PCI DSS v3.2 SAQ D for Merchants, Rev. 1.1 January 2017
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Guidance for Non-Applicability of Certain, Specific Requirements
While many organizations completing SAQ D will need to validate compliance with every PCI DSS
requirement, some organizations with very specific business models may find that some requirements do
not apply. For example, a company that does not use wireless technology in any capacity would not be
expected to validate compliance with the sections of the PCI DSS that are specific to managing wireless
technology. Similarly, an organization that does not store any cardholder data electronically at any time
would not need to validate requirements related to secure storage of cardholder data (for example,
Requirement 3.4).
Examples of requirements with specific applicability include:
The questions specific to securing wireless technologies (for example, Requirements 1.2.3, 2.1.1,
and 4.1.1) only need to be answered if wireless is present anywhere in your network. Note that
Requirement 11.1 (use of processes to identify unauthorized wireless access points) must still be
answered even if you don’t use wireless technologies in your network, since the process detects
any rogue or unauthorized devices that may have been added without your knowledge.
The questions specific to application development and secure coding (Requirements 6.3 and 6.5)
only need to be answered if your organization develops its own custom applications.
The questions for Requirements 9.1.1 and 9.3 only need to be answered for facilities with
“sensitive areas” as defined here: “Sensitive areas” refers to any data center, server room or any
area that houses systems that store, process, or transmit cardholder data. This excludes the
areas where only point-of-sale terminals are present, such as the cashier areas in a retail store,
but does include retail store back-office server rooms that store cardholder data, and storage
areas for large quantities of cardholder data.
If any requirements are deemed not applicable to your environment, select the “N/A” option for that
specific requirement, and complete the “Explanation of Non-Applicability” worksheet in Appendix C for
each “N/A” entry.
Understanding the difference between Not Applicable and Not Tested
Requirements that are deemed to be not applicable to an environment must be verified as such. Using
the wireless example above, for an organization to select “N/A” for Requirements 1.2.3, 2.1.1, and 4.1.1,
the organization would first need to confirm that there are no wireless technologies used in their CDE or
that connect to their CDE. Once this has been confirmed, the organization may select “N/A” for those
specific requirements.
If a requirement is completely excluded from review without any consideration as to whether it could
apply, the “Not Tested” option should be selected. Examples of situations where this could occur may
include:
An organization may be asked by their acquirer to validate a subset of requirements—for
example: using the prioritized approach to validate certain milestones.
An organization may wish to validate a new security control that impacts only a subset of
requirements—for example, implementation of a new encryption methodology that requires
assessment of PCI DSS Requirements 2, 3 and 4.
A service provider organization might offer a service which covers only a limited number of PCI
DSS requirements—for example, a physical storage provider may only wish to validate the
physical security controls per PCI DSS Requirement 9 for their storage facility.
In these scenarios, the organization only wishes to validate certain PCI DSS requirements even though
other requirements might also apply to their environment.
Legal Exception
If your organization is subject to a legal restriction that prevents the organization from meeting a PCI DSS
requirement, check the “No” column for that requirement and complete the relevant attestation in Part 3.