PCI DSS Compliance for SaaS (2026 Guide)

The global SaaS market size of $408.21 billion in 2025 is forecasted to reach $1,367.68 billion by 2035. The increase in subscription-based cloud services is a major driver of this expansion. 

With this rise, new payment methods are evolving as well. Card-not-present (CNP) is one such method, where purchases can be made without the presence of a physical credit or debit card. Another is subscription billing. Here, a customer's card is automatically charged on a periodic basis without them having to manually make a payment each time.

The methods are pretty convenient, but they come with a higher risk of fraud and data breaches compared to traditional in-person payments. It’s because of these security risks that compliance with PCI DSS becomes critical. 

A common misconception may arise that using platforms like Stripe for processing payments makes you automatically compliant, but that’s hardly the case. 

Every organization that handles payment data, whether directly or indirectly, must comply with PCI DSS. We explore why this is the case in this article.

Payment Card Industry Data Security Standard, or PCI DSS, establishes policies and standards for organizations that store, process, or transmit payment or cardholder data. It aims to protect consumer data from fraud and data breaches.

PCI DSS was established in 2006 by the Payment Card Industry Security Standards Council (PCI SSC). PCI SSC is a global forum formed by five major card networks: Visa, Mastercard, JCB, American Express, and Discover. It primarily focuses on developing security standards and assisting with their implementation.

PCI SSC published the latest PCI DSS 4.0.1 in 2024, which brings more clarity to the previous PCI DSS 4.0 version, while maintaining the same requirements. It was developed with evolving security needs and cyber threats in mind, giving organizations more flexibility in applying PCI standards, while requiring them to address all security vulnerabilities, not just those defined by PCI SSC.

Every SaaS that handles payment and card details, whether on its own or via a third-party processor, is mandated to comply with PCI DSS. It is required if your SaaS: 

• Processes, stores, or transmits card data.
• Handles card data through payment gateways, processors, or applications that collect client payment data (PayPal).

Dealing with card and payment data of clients puts your SaaS at risk of cyber fraud and theft. Compliance with PCI DSS safeguards it against such threats and the penalties associated with these breaches.

For a better understanding of PCI for SaaS, have a look at this table.

PCI DSS has 12 requirements divided into its 6 goals to protect cardholder data from theft or fraud. These are:

1. Build and maintain a secure network

A strong firewall has to be installed and maintained to secure the organization’s network against suspicious activity. Default passwords that come pre-set on vendor-supplied systems must never be used, as they can be easily accessed by cybercriminals and hackers.

2. Protect cardholder data

Cardholder data must be protected by storing only the minimum necessary data and using encryption. All SaaS should not store sensitive authentication data (SAD). They must also strongly encrypt cardholder data when it is shared over open public networks. 

3. Maintain vulnerability management

Systems should be protected using endpoint security tools, along with API-specific protections like authentication controls, rate limiting, and web application firewalls (WAFs) to prevent abuse and unauthorized access. In addition, the DevOps pipeline should be assessed for any new threats and protected with updated security patches.

4. Implement strong access controls

Access to cardholder data should be limited to employees who require it for work, and they should be issued unique IDs for it. Along with this, the data should be protected physically by using document shredders and limiting document duplication.

5. Monitor and test networks

Access to network resources and cardholder data has to be regularly monitored by maintaining activity logs. Infrastructure-as-code audits should be conducted periodically to assess for vulnerabilities and enhance security with appropriate measures. 

6. Maintain security policy

Organizations should develop and maintain information security policies. They should be reinforced through periodic employee training.

PCI DSS specifies a compliance level based on the annual volume of transactions handled by a service provider or a merchant. Service providers have 2 PCI levels, while merchants have 4 PCI levels.

If your SaaS directly interacts with and accepts payment from cardholders, you fall into the category of a merchant. On the other hand, if your SaaS facilitates or secures the payment process for merchants, you are a service provider.

Merchants

Merchants have 4 PCI levels based on their annual transactions, and their compliance requirements can vary based on that.

Service provider

Service providers have 2 PCI levels, and their compliance requirements vary based on that.

The shared responsibility mode refers to the division of security tasks between the cloud service provider and its customers. PCI compliance is achieved only when both fulfill their respective responsibilities.

Cloud service providers like AWS, Microsoft Azure, and GCP are responsible for securing the cloud infrastructure, including hardware, software, networking equipment, and data centers. 

SaaS providers using cloud services are responsible for securing their applications and data with strong code and encryption, using Identity and Access Management (IAM) tools for securing resources, configuring firewalls & networks, and monitoring and logging all activity within their environment. 

To achieve Saas PCI compliance, follow the given steps: 

1. Determine scope

Identify all areas in your system and network that process, store, or transmit cardholder data. This is the starting point, everything within this scope will need to meet PCI DSS requirements.

2. Reduce cardholder data environment

The smaller your cardholder data environment, the easier compliance becomes. Segregate and segment the networks and systems that process cardholder data using Virtual LANs, firewalls and Access Control Lists (ACL), thus restricting access and traffic to them.

3. Implement tokenization

Tokenization replaces payment information, such as name, card number, SAD, etc., with a randomly generated, unique token, while the actual data is stored in the payment service providers’ token vault. This is especially useful for subscription-based SaaS, where recurring payments are processed using tokens instead of raw card data, while the cardholder data is never revealed to them. 

4. Encrypt data

To prevent data exposure or theft, use strong encryption for payment data when processing or transmitting it, especially when done over open public networks.

5. Conduct vulnerability scans

Conduct internal and external network vulnerability scans quarterly or after making any changes to the network. This can be done using an automated web scanner from ASV organizations that identify areas of weakness and give suggestions for security patches.

6. Perform penetration testing

Penetration tests are performed annually or when changes are made in the network. This is done manually and helps identify ways attackers can exploit vulnerabilities and compromise the organization’s security systems and networks.

7. Complete SAQ or engage a QSA

If your organization falls into levels 2-4, you can complete a Self-Assessment Questionnaire (SAQ) for PCI compliance. Merchants that use third-party sources for processing, storing and transmitting payment data complete SAQ A, A-EP, B, B-IP, C, C-VT or P2PE depending on their payment environment. 

Merchants that store, process, or transmit payment data on their own systems must complete SAQ D. Organizations in the level 1 category must engage a Qualified Security Assessor (QSA) to prepare their Report on Compliance (ROC). 

8. Obtain Attestation of Compliance

Attestation of Compliance (AOC) serves as proof of compliance with PCI DSS 12 requirements. It is obtained on completing SAQ or ROC and is either self-attested or attested by a QSA.

PCI DSS compliance is important for all SaaS companies to operate, but it comes with various costs beyond simply setting up your platform. A simple breakdown of approximate costs for PCI compliance looks like this: 

• Annual SAQ audit: $5000 to $200,000 based on PCI level
• Vulnerability scans: Around $200 per IP annually 
• Penetration test: $3000 to $30,000, depending on organization size

Setting up firewalls, anti-viruses, and compliance automation tools adds to costs and drives operational expenses soaring high. A wide range of PCI scope means higher compliance costs. It would be beneficial to explore methods to reduce your PCI scope and save on these costs.

You can adopt the following methods to lower your SaaS organization’s PCI scope: 

1. Hosted payment pages

A hosted payment page redirects your customer to your payment processor's page when making a payment. This places the security burden on the payment processor, as the payment information does not enter your servers. You will only need to complete SAQ A, which is the simplest form of PCI assessment.

2. Client-side tokenization

Rather than storing actual payment details, store them as tokens for business purposes in your systems. Even in the case of cyber-attacks, tokens provide no tangible information about cardholder data. This minimizes the systems that fall under the PCI DSS Scope.

3. Avoid storing PAN data

Storing Primary Account Number (PAN) or Sensitive Authentication Data (SAD) should be avoided. If it is needed for business operations, it should be deleted after those operations are complete. This lessens the burden of cybersecurity measures.

4. Use iframe checkout

An iframe checkout embeds the payment processor's window on your page. Since the payment is being made on the payment processor’s server, you only have to configure the iframe, which significantly reduces your compliance costs.

5. Outsource billing infrastructure

By outsourcing billing infrastructure to third-party payment processors, a business’s PCI compliance shrinks as they are no longer the ones processing, storing or transmitting payment information of clients. Businesses engaging in cross-border payments can utilize Xflow for receiving payments to reduce their PCI exposure and stay compliant. 

Xflow comes with critical certifications like ISO 27001 and SOC 2, which are industry gold standards for information security. These certifications support the highest level of security, lowering the risk of data breaches.

Businesses that think they are in compliance with PCI can still end up making mistakes in securing their network, which can result in huge penalties and loss of customer trust. Some common mistakes observed in PCI compliance are:

1. Assuming gateway=compliance

While using third-party gateways for payment processing can reduce your compliance requirements, you still need to ensure the window is properly configured to prevent sensitive payment data from entering your company’s network. 

2. Ignoring logging requirements

Users who can access systems containing cardholder data must be limited, and their activities logged.  Ignoring logging requirements invites an insider threat that may misuse the payment information.

3. Failing quarterly scans

The changing pace of cyber threats makes it necessary to conduct vulnerability scans promptly. Failing to perform quarterly scans leaves your system exposed to exploitation from attackers.

4. Not segmenting environments

Segmenting your network using VLANs and firewalls isolates your cardholder data environment. This also limits who has access to this data. By not segmenting CDE, your entire network must be configured, making PCI compliance difficult.

5. Weak access controls

Only certain users with a unique ID should have access to cardholder data. Weak access controls make it easy for malicious actors to breach systems containing payment information. This is a clear violation of PCI DSS requirements and can result in huge penalties for your company.

To establish your SaaS as safe and secure to customers, there are other compliance frameworks apart from PCI DSS that you may need to adhere to, depending on where your customers are and what data you handle. Here is a quick comparison:

Xflow is a secure payment solution for all your cross-border settlements. It helps your SaaS stay PCI compliant with:

• Tokenized payment flows to keep your customer payment data safe and reduce your burden of implementing specialized security measures.
• Encrypted infrastructure for secure payment processing and settlement.
• Reduced compliance burden with SOC 2 and ISO 27001 certifications, which deliver the promise of secure systems and controls protecting information assets.
• Transparent audit documentation to speed up SAQ completion.

The benefits of Xflow don’t stop here. You can get settlements within 24 hours with the lowest FX rates. It also helps you stay compliant with RBI and FEMA guidelines by generating eFIRA. And it easily integrates with your third-party tools, making cross-border payment settlements easier.

If your SaaS handles payments, PCI DSS compliance is not something you can put off or work around. It’s a basic requirement to protect your customers and your business.

The good news is that compliance doesn't have to be overwhelming. You can reduce PCI scope through tokenization, hosted payment pages, or outsourcing billing infrastructure. Pairing that with automated security tools and the right payment infrastructure partners makes the whole process far more manageable.

If cross-border payments are a regular part of your business, Xflow is worth considering. It offers fast, secure international payment settlement at transparent, cost-effective pricing, with built-in tokenization, strong encryption, and compliance automation already taken care of.

To learn more, head over to Xflow’s website now!