PCI DSS v4.0.1 Self-Assessment Questionnaire (SAQ C) — Cardholder Data Security Controls for Payment Application Systems

SmartSuite provides the system for managing controls, evidence, mappings, assessments, and reporting. Framework text may require a separate license unless explicitly provided.
Overview
PCI DSS v4.0.1 Self-Assessment Questionnaire (SAQ C) is a compliance assessment tool that helps organizations validate the implementation of security controls for payment application systems that store, process, or transmit cardholder data. It is a key part of the Payment Card Industry Data Security Standard (PCI DSS), which aims to protect payment card information and reduce the risks of data breaches.
Published by the PCI Security Standards Council (PCI SSC), this questionnaire is intended for merchants with payment application systems connected to the internet but without electronic storage of cardholder data. SAQ C covers essential cybersecurity requirements, including data protection, access controls, network security, and regular monitoring, ensuring compliance with industry regulations for cardholder data environments.
Organizations complete SAQ C by evaluating and documenting their adherence to specific PCI DSS controls, supporting internal risk management and compliance programs. This process helps strengthen payment system security, prepare for third-party audits, and demonstrate compliance to acquiring banks and card brands within the broader landscape of payment security standards.
Why it Matters
PCI DSS v4.0.1 SAQ C ensures organizations that handle payment application systems effectively safeguard cardholder data and minimize payment security risks.
Key benefits include:
- Strengthen data protection practices
Safeguard cardholder data through robust controls, reducing the risk of unauthorized access or data breaches in payment environments.
- Improve compliance support
Demonstrate adherence to PCI DSS requirements, enabling smoother assessments and reducing risk of non-compliance penalties.
- Enhance incident response preparedness
Establish structured processes for timely detection and response to security incidents involving payment application systems.
- Increase audit readiness
Maintain clear documentation and evidence of security controls to streamline audit preparation and their assessments.
- Promote operational resilience
Reduce the risk of service disruptions from security incidents by implementing robust security practices aligned with PCI DSS requirements.
How it Works
PCI DSS v4.0.1 SAQ C is structured as a targeted self-assessment questionnaire for organizations operating payment application systems connected to the internet. The SAQ organizes its control requirements into domains covering application security, access controls, encryption, and logging practices that protect cardholder data within payment application environments.
Organizations implement SAQ C by evaluating their payment application systems against the prescribed controls, identifying gaps, and applying required security safeguards. Typical activities include reviewing network segmentation and access controls, implementing multi-factor authentication, ensuring patch management for payment applications, and maintaining evidence to support ongoing compliance. Regular assessments and periodic reviews support consistent adherence to PCI DSS requirements across payment application environments.
With SmartSuite, organizations can operationalize SAQ C compliance by leveraging control libraries mapped to SAQ C requirements, maintaining risk registers, and managing policy governance for payment security. The platform supports evidence collection, compliance tracking, and reporting dashboards that provide visibility into control status, streamlining audit readiness and facilitating remediation workflows for payment application security programs.
Key Elements
- Payment Application Security Controls
Specifies security requirements for payment applications, including patch management, secure configurations, and access restrictions.
- Network Security and Segmentation
Describes requirements for securing network environments and implementing appropriate segmentation within payment application systems.
- Access Control and Authentication
Outlines controls for managing user access, including multi-factor authentication and restrictions on privileged access to payment systems.
- Logging and Monitoring Requirements
Defines criteria for maintaining audit logs and monitoring systems to detect unauthorized activity in payment environments.
- Incident Response Procedures
Establishes structured processes for identifying, containing, and responding to security incidents within payment application systems.
- Vendor Management Obligations
Specifies requirements for managing third-party vendors and service providers with access to payment application environments.
Framework Scope
PCI DSS v4.0.1 SAQ C is used by merchants that process cardholder data through payment application systems connected to the internet. It governs payment applications and their supporting environments, and is typically implemented to comply with PCI DSS requirements, improve payment security controls, and support audit readiness for payment card compliance programs.
Framework Objectives
PCI DSS v4.0.1 SAQ C defines security requirements to protect cardholder data in payment application environments and support PCI DSS compliance.
Protect cardholder data through robust access controls and application security measures
Enhance compliance with PCI DSS requirements for payment application environments
Strengthen governance and oversight of payment security controls and processes
Improve incident response preparedness for security events in payment systems
Support audit readiness through structured documentation and ongoing compliance monitoring
Promote operational resilience by reducing security risks in payment application environments
Framework in Context
PCI DSS v4.0.1 SAQ C is a targeted self-assessment questionnaire for merchants using payment applications connected to the internet, aligned with the broader PCI DSS v4.0.1 standard. Organizations use it to demonstrate compliance, reduce payment security risks, and meet assessment obligations for payment card industry standards.
Common Framework Mappings
PCI DSS v4.0.1 SAQ C is commonly mapped to broader payment security and information security frameworks to demonstrate comprehensive control coverage and align security practices across payment application environments.
Mapped frameworks include:
ISO/IEC 27001
ISO/IEC 27002
NIST Cybersecurity Framework
NIST SP 800-53
PCI DSS v4.0.1
PCI PA-DSS
SOC 2
- ClassificationCategoryPayment SecurityDomainCybersecurityFramework FamilyPCI Security Standards
- Regulatory ContextTypeStandardLegal InstrumentStandardSectorFinancial SectorIndustryPayment & FinTech
- Region / PublisherRegionGlobalRegion DetailPCI DSS v4.0.1 (including the Self‑Assessment Questionnaire SAQ C) is issued and administered by the PCI Security Standards Council. This organization is headquartered in the United States. Therefore, the jurisdiction for this document is: United StatesPublisherPayment Card Industry Security Standards Council (PCI SSC)
- VersioningVersionv4.0.1Effective DateJune 11, 2024Issue DateJune 2024
- AdoptionAdoption ModelRegulatory ComplianceImplementation ComplexityHigh
- Official ReferenceOpen Link in New TabSource
License included / downloadable: Yes
The PCI DSS v4.0.1 SAQ C is published by the PCI Security Standards Council and is publicly available for download from the Council’s website.License included with platform
How SmartSuite Supports PCI DSS v4.0.1 SAQ C
Manage compliance for payment environments using payment application systems connected to the internet by organizing SAQ C requirements, tracking security controls, and maintaining audit-ready documentation.
SAQ C Requirement Library
Structure SAQ C requirements with mapped controls, implementation tasks, and accountable owners.
Payment Application Scope Documentation
Document payment application systems, infrastructure components, and network boundaries supporting transactions.
Network Security and Monitoring Controls
Track firewall rules, segmentation controls, and monitoring protecting payment application systems.
Payment System Vulnerability and Patch Management
Manage vulnerability scanning, patch deployment, and remediation activities affecting payment systems.
Access Reviews and Authentication Management
Track user access reviews, authentication policies, and privileged access management.
PCI DSS SAQ C Compliance Reporting
Provide dashboards showing requirement coverage, remediation progress, and readiness for PCI DSS SAQ C assessments.
Related frameworks

CIS Controls v8.1 provides prioritized, practical security actions to help organizations mitigate common cyber threats and strengthen defenses.

ISO/IEC 27001:2022 is an international ISMS standard that helps organizations manage information security risks and protect data.

ISO/IEC 27002:2022 provides best-practice information security controls to help organizations select, implement, and manage protections for information assets.

NIST Cybersecurity Framework (CSF) v2.0 is a risk-based framework that helps organizations manage and reduce cybersecurity risks.

NIST SP 800-53 Rev. 5 provides a catalog of security and privacy controls to manage risks to information systems.
Frequently Asked Questions For PCI DSS v4.0.1 SAQ C (Cardholder Data Security Controls for Payment Application Systems)
PCI DSS v4.0.1 SAQ C is a self-assessment questionnaire designed for merchants with payment application systems that process cardholder data but do not store electronic cardholder data. It helps organizations validate their compliance with PCI DSS requirements specifically related to securing cardholder data during processing and transmission.
PCI DSS v4.0.1 SAQ C is required for merchants that meet certain eligibility criteria, such as those whose payment application systems are connected to the internet and do not store cardholder data electronically. The use of this SAQ is determined by your acquirer or payment brand, so eligibility must be confirmed with them.
SAQ C is applicable to merchants with payment application systems that are internet-connected, do not store electronic cardholder data, and process payments via standalone terminals or systems. Organizations that store cardholder data electronically, or use systems integrated with other network components, may need to use a different SAQ.
The SAQ C requires controls such as installing and maintaining secure systems, protecting cardholder data during transmission, maintaining vulnerability management programs, implementing strong access controls, monitoring security of systems, and maintaining an information security policy.
Merchants should ensure that all payment application systems are securely configured, regularly patched, and segmented from other systems. Strong authentication, encryption for cardholder data in transit, and regular monitoring for unauthorized access or vulnerabilities are essential for effective compliance.
SAQ C is tailored for a specific merchant environment where payment applications are used and cardholder data is not stored electronically. Other SAQs, like SAQ A or SAQ B, apply to different setups, such as fully outsourced payment processing or standalone terminal environments. Selecting the correct SAQ is critical for accurate assessment.
Ongoing compliance involves conducting annual self-assessments, maintaining required security controls, performing quarterly network scans, and keeping documentation and evidence of compliance. Regular staff training and incident response procedures are also necessary to protect cardholder data consistently.
SmartSuite can help organizations manage PCI DSS v4.0.1 SAQ C by enabling risk tracking, assigning and monitoring control implementation, and centralizing evidence collection for each control. It also supports audit readiness through structured workflows and provides real-time reporting to demonstrate ongoing compliance and streamline assessments.
Manage controls, risks, evidence, and audits in one platform designed for modern governance, risk, and compliance.

