Last Updated on September 24, 2025 by Narendra Sahoo
The Payment Card Industry Data Security Standard (PCI DSS) aims to prevent financial fraud by securing payment card data. Any company that handles this data must implement security measures to ward off unauthorized access.In this process, you’ll come across key terms like PCI SAQ (Self-Assessment Questionnaire), AOC (Attestation of Compliance), and PCI ROC (Report on Compliance). Let’s focus on the ROC for now.
It assesses a company’s security controls that protect cardholder data, providing a detailed analysis of compliance with the 12 requirements of the PCI DSS standard and pointing out any identified shortcomings. Every year, organizations must show that they comply with PCI DSS. However, not all merchants or service providers need a ROC. It’s crucial to understand these requirements and the complexities of data storage and transmission for compliance.
Difference Between PCI ROC and AOC: What Sets Them Apart?
| Factor | PCI RoC | PCI AOC |
|---|---|---|
| Purpose | Detailed report prepared by a QSA | Short summary/attestation after the RoC |
| Audience | Banks, card brands, regulators | Acquiring banks, partners |
| Level Required | Level 1 merchants/service providers | All levels (based on compliance validation) |
| Detail | 200+ page technical audit | 1–2 page declaration |
| Validity | 12 months | 12 months |
Who Needs a PCI RoC?
In my two decades of working with global enterprises, one of the most common misconceptions I see is that every business needs a PCI RoC. That’s not the case. A RoC is mandatory primarily for Level 1 merchants processing more than six million card transactions annually, and for service providers handling sensitive cardholder data on behalf of others. It’s also often required after a data breach or at the request of payment brands and acquirers.
For smaller organizations, a Self-Assessment Questionnaire (SAQ) may be enough, but the moment transaction volumes grow or regulators demand deeper assurance, a RoC becomes unavoidable.
How to Get a PCI RoC (Step-by-Step Process)
Over the years, I’ve guided many clients through the RoC journey. While every business is different, the process typically follows these key stages:
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Scoping the Environment – Pinpointing where cardholder data resides and mapping how it flows across systems. This is critical, and mistakes here can triple your audit headaches later.
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Gap Assessment – A dry run of the audit, where weaknesses and missing controls are identified. It’s far less painful to find issues here than during the official audit.
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Remediation Work – Closing security gaps, patching vulnerabilities, tightening access, and updating outdated policies.
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The QSA Audit – Your Qualified Security Assessor reviews evidence, interviews staff, and validates controls.
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Final RoC & AoC – The QSA prepares the Report on Compliance, and you submit the Attestation of Compliance to your acquiring bank or card brand.
For most organizations, this takes anywhere between three to six months, though I’ve seen large, complex environments stretch closer to a year.
PCI RoC Checklist: What You’ll Need Ready
When I prepare clients for a RoC, I always insist on a readiness pack. Without it, audits stall. At minimum, you’ll need:
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Updated network diagrams showing cardholder data flows.
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Documented security policies (access control, encryption, incident response).
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Recent ASV scan results and penetration test reports.
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System configuration screenshots and audit logs.
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Evidence of security awareness training for employees.
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Proof of monitoring and remediation activities.
This checklist not only keeps the audit on track but also signals to your assessor that you take compliance seriously.
Common Pitfalls During a PCI RoC (and How to Avoid Them)
I’ve lost count of how many times I’ve seen projects stumble on the same avoidable issues:
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Scoping Mistakes – Overlooking even a single system that touches card data can invalidate an entire audit.
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Weak Documentation – Missing or outdated policies slow everything down.
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Failed ASV Scans – Unpatched servers are one of the biggest audit killers.
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Poor Network Segmentation – Mixing cardholder systems with general IT infrastructure increases scope and risk.
The fix? Conduct a thorough gap assessment months before the audit. It gives you breathing room to remediate issues instead of scrambling when the QSA is on-site.
FAQ
Q1. Who needs a PCI RoC?
Level 1 merchants and large service providers, or any organization directed by card brands or acquiring banks.
Q2. How long does a PCI RoC take?
On average, three to six months, though larger environments may take closer to a year.
Q3. What is the difference between PCI RoC and AoC?
The RoC is the detailed technical audit; the AoC is the brief compliance attestation derived from it.
Q4. Can a company perform a PCI RoC internally?
No. Only a Qualified Security Assessor (QSA) is authorized to conduct and issue a RoC.
Q5. How long is a PCI RoC valid?
One year from the date of issue. After that, a reassessment is required.
Q6. What happens if an organization fails a PCI RoC?
You’ll need to remediate deficiencies and undergo re-validation. Non-compliance may also trigger fines or reputational risk.
Conclusion:
Is a PCI Report on Compliance the right fit for your organization? This is a question only you can answer, considering your unique circumstances. Opting for a ROC, even if not mandatory, reflects your commitment to compliance and security.
Lets us help you
Need help navigating PCI DSS v4.0? Since, we have been active in the PCI DSS space since 2008 and even certify payment brand. Our PCI DSS services provide assurance on card security controls, with offerings for both product platform and backend services attestation.
Having a dedicated team of auditors and a separate team for consulting/advisory assignments to even help our esteemed clients to define processes and achieve compliance & completed multiple PCI DSS 4.0 certifications too right from scoping to Readiness Assessment, Advisory and Final Certification we stay ahead.
We are vendor neutral and have a strict no-outsourcing policy. Another key point is also that, we can also assist you with the technical assessments needed for PCI DSS Compliance – Vulnerability Assessment, Penetration Testing, Network Segmentation Testing, Network Architecture Review, Firewall Assessment, Secure Configuration Assessment, Web and Mobile Application Security Assessment, and Secure Code Review.
Narendra Sahoo (PCI QPA, PCI QSA, PCI SSF ASSESSOR, CISSP, CISA, CRISC, 27001 LA) is the Founder and Director of VISTA InfoSec, a global Information Security Consulting firm, based in the US, Singapore & India. Mr. Sahoo holds more than 25 years of experience in the IT Industry, with expertise in Information Risk Consulting, Assessment, & Compliance services. VISTA InfoSec specializes in Information Security audit, consulting and certification services which include GDPR, HIPAA, CCPA, NESA, MAS-TRM, PCI DSS Compliance & Audit, PCI PIN, SOC2 Compliance & Audit, PDPA, PDPB to name a few. The company has for years (since 2004) worked with organizations across the globe to address the Regulatory and Information Security challenges in their industry. VISTA InfoSec has been instrumental in helping top multinational companies achieve compliance and secure their IT infrastructure.
