PCI DSS Merchant Levels
All merchants who process their customers’ cardholder data during a transaction need to ensure they are PCI DSS compliant to protect both the business and the consumer from any potential data breaches. By putting your business through a PCI DSS audit, you can catch any security threats before they come to fruition and monitor your existing system to ensure data is being processed and protected correctly.

PCI DSS Merchant Levels
It’s important to know during this process that there are four different PCI DSS merchant levels, based on size and scale, that your business will fall into. The requirements and security controls are different for each level, so it’s important to know what applies to your business to remain compliant.
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How to find your level
- Your level is set by annual card transaction volume, across four bands.
- Requirements and security controls differ at each level.
- Confirm your level with your card processor or reporting tools.
- Verify each card brand’s thresholds match the industry-level requirements.
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What are the PCI DSS compliance levels for merchants?
Depending on the number of card transactions your business processes a year, you will fall into one of the following four categories:
| Merchant level | Annual card transactions | Validation |
|---|---|---|
| Level 1 | Over 6 million | Annual on-site assessment (QSA or officer-signed internal audit), quarterly ASV scan and Attestation of Compliance |
| Level 2 | 1 million to 6 million | Annual self-assessment questionnaire and quarterly external ASV scan |
| Level 3 | 20,000 to 1 million | Annual self-assessment questionnaire and quarterly external ASV scan |
| Level 4 | Fewer than 20,000 | Depends on the acquiring bank |
If you’re not sure which level you fall under, it’s worth checking with either your card processing service providers or by using reporting tools. You will also need to check that the levels for the credit card companies you use match up with the industry level requirements.
What are the PCI DSS merchant levels used for?
A business’ PCI DSS merchant levels determine the level of security validation required for a merchant to maintain PCI DSS compliance. The merchant level also determines how many assessments (including risk assessments and penetration testing) the business will need to do a year to keep threats at bay.
PCI DSS merchant Levels 1-3 need to report their PCI DSS compliance status directly to the banks they use. However, Level 4 merchants need to consult directly with their banks as they may be required to validate their compliance.
Additionally, Level 1 merchants need to submit a Level 1 On-site Assessment, which is an annual report on compliance completed by a Qualified Security Assessor (QSE), or an internal audit signed by one of the company’s officers. Level 1 merchants are also subject to a quarterly network scan by an Approved Scanning Vendor (ASV), and an Attestation of Compliance form.
Level 2 and Level 3 merchants are required to submit a self-assessment questionnaire annually. They will also need to have a quarterly external vulnerability scan by an ASV.
The requirements for Level 4 merchants completely depend on their acquiring bank.
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From the Hicomply team
Your merchant level sets the floor, not the ceiling. Even a Level 4 merchant handling a handful of transactions is better off treating validation as continuous rather than a once-a-year scramble. Keep your evidence, scans and questionnaires in one place so moving up a level never means starting your compliance work from scratch — our platform tour shows how.
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Compliance as you work with Hicomply
The complex nature of PCI DSS compliance requirements can seem overwhelming at times – especially when determining your PCI DSS merchant levels. At Hicomply, we’ve aimed to streamline the process by creating a custom ISMS dashboard for businesses who want to keep all their security framework in one place.
To find out more about how Hicomply can help your business make the PCI DSS compliance a breeze, request a demo with our team today.
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