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SAQ SPoC: Software-Based PIN Entry on COTS Devices

Eligibility criteria and requirements for SAQ SPoC — new in PCI DSS v4.0, for merchants using a PCI-listed SCRP card reader paired with an everyday phone or tablet.

SAQ SPoC is new for PCI DSS v4.0. It covers merchants taking card-present payments using a PCI-listed Secure Card Reader-PIN (SCRP) device paired with a commercial off-the-shelf (COTS) phone or tablet — the kind of setup you'd see with a mobile point-of-sale app on a regular smartphone.

Eligibility criteria — a merchant needs all of these to be true

  • All payment processing happens through a card-present channel only.

  • All cardholder data entry goes through an SCRP that's part of a validated, PCI SSC-listed SPoC solution.

  • The only systems in the SPoC environment touching account data are part of that validated solution.

  • The merchant doesn't otherwise receive, transmit, or store account data electronically.

  • This payment channel isn't connected to any other system or network in the merchant's environment.

  • Any retained data is paper only.

  • The merchant has implemented every control in the SPoC user guide from the solution provider.

Important exclusions

SPoC explicitly does not apply to unattended card-present channels (kiosks, self-checkout), mail/telephone order, or e-commerce. It's attended, in-person transactions only. Merchants using a non-PTS-listed magnetic stripe reader also don't qualify — though a PTS-listed SCRP with magstripe capability is fine. As with P2PE, check for expired SPoC-listed solutions with the acquirer.

What this looks like in practice

A retail employee, delivery driver, or market vendor using a smartphone or tablet with a paired card reader to take chip, contactless, or magstripe payments — mobile pop-up shops are a classic example.

Requirement scope

Very light — 4 requirement categories (Requirements 3, 8, 9, 12): protect stored account data, user authentication, physical access, and security policy.

ASV scanning

No — Requirement 11 doesn't apply.

Not a fit?

MOTO or e-commerce merchants can't use SPoC regardless of their card reader — look at P2PE (works for both card-present and MOTO) or the appropriate e-commerce SAQ instead. Unattended/self-checkout setups need SAQ D.

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