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How to Determine Merchant Level and Validation Requirements

All merchants that store, process, or transmit cardholder data must be PCI compliant. Each merchant that is categorized as a Level 1, Level 2 or Level 3 merchant is required to report its compliance status directly to its acquiring bank.

Determining merchant level often raises questions for many companies. To accurately determine merchant levels, MasterCard recommends merchants first contacting their acquiring bank. With assistance from their acquiring bank, merchants can then complete the following steps:

  • Determine merchant level using MasterCard transaction volume from the most recent 52-week period
  • Confirm necessary PCI validation requirements (Onsite or Self-Assessments, Self-Assessment Questionnaire, External Vulnerability Scan)
  • Engage an approved vendor, as appropriate, and follow the validation procedures
  • Once a merchant had been verified as compliant, the merchant must submit the validation requirements to its acquiring bank, which then will report the merchant’s compliance status to MasterCard.

SDP Merchant Levels

Category Criteria Requirements Compliance Date
Level 1
  • Any merchant that has suffered a hack or an attack that resulted in an account data compromise
  • Any merchant having more than six million total combined MasterCard and Maestro transactions annually
  • Any merchant meeting the Level 1 criteria of Visa
  • Any merchant that MasterCard, in its sole discretion, determines should meet the Level 1 merchant requirements to minimize risk to the system
  • Annual Onsite Assessment1
  • Quarterly Network Scan conducted by an ASV2
  • 30 June 20123
Level 2
  • Any merchant with more than one million but less than or equal to six million total combined MasterCard and Maestro transactions annually
  • Any merchant meeting the Level 2 criteria of Visa
  • Annual Self-Assessment4
  • Onsite Assessment at Merchant Discretion4
  • Quarterly Network Scan conducted by an ASV2
  • 30 June 20124
Level 3
  • Any merchant with more than 20,000 combined MasterCard and Maestro e-commerce transactions annually but less than or equal to one million total combined MasterCard and Maestro e-commerce transactions annually
  • Any merchant meeting the Level 3 criteria of Visa
  • Annual Self-Assessment
  • Quarterly Network Scan conducted by an ASV2
  • 30 June 2005
Level 4
  • All other merchants5
  • Annual Self-Assessment
  • Quarterly Network Scan conducted by an ASV2
  • Consult Acquirer
  1. Effective 30 June 2012, Level 1 merchants that choose to conduct an annual onsite assessment using an internal auditor must ensure that primary internal auditor staff engaged in validating PCI DSS compliance attend PCI SSC ISA Training and pass the associated accreditation program annually in order to continue to use internal auditors.
  2. Quarterly network scans must be conducted by a PCI SSC Approved Scanning Vendor (ASV).
  3. Initial compliance date of June, 2005 for Level 1 merchants has now passed. The 30 June 2012 deadline is for PCI SSC ISA training and certification only and is for those merchants that choose to conduct an annual onsite assessment using an internal auditor.
  4. Effective 30 June 2012, Level 2 merchants that choose to complete an annual self-assessment questionnaire must ensure that staff engaged in the self-assessment attend PCI SSC ISA Training and pass the associated accreditation program annually in order to continue the option of self-assessment for compliance validation. Alternatively, Level 2 merchants may, at their own discretion, complete an annual onsite assessment conducted by a PCI SSC approved Qualified Security Assessor (QSA) rather than complete an annual self-assessment questionnaire.
  5. Level 4 merchants are required to comply with the PCI DSS. Level 4 merchants should consult their acquirer to determine if compliance validation is also required.



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