Which PCI SAQs require a penetration test?

PCI DSS v4.0.1. Last reviewed October 2026.

Five of the ten PCI DSS self-assessment questionnaires require some form of penetration testing: SAQ D for service providers, SAQ D for merchants, SAQ A-EP, SAQ C and SAQ B-IP. The other five (SAQ A, B, C-VT, P2PE and SPoC) do not. Your quarterly ASV scan covers Requirement 11.3.2. A penetration test covers Requirement 11.4. They are different requirements.

Which PCI SAQs require a penetration test?
SAQWho uses itPenetration test required?What it asks for
SAQ D Service ProviderBusinesses that store, process or transmit card data for other businessesYesInternal and external testing every 12 months, retesting, and segmentation testing every 6 months (11.4.1 to 11.4.6; 11.4.7 for multi-tenant providers)
SAQ D MerchantMerchants that store card data or do not fit another SAQYesInternal and external testing every 12 months, retesting, and segmentation testing if used (11.4.1 to 11.4.5)
SAQ A-EPEcommerce sites whose own pages affect the payment formYesExternal penetration testing every 12 months, plus retesting
SAQ CPayment application on a system connected to the internetWhen segmentation reduces scopeSegmentation testing every 12 months (11.4.5)
SAQ B-IPStandalone payment terminals connected over IPWhen segmentation reduces scopeSegmentation testing every 12 months (11.4.5)
SAQ AEcommerce fully outsourced to a PCI compliant processorNoQuarterly ASV scans are still required (11.3.2)
SAQ BImprint machines or standalone dial-out terminalsNoNone
SAQ C-VTVirtual terminal on one isolated computerNoNone
SAQ P2PEPCI listed point-to-point encryption terminals onlyNoNone
SAQ SPoCSoftware-based PIN entry on a phone or tabletNoNone

Not sure which SAQ you file?

Your acquiring bank or payment processor tells you which SAQ to complete. If you buy PCI ASV scanning from Clone Systems, your SAQ type is in your portal.

Not sure which SAQ you file? Use the SAQ Finder

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One team for 11.3 and 11.4

Clone Systems has been a PCI Approved Scanning Vendor since 2007. The same team that runs your quarterly ASV scans runs penetration tests of every type for every SAQ, delivered remotely. Automated external tests start at $1,995 and can be bought online and started the same day. Engineer-led tests are scoped to your environment.

Who runs your test

Clone Systems penetration testers hold CISSP, CMMC Certified Professional (CCP), API Penetration Testing (APIsec University), Hack The Box Dante Pro Lab, DevOps for Pentesters (Zero-Point Security), Practical Malware Analysis (TCM Security) and Targeted Malware Reverse Engineering (Kaspersky) credentials, and work alongside PCI ASV qualified staff. Every test is remote; we do not perform on-site testing.

Frequently asked questions

Source: PCI Security Standards Council, PCI DSS v4.0.1 Self-Assessment Questionnaires. PCI Security Standards Council document library