PCI DSS vs SOC 2
Choose PCI DSS (Payment Card Industry Data Security Standard) validation when you store, process, or transmit card data and a payment brand or acquirer requires it. Choose SOC 2 when customers or partner banks ask for a certified public accountant (CPA) firm's report on your controls. A card-handling service provider that sells to businesses can need both.
PCI DSS and SOC 2 compared
The table compares PCI DSS v4.0.1, which covers cardholder data and sensitive authentication data, with a SOC 2 examination, using the PCI DSS v4.0.1 Requirements and Testing Procedures (June 2024; the PCI SSC PDF returned HTTP 403, so the text was read on 2026-09-22 from a published copy), the AICPA SOC 2 guide, October 2022 edition, the 2018 SOC 2 Description Criteria, the 2017 Trust Services Criteria (revised points of focus, 2022), AICPA notes on SOC engagements (December 2023), and the Visa Europe PCI DSS compliance page, all other sources checked on 2026-09-22.
| Factor | PCI DSS v4.0.1 | SOC 2 |
|---|---|---|
| Who requires it | Payment brands and acquirers decide whether an entity must comply with and validate PCI DSS v4.0.1 | Customers and business partners request a SOC 2 report from the service organisation, according to the AICPA SOC 2 guide |
| Who it applies to | PCI DSS v4.0.1 applies to entities that store, process, or transmit cardholder data or sensitive authentication data, or could impact its security | A SOC 2 examination covers a service organisation that engages a service auditor for its system |
| Scope | PCI DSS v4.0.1 scope is the cardholder data environment (CDE) plus system components, people, and processes that could impact its security | SOC 2 scope is the system that management describes under the AICPA 2018 Description Criteria (DC 200) |
| Criteria | PCI DSS v4.0.1 has 12 principal requirements, each with defined testing procedures | SOC 2 uses the AICPA 2017 Trust Services Criteria for security, plus optional availability, processing integrity, confidentiality, and privacy |
| Who assesses | PCI DSS v4.0.1 is assessed by a Qualified Security Assessor (QSA), an Internal Security Assessor (ISA), or the entity itself through a Self-Assessment Questionnaire (SAQ) | A SOC 2 examination is performed by a certified public accountant (CPA) firm in public practice |
| Output | PCI DSS v4.0.1 validation produces a Report on Compliance (ROC) or an SAQ, plus an Attestation of Compliance (AOC) on the official PCI SSC form | A SOC 2 examination produces a SOC 2 type 1 or type 2 report with the service auditor's opinion |
| Scope confirmation | PCI DSS v4.0.1 12.5.2 requires scope confirmation at least once every 12 months and upon significant change; 12.5.2.1 sets every six months for service providers | A SOC 2 type 2 report covers the described system throughout one specified period |
| Validation cadence | Visa Europe requires issuers and acquirers to ensure that Level 1 and Level 2 service providers demonstrate PCI DSS compliance at Third-Party Agent registration and every 12 months thereafter | A new SOC 2 type 2 report needs a new examination for the next period |
| Customer reuse | PCI DSS v4.0.1 expects a third-party service provider (TPSP) with an AOC to provide the AOC to customers upon request | A SOC 2 report goes to the customers and partners that request it from the service organisation |
The requirement-by-requirement test scope is on the PCI DSS testing requirements page, and the criterion-by-criterion scope is on the SOC 2 testing requirements page.
When to choose PCI DSS
- Your systems store, process, or transmit card data, or could impact its security. PCI DSS v4.0.1 section 2 lists merchants, processors, acquirers, issuers, and other service providers, and whether each must validate "is at the discretion of those organizations that manage compliance programs (such as payment brands and acquirers)".
- Your transaction volume puts you in a brand level that names the validation form. On Visa's validation levels page for Latin America and the Caribbean (checked on 2026-09-22), a service provider that "stores, processes and/or transmits over 300,000 transactions per year" is Level 1 and validates with an annual ROC by a QSA. Visa Europe states that "Level 2 service providers must submit a signed self-assessment questionnaire (SAQ-D) form or an AOC including QSA signature." Visa Europe tells merchant banks and merchants to verify the reporting requirements of other card brands too.
- Merchants rely on your service for their own assessment. PCI DSS v4.0.1 section 4 expects a TPSP with an AOC to provide the AOC to customers upon request, and customers may request relevant sections of the ROC, redacted to protect confidential information.
- You plan a customized approach for a requirement. PCI DSS v4.0.1 Appendix D states that use of the customized approach must be documented by a QSA or ISA, and entities that complete an SAQ are not eligible to use it.
The PCI DSS assessment preparation scenario sets out the sequence and timeline before an assessor arrives.
When to choose SOC 2
- A customer contract or partner bank questionnaire names a SOC 2 report. The AICPA SOC 2 guide states that customers and business partners often request a SOC 2 report. An AOC answers a different question, because it covers only the PCI DSS scope around account data.
- Your product never touches card data and cannot impact its security. PCI DSS v4.0.1 section 2 ties applicability to cardholder data and sensitive authentication data, so a ledger, payroll, or lending platform without card flows has no PCI DSS scope to validate.
- Buyers ask about controls beyond card data. The AICPA SOC 2 guide covers availability, processing integrity, confidentiality, and privacy alongside security, so a SOC 2 report can include payout, invoice, or ledger processing that PCI DSS does not address.
- You need a first report before an operating period has passed. The AICPA states that for a SOC 2 type 1 report "the service auditor is evaluating controls as of a specific date", and a SOC 2 type 2 report can follow once evidence covers a full period.
The bank vendor due diligence scenario covers the case where a partner bank asks for a SOC 2 report. Teams choosing between SOC 2 and a certificate can read the SOC 2 and ISO 27001 comparison.
Cost and timeline factors
We give no prices, because the QSA or the CPA firm sets its own fees.
PCI DSS factors:
- CDE size and segmentation. PCI DSS v4.0.1 section 4 states that segmentation is not a PCI DSS requirement but is strongly recommended as a method that may reduce the scope and the cost of the assessment. Without adequate segmentation, the entire network is in scope.
- Validation form. A ROC documents an assessment by a QSA or ISA, while an SAQ documents the entity's own self-assessment. The payment brand or acquirer sets which form applies.
- Recurring tests. PCI DSS v4.0.1 11.3.2 requires external scans by an Approved Scanning Vendor (ASV) at least once every three months, and 11.4.2 and 11.4.3 require internal and external penetration tests at least once every 12 months and after any significant infrastructure or application upgrade or change.
- Open items at assessment time. PCI DSS v4.0.1 section 12 states that requirements are not considered in place if controls are not yet implemented or are scheduled to be completed at a future date, so remediation and reassessment come before the AOC.
SOC 2 factors:
- Report type. A SOC 2 type 2 report needs evidence for the whole period that it covers, while a type 1 report needs evidence as of one date.
- Categories in scope. Each category added to security brings its own criteria series: availability, processing integrity, confidentiality, or privacy.
- Breadth of the system description. In our reading, every application and API that the description lists is part of the examined system, so test evidence has to cover each one.
Factors for both: our practice is to reconcile the PCI DSS data-flow diagrams from requirement 1.2.4 with the SOC 2 system description, so one penetration test scope covers both. The audit evidence testing service delivers the requirement-to-test traceability matrix and a test evidence pack per audit scope, and the security testing service delivers the penetration test report that both assessments request.
Questions
Is PCI DSS a certification?
What is a PCI ROC?
How long is a SOC 2 report valid?
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