Does SAQ P2PE require a penetration test?

PCI DSS v4.0.1. Last reviewed October 2026.

No. SAQ P2PE has no Requirement 11 section, so it does not require a penetration test, internal scans or ASV scans. It is for merchants that take cards only through payment terminals from a validated, PCI-listed point-to-point encryption (P2PE) solution, so they never have access to clear-text card data.

Does SAQ P2PE require a penetration test?

When SAQ P2PE stops applying

IfYou likely move toWhat that adds
Your terminals are encrypted but not a PCI-listed P2PE solutionSAQ B-IP or SAQ CASV scans and segmentation testing if used
You add a website that takes payments through a hosted payment pageSAQ A for that channelQuarterly ASV scans
You store card data on any computerSAQ D for merchantsFull penetration testing and scanning

Who qualifies for SAQ P2PE

The official SAQ P2PE lists these conditions. All must be true for this payment channel:

  • All payment processing goes through a validated, PCI-listed P2PE solution.
  • The only systems in your business that store, process or transmit card data are the terminals from that P2PE solution.
  • You do not otherwise receive, send or store card data electronically.
  • Any card data you keep is on paper only and is never received electronically.
  • You have put in place every control in the P2PE Instruction Manual (PIM) from your P2PE solution provider.

SAQ P2PE can apply to in-person and mail or phone order merchants who key orders only into the P2PE terminal. It does not apply to ecommerce or to service providers.

How to confirm your solution is P2PE

Ask your processor whether your terminals are part of a validated P2PE solution, then look it up on the PCI Security Standards Council list of validated P2PE solutions. "Encrypted" or "end-to-end encrypted" terminals are not the same as a PCI-listed P2PE solution.

How Clone Systems can help

PCI SAQ Finder

Confirm SAQ P2PE still fits in a few minutes.

PCI ASV scanning

Needed as soon as you add a website or a non-P2PE terminal, from $185 a year.

Penetration testing when someone asks for it

Cyber insurers and business customers often ask for a pen test even when PCI does not. Automated external tests from $1,995.

Ready when you are

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.

Frequently asked questions