PCI DSS SAQ A-EP Compliance Guide
The self-assessment for e-commerce merchants whose websites affect payment data security — significantly more rigorous than SAQ A.
Understand when SAQ A-EP applies, the web security requirements involved, and how GRCTrack helps you navigate this demanding compliance path.
What Is SAQ A-EP?
SAQ A-EP (E-Commerce Partially outsourced) is designed for e-commerce merchants who partially outsource their payment processing but whose website still plays a role in the security of the payment transaction. Unlike SAQ A merchants who fully outsource, SAQ A-EP merchants have website elements — typically JavaScript code — that control how cardholder data is transmitted to the payment processor.
This SAQ applies when the merchant's website does not receive cardholder data directly, but the merchant's web server and application code can affect the integrity and security of the payment page. Common scenarios include using JavaScript-based payment forms (like Stripe Elements or Braintree hosted fields), direct post integrations, and any implementation where the merchant's page code loads or controls payment-related scripts.
With approximately 139 requirements, SAQ A-EP is substantially more demanding than SAQ A's 22 requirements. This reflects the increased risk that comes with having website code that could be compromised to intercept or redirect payment data. Merchants must implement web application security, network protection, vulnerability management, and comprehensive access controls.
Who Qualifies for SAQ A-EP?
Key SAQ A-EP Requirement Areas
Req 1: Network Security
Install and maintain network security controls including firewalls and network segmentation to protect your web servers and payment page infrastructure.
Req 2: Secure Configurations
Apply secure configurations to all system components including web servers, application servers, and any infrastructure that hosts or delivers payment pages.
Req 6: Secure Development
Develop and maintain secure systems and software. Includes secure coding practices, code reviews, web application firewalls, and client-side script management (6.4.3).
Req 7 & 8: Access Controls
Restrict access to system components by business need-to-know and identify and authenticate all users. Strong authentication is required for all access to web application infrastructure.
Req 11: Security Testing
Regularly test security systems including ASV scans, penetration testing, intrusion detection, and payment page change-and-tamper-detection mechanisms (11.6.1).
Req 9 & 12: Physical & Policy
Restrict physical access to system components, maintain security policies, manage third-party relationships, and implement security awareness training.
Common SAQ A-EP Mistakes
Thinking SAQ A Applies When Using JavaScript Forms
The most common mistake is assuming that because cardholder data goes directly to the processor, SAQ A applies. If your website loads JavaScript that controls how payment fields are rendered or how data is transmitted, your site can affect payment security, making SAQ A-EP the correct choice.
Not Understanding Redirect vs. Iframe Triggers
Merchants often conflate redirect and iframe implementations. A true redirect takes the customer to the processor's domain. An iframe embeds the processor's page. Both can qualify for SAQ A — but if your page JavaScript interacts with either, you may need SAQ A-EP. The technical implementation details, not the visual appearance, determine the correct SAQ.
Missing Req 6.4.3 Client-Side Script Management
PCI DSS v4.0.1 requires merchants to maintain an inventory of all scripts loaded on payment pages, justify each script, and implement integrity monitoring. Many SAQ A-EP merchants underestimate this requirement, particularly when using third-party analytics, tag managers, or advertising scripts on checkout pages.
Failing Web Application Firewall Requirements
SAQ A-EP requires a web application firewall (WAF) or equivalent protection for web-facing applications. Merchants who rely solely on network firewalls without implementing application-layer protection fail to meet Requirement 6.4 and leave their payment pages vulnerable to application-level attacks.
How GRCTrack Helps with SAQ A-EP Compliance
SAQ A-EP Compliance — Frequently Asked Questions
Related PCI DSS Resources
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