing a self-signed SAQ. The distinction is that the AOC is signed by the organization itself rather than attested and signed by an independent Qualified Security Assessor.

When a Self-Signed SAQ May Be Appropriate

A self-signed SAQ can be reasonable when the payment environment is very simple, payment processing is fully outsourced to validated third-party providers, transaction volumes are low, cardholder data is not stored internally, and there is no contractual or external requirement for QSA attestation.

Hidden Complexity to Watch For

Even environments that appear simple can introduce unintended PCI scope over time. Fallback transaction handling, misunderstandings about vendor responsibility, internal system or log access, or new integrations can quietly expand PCI obligations. Without an objective, third-party review of the environment, these changes often go unnoticed.

Risks to Consider with a Self-Signed SAQ

While a self-signed SAQ may appear faster or less expensive, it carries real risk. Common challenges include incorrect SAQ selection, misinterpretation of PCI DSS requirements, incomplete or inaccurate responses, and overreliance on vendor assurances.

After a breach, forensic investigators and card brands assess whether the SAQ accurately reflected the organization’s environment at the time of validation, not whether it was completed with good intentions. Errors in a self-signed SAQ can lead to fines, mandatory remediation, and in some cases loss of merchant privileges or contractual consequences with customers or other third parties.

Option 2: Engaging a QSA for an Attested SAQ

A QSA-attested SAQ involves a Qualified Security Assessor independently reviewing the payment environment, validating scope, ensuring the correct SAQ type is used, and confirming that applicable PCI DSS requirements are met.

Organizations still receive an Attestation of Compliance in this scenario. The difference is that the AOC is formally attested and signed by an authorized QSA, providing independent validation that is recognized by acquirers, processors, customers, and other third parties.

At CompliancePoint, our QSAs validate cardholder data flows, confirm scope and SAQ applicability, identify gaps before submission, provide defensible documentation, and attest and sign the AOC.

It is important to distinguish between informal PCI advisory services and formal QSA attestation. Only an authorized QSA can validate scope and sign an Attestation of Compliance in a manner that carries independent weight with external stakeholders.

When QSA Attestation Is the Better Choice

Organizations often benefit from QSA attestation when they operate complex or evolving payment environments, rely on multiple vendors or custom integrations, process higher transaction volumes, or face increased scrutiny from acquirers and processors.

For service providers, QSA attestation is frequently requested by customers or other third parties as part of vendor risk management, contracting, or ongoing assurance requirements.

QSA involvement is also common during security questionnaire reviews tied to sales cycles, mergers and acquisitions or due diligence activities, and expansions into new payment channels or geographic markets.

Even when self-signing is technically permitted, many organizations find that external stakeholders strongly prefer or expect QSA attestation.

Cost vs. Risk: The Real Comparison

Consideration	Self-Signed SAQ	QSA-Attested SAQ
Upfront Cost	Lower	Higher
Confidence in Accuracy	Variable	High
Acceptance by Acquirers, Processors, Customers, and Third Parties	Not guaranteed	Strong
Risk Reduction	Limited	Significant
Audit and Review Readiness	Weak	Strong
Breach Defensibility	Low	High
Internal Time and Disruption	Often underestimated	Structured and predictable

What initially appears to be cost savings can become significantly more expensive if issues surface later.

A Common Misconception

“We’ve always self-signed our SAQ, so we must be fine.”

PCI environments evolve. New payment methods, updated integrations, changes in vendors, or internal access to systems can quietly invalidate prior assumptions. What was accurate in a previous year may no longer reflect the current environment.

How CompliancePoint Helps

CompliancePoint supports organizations at every stage of PCI compliance, including SAQ scoping and validation, QSA-attested SAQs, PCI readiness assessments, remediation guidance, and ongoing compliance support.

As a long-standing QSA with experience across assurance, cybersecurity, and privacy, CompliancePoint brings an independent and objective perspective to PCI compliance. That external viewpoint helps validate scope, ensure the correct SAQ type is applied, and identify gaps or assumptions that internal teams may overlook.

Final Thought: Which Option Is Right for You?

If an organization’s environment is simple and its risk tolerance is high, a self-signed SAQ may be acceptable. If the environment is complex, growing, or subject to scrutiny from acquirers, processors, customers, or other third parties, QSA attestation is often the safer long-term decision.

An objective review by an experienced QSA can often prevent months of rework later.

If there is uncertainty about which path applies, that uncertainty alone is usually a sign that expert guidance is warranted.

Ready for an Objective Review of Your Cardholder Data Environment?

Determining the correct PCI scope and SAQ type often requires more than internal knowledge of systems and vendors. An independent review by an experienced QSA can help ensure your cardholder data environment is accurately defined, assumptions are validated, and compliance efforts are defensible with acquirers, processors, customers, and other third parties.

If you would like CompliancePoint to perform an objective evaluation of your cardholder data environment and help determine the most appropriate PCI validation approach, we welcome the conversation.

You can reach our team at connect@compliancepoint.com to get started.