Comment Re:PCI-DSS (Score 1) 217
Self-assessment is the method used by the vast majority of small businesses, and they're often not even required to do even minimal work to get started. The acquiring bank will just set them up an account and start the ball rolling after Farmer Bob buys a cheap swipe terminal off eBay for the weekend Farmer's market and signs a couple papers. For those organizations that aren't self-assessing, they get to deal with the fact that QSAs often can't even agree on what some requirements mean in principle, let alone when applied to their specific circumstances. Show three different QSAs the same architecture and documentation, get three different reports. That ROC? That's good for toilet paper by the time the QSA pulls out of the parking lot. Don't believe me? Have a data breach and watch Visa roll in with auditors who won't leave until they find a reason to fail your compliance. That's just how the game is played.
All that said, people just declaring that they are PCI DSS compliant is actually exactly what happens. You tell the acquiring bank that you're PCI compliant (either via SAQ or QSA/ROC). If you've met certain levels of activity, the acquiring bank may pass along some paperwork regarding your audits to certain payment brands who require it. They then effectively state that your paperwork appears to be in order and begin processing your credit card transactions. At no point do they declare you PCI DSS compliant and they will most certainly toss your ass to the wolves the second there's a whiff of trouble. And even if they did say you were compliant at filing time, any QSA will tell you that any minor change, lapse, or mistake can completely alter the state of your compliance. From the PCI SSC website: "There are three steps for adhering to the PCI DSS – which is not a single event, but a continuous, ongoing process."
In other words, yesterday you might have been compliant, and tomorrow you might be compliant, but today (always of course the day of the breach), you're non-compliant.