FAQ #1324 Diff
What changes are PFI companies allowed to make to the PFI Reporting Templates?
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PCI SSC recognizes the need for personalization changes by the PFI to the PFI Reporting Templates, such as the addition of company logos, but requirethat there may be a need for PFIs to personalize the PFI Report Templates, such as adding a company logo or add rows for more detail. However, such changes to be verymust be limited and per the following guidance:
Personalization, such as inclusion of corporate logosand the like, must be limited to the title page of the document.
The format and content of the PFIReportingReport Templates must remain unchangedbe maintained with no deletions . Generally, changes to the format must be limited to the addition of rows as needed. This includes a requirement not to change the order of sections.
Again, nothing must be removed, including sections or requirements— the only permitted format change is the addition of rows as needed to facilitate complete and accurate responses. Changes to the order or content of sections, reporting instructions, guidance notes or other static text are not permitted.
Removal or omission of any static text, including section headers, guidance notes and instructions is prohibited. Where a section or requirement is determined to be not applicable. Those, those sections and/or requirements must remain in the completed PFI Reporting Templatereports with theany "not applicable" resultresults documented instead.
The addition of content, such as legal verbiage or additional reporting, is allowed in a limited manner; such additional content/reporting sections should be treated as addendum sectionsand not added to the PFI Reporting Template format before the appendicesthat are attached at the end of the PFI Report following the appendices. If a PFI would like to include more information than they feel can be included in the allotted space, they must put an addendum reference in the report at the location where expansion is needed, and identify where (in the addendum) that data can be found. Additions of addendum content should be carefully considered, as acceptingthe affected payment brand(s) have the right to not acceptreject such changes.
PCI SSC would request that PFIs ensure there is reasonable distinction that the content has been added by the PFI and is not part of the published PCI SSC document. Where a PFI would like to include more information than they feel they can include in the allotted space, they must put an appendix reference in the PFI Reporting Template at the location that expansion is needed and identify where in the appendices that data can be foundPFIs must also ensure that any content added by the PFI is visually evident and discernable from the original PCI SSC Report Template. Any additional reporting must not be a duplication ofduplicated information, andbut rather, must be additional details that add value to the above required sections.
PCI SSC recognizes that this approach is strict and that other Reporting Templates such as for PCI DSS and PA-DSS do not currently have the same limitations at the time of this FAQ. The determination to set such strict boundaries for PFI reporting was made with feedback from the Payment Card brands and similar receiving entities who note that over personalization by PFIs needlessly complicates the review process in many cases, which the PFI Reporting Templates were intended to simplify.
Below is an example of how addendum content could be addressed within the PFI Reporting Template where the PFI feels more detail is warranted, but the reporting format doesn't facilitate that reporting data:context or clarification to the responses provided in the main body of the report.
Personalization, such as inclusion of corporate logos
The format and content of the PFI
Again, nothing must be removed, including sections or requirements
Removal or omission of any static text, including section headers, guidance notes and instructions is prohibited. Where a section or requirement is determined to be not applicable
The addition of content, such as legal verbiage or additional reporting, is allowed in a limited manner; such additional content/reporting sections should be treated as addendum sections
PCI SSC recognizes that this approach is strict and that other Reporting Templates such as for PCI DSS and PA-DSS do not currently have the same limitations at the time of this FAQ. The determination to set such strict boundaries for PFI reporting was made with feedback from the Payment Card brands and similar receiving entities who note that over personalization by PFIs needlessly complicates the review process in many cases, which the PFI Reporting Templates were intended to simplify.
Below is an example of how addendum content could be addressed within the PFI Reporting Template where the PFI feels more detail is warranted, but the reporting format doesn't facilitate that reporting data:
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