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PCI DSS guide

Taking Card Payments Over the Phone: PCI DSS Rules for Small Businesses

Updated

An independent guide for small businesses and sole traders, written by a PCI SSC-approved QSA company: the ways to take card payments by phone, the PCI DSS questionnaire each one leads to, and the habits that get businesses into trouble.

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  • Written by a PCI SSC-approved QSA company
  • Each phone payment method mapped to its SAQ
  • A one-page checklist for small teams

The short answer

Yes. Taking debit or credit card payments over the phone is legal once your payment provider has enabled telephone (MOTO) payments. Key the details straight into a virtual terminal or card machine during the call, or send the customer a payment link. Never write down or record the card security code, and never take card numbers by email.

On this page
  1. How do you take card (credit or debit) payments over the phone?
  2. Which PCI SAQ does each phone payment method lead to?
  3. What must you never do when taking card payments by phone?
  4. What UK regulations apply to taking card payments over the phone?
  5. What is the safest way to take card payments by phone?
  6. Can staff take phone payments from home?
  7. Want to take card payments on your phone instead?
  8. Checklist for taking card payments over the phone
  9. Do you still need to complete an SAQ?
  10. Why Sovereign Secure
  11. Next step

Taking card payments over the phone is legal and routine, as long as your payment provider has switched on telephone payments and you handle the card details safely. The four common methods are a virtual terminal in your web browser, keyed entry on your card machine, a payment link the customer completes themselves, and keypad entry (DTMF) or an automated payment line for busier teams. Whichever you choose, the rules that matter most are simple: never keep the card security code, never take card numbers by email, and keep card details out of notes, spreadsheets and recordings.

This guide, from a PCI SSC-approved Qualified Security Assessor (QSA) company, adds what payment providers’ how-to guides leave out: the PCI DSS questionnaire each method leads to, and what makes you ineligible for the short ones. It is written for small businesses and sole traders; if you run a contact centre, read our guide to contact centre PCI compliance instead.

How do you take card (credit or debit) payments over the phone?

Ask your payment provider to enable telephone payments, often called MOTO (mail order, telephone order), then choose how the card details will reach the provider:

  1. Virtual terminal: you type the customer’s card details into a secure web page hosted by your provider, one payment at a time.
  2. Card machine keyed entry: you type the card number into your card machine while the customer is on the line, if your provider allows keyed transactions.
  3. Payment link: you send a link by text or email, and the customer enters their own card details on the provider’s hosted payment page.
  4. DTMF masking or a payment IVR: the customer types their card number on their phone keypad, and the tones are hidden from you and from any recording, or the call is passed to an automated payment line.

Every method ends the same way: the provider authorises the payment, and the customer’s receipt should never show the full card number.

Which PCI SAQ does each phone payment method lead to?

How you take phone payments decides which Self-Assessment Questionnaire (SAQ) you complete each year. The table shows the usual outcome; your acquirer has the final say, and you must meet every eligibility criterion in the SAQ itself.

Method How card data moves Usually leads to What makes you ineligible
Virtual terminal You key it into your provider’s web page SAQ C-VT A computer that is not isolated from your other systems, a card reader attached to it, or card numbers stored or received electronically
Card machine, keyed entry You key it into a standalone terminal SAQ B (dial-out terminal) or SAQ B-IP (standalone terminal on broadband, Wi-Fi or mobile data) A terminal that is not PCI PTS approved, is linked to a till, or connects through a phone, tablet or computer
Payment link The customer enters it on the provider’s hosted page SAQ A, for that channel You fill in the payment page yourself while the customer reads out their details
DTMF masking or payment IVR The customer keys it, and it bypasses you Often a much smaller scope; how small depends on where the masking happens and what the provider’s Attestation of Compliance covers Card data passing through, or recorded by, phone systems you control
Card numbers taken by email, or stored electronically for repeat orders Your systems hold it SAQ D Not a route to choose; change the process instead

If your card machines belong to a PCI-listed point-to-point encryption (P2PE) solution, ask your provider whether keyed telephone payments are covered by it; if so, SAQ P2PE may apply. If you take payments in more than one way, each channel may need its own SAQ, or your acquirer may ask for a single SAQ D. The full eligibility rules are in each questionnaire in the PCI SSC SAQ library.

What must you never do when taking card payments by phone?

These habits cause most problems, and several move you straight to SAQ D:

  • Never write down or keep the security code. Key it only into the payment screen. PCI DSS Requirement 3.3.1.2 forbids keeping it once the payment is authorised, on paper, in a system or in a recording.
  • Never take card numbers by email, text, web chat or social media messages. Requirement 4.2.2 requires strong cryptography whenever card numbers are sent by end-user messaging, and receiving them brings your mailbox, phone or chat tool into scope.
  • Never record card details in calls. If you record calls, pause the recording for the payment or use DTMF masking.
  • Never put card details into spreadsheets, CRM notes or booking systems. Use your provider’s tokens or saved-card feature for repeat customers instead.
  • Never repeat the full card number aloud where others can hear it.
  • Never use a personal phone or laptop to key payments.

Can I write down card details taken over the phone?

Avoid it, and never write down the security code at all. The safest habit is to key details straight into the virtual terminal or card machine while the customer is still on the line. If a card number does end up on paper, PCI DSS expects it to be physically secured (Requirement 9.4.1) and destroyed when no longer needed by cross-cut shredding, incineration or pulping (Requirement 9.4.6). A notepad by the phone or a stack of booking forms with card numbers on them will not pass.

What UK regulations apply to taking card payments over the phone?

No UK law bans taking card payments over the phone, and telephone payments are a standard card-not-present transaction type, so no special licence is needed beyond your merchant agreement. Four sets of rules apply:

Rule What it means for phone payments Source
PCI DSS, through your acquirer Not a law but a condition of your merchant agreement: your provider must enable telephone (MOTO) payments, and you validate PCI DSS compliance every year, usually with an SAQ Your merchant agreement; see our PCI compliance UK guide
UK GDPR Card details and call recordings are personal data: collect only what you need, keep it no longer than necessary and keep it secure UK GDPR, Article 5(1)(c), (e) and (f)
Payment Services Regulations 2017 and Strong Customer Authentication (SCA) SCA applies when the payer initiates an electronic payment. The FCA classes mail and telephone orders as payments initiated non-electronically, so SCA checks such as 3-D Secure are not used on payments you key in during a call Regulation 100; FCA Handbook SUP 16 Annex 27F
Consumer card surcharge ban You cannot add a fee for payment by a consumer (non-commercial) debit or credit card when both your provider and the customer’s card issuer are in the UK, whether you take the payment in person, online or by phone. The ban has applied since 13 January 2018 Consumer Rights (Payment Surcharges) Regulations 2012, regulation 6A

Because SCA does not apply, a phone payment made with a stolen card normally comes back to you as a chargeback. Use the address and security code checks your provider offers; our explainer on card-not-present fraud covers the risks. This table is a summary, not legal advice.

What is the safest way to take card payments by phone?

The safest method is the one where nobody in your business ever hears or sees the card number. In order of exposure:

Method Who in your business sees the card number Typical exposure
Payment link Nobody Lowest, and the customer can be authenticated with 3-D Secure because they pay online
DTMF masking or payment IVR Nobody, if set up correctly Low, but suits teams more than sole traders
Standalone card machine, keyed The person taking the call Moderate: depends on discipline on calls
Virtual terminal on a dedicated computer The person taking the call Moderate: the computer must be kept isolated and secure
Virtual terminal on a shared office PC The person taking the call, plus anything that compromises the PC High, and usually ineligible for SAQ C-VT

Larger teams weighing up masking should read our PCI IVR guide, which compares DTMF masking, IVR and pause-and-resume.

Can staff take phone payments from home?

Yes, but it is harder to do well. If a home worker hears or keys card details, their workspace and device are in scope, and SAQ C-VT’s requirement for an isolated computer is hard to meet with a laptop that also connects to your office network.

For most small businesses, payment links are the simplest answer for home workers: the worker never hears the card number, so their laptop and home broadband stay out of the payment flow. If home workers must key payments, use company-managed devices, require multi-factor authentication for any remote access into your systems (Requirement 8.4.3) and set clear rules: no one else present, no notes, no recordings.

Want to take card payments on your phone instead?

If the customer is with you rather than on a call, you can take card payments on your phone with a tap to pay app from your payment provider, which lets a phone or tablet accept contactless cards in person. The PCI SSC standard for these apps is PCI MPoC, and our guide to how you can take card payments on your phone explains what to check before you switch one on.

Checklist for taking card payments over the phone

Use this one-page check before you take your first phone payment, and again each year when you complete your SAQ:

  • Telephone (MOTO) payments enabled on your merchant account.
  • One method chosen for phone payments, and staff know it.
  • Card details keyed directly during the call, or sent by payment link.
  • The security code is never written down, typed into notes or recorded.
  • Card numbers are never accepted by email, text or chat.
  • No card numbers in spreadsheets, CRM notes or booking systems.
  • Any paper with card numbers locked away and cross-cut shredded after use.
  • Call recording paused or masked during payment, or not used.
  • Virtual terminal used only on a dedicated, up-to-date, isolated computer.
  • Only named, trained staff take payments, with their own log-ins.
  • Your provider’s Attestation of Compliance on file and checked every year.
  • The right SAQ completed and submitted to your acquirer every year.

Want to see where you stand? Our PCI compliance check asks a short set of questions and points you to next steps.

Do you still need to complete an SAQ?

Yes. Your acquirer expects you to validate PCI DSS compliance once a year, and for a small business that usually means an SAQ completed through an online portal run by or for the acquirer; our Worldpay PCI compliance guide shows how one acquirer’s programme works. Choosing the right phone payment method is the biggest lever on that workload: moving from keyed payments to payment links can turn a longer questionnaire into a much shorter one. Our guide to the cost of PCI compliance for a small business shows how your set-up affects the time and money involved. The PCI SSC also publishes guidance on protecting telephone payment data in its document library.

Why Sovereign Secure

Sovereign Secure Ltd (Companies House 08334453, incorporated 2012) is headquartered in Accrington, Lancashire. The PCI Security Standards Council has approved us as a Qualified Security Assessor (QSA) company, a Qualified PIN Assessor (QPA) and a Card Production Security Assessor (CPSA), and we are a member of its Global Executive Assessor Roundtable (GEAR) for 2026 to 2028.

This is an independent guide: we do not rank or recommend payment providers. We help businesses confirm which SAQ applies to the way they actually take payments, and assess them where their acquirer needs a QSA.

Next step

Not sure which questionnaire your phone payments fall under? Tell us how you take payments and we will confirm your SAQ and send a fixed quote for any help you need. Contact our PCI team or call +44 161 523 5276.

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Last reviewed October 2026 by the Sovereign Secure assessment team.

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FAQ

Frequently asked questions

Can't find your answer? Call us on +44 161 523 5276 or send us a message.

Is it legal to take card payments over the phone?

Yes. Telephone payments are a normal card-not-present transaction type, usually called MOTO (mail order, telephone order). Your payment provider has to enable them on your account, and you must handle the card data in line with PCI DSS and UK GDPR.

Can I write down card details taken over the phone?

Avoid it. Never write down the security code, because PCI DSS does not allow it to be kept after the payment is authorised. If you must jot down a card number, lock the note away and cross-cut shred it as soon as the payment has gone through.

What is the safest way to take card payments by phone?

The safest methods are the ones where nobody in your business hears the card number: a payment link the customer completes on the provider's hosted page, or keypad entry with DTMF masking. If you key payments yourself, use a virtual terminal on a dedicated computer or a standalone card machine.

How safe is paying by credit card over the phone?

It is safe when the business keys your details straight into a virtual terminal or card machine during the call, or sends you a payment link, and never writes down your security code. Only give card details on a call to a number you trust, never share your PIN, and check your statement for the payment.

Can customers email me their card details?

Do not ask them to. Email brings your mailbox and devices into PCI DSS scope and usually makes you ineligible for the shorter questionnaires. If a customer emails a card number anyway, do not process it from the email: delete it securely, reply without quoting the number and ask them to pay another way.

Do I have to record calls when taking card payments?

No. PCI DSS does not require call recording. If you record calls for other reasons, the security code must never end up in the recording; our PCI IVR guide explains pause-and-resume and DTMF masking.

Can I charge a fee for taking a card payment over the phone?

Not on consumer cards. UK rules have banned surcharges on consumer debit and credit card payments since January 2018, whether the payment is taken in person, online or by phone.

Which PCI SAQ covers phone payments?

It depends on the method: a virtual terminal usually means SAQ C-VT, a standalone card machine SAQ B or B-IP, and a payment link completed on your provider's hosted page usually SAQ A. Storing card numbers or taking them by email usually means SAQ D.

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