The CFO’s Compliance Checklist: Key Insurance Requirements and Where PCI Fits

As a financial leader in Insurance, you are responsible for more than clean books. You are accountable for audit readiness, operational oversight, and choosing partners who protect your agency from compliance risk. PCI compliance goes beyond IT. It directly impacts how your payment data is handled, stored, and secured across every partner you rely on. This checklist helps you evaluate whether your payment partners, including platforms like AndDone, meet the standards your finance team needs to stay accurate, in control, and audit-ready.

1. Define PCI Scope and Ownership Across Systems and Vendors

PCI compliance for your insurance agency starts with clearly defining scope and ownership. Finance teams must understand every system, workflow, and vendor involved in accepting, processing, refunding, or adjusting card payments, especially when payment activity extends beyond internal systems.

Finance leaders should inventory every touchpoint where card data could appear, including:

• Customer-facing payment portals and hosted checkout experiences.
• Embedded payment links used in emails, invoices, or AMS workflows.
• Internal systems that process, reconcile, refund, or adjust transactions.
• Reprocessed or corrected payments handled outside the original workflow.
• Third-party vendors involved in payment acceptance, processing, tokenization, refunds, chargebacks, or reporting.

Just as important as defining ownership, PCI compliance in insurance depends on documented internal accountability and clearly outlined third-party vendor compliance responsibilities. While technical controls may live with IT teams or vendors, finance remains responsible for oversight.

Finance leaders should document:

• Who owns PCI oversight internally, including validation of scope, controls, and ongoing compliance.
• Which vendors are responsible for PCI controls related to payment acceptance, processing, and tokenization.
• How PCI evidence is collected, reviewed, and stored for audits.
• Where escalation occurs when compliance questions or control gaps arise.

2. Verify How Card Data Is Handled and Stored

Understanding how card data is handled is essential for limiting compliance burden.

Key areas to review include:

• Where card data is captured.
• Whether tokenization occurs immediately.
• Whether any system stores raw card data.
• How long payment data is retained.
• How data is removed or invalidated.

Platforms that rely on tokenization and limit data exposure help finance teams reduce audit scope while maintaining reporting visibility. Less exposure means fewer controls to manage and fewer questions to answer later.

Finance teams should confirm these controls are applied consistently across collections, refunds, and payment adjustments, not only initial transactions.

Look for platforms such as AndDone that tokenize payment data at capture and avoid storing raw card information to reduce audit scope and limit risk.

3. Restrict and Review Access to Payment

Access control is both compliance and financial security.

Finance teams should regularly review:

• Who can view payment details.
• Who can initiate refunds or adjustments.
• Who can export transaction data.
• How role changes are logged and approved.

Role-based permissions and access logs protect against internal risk and support clean audit trails in platforms like the AndDone Portal.

4. Validate Daily Reconciliation and Audit Trails

Reconciliation is where compliance becomes operational.

Strong payment workflows support:

• Transaction-level detail.
• Time-stamped audit logs.
• Clear linkage between payments, refunds, and accounting entries.
• Visibility into paid, pending, failed, and reversed transactions.

Manual reconciliation increases compliance risk. Finance teams benefit from systems that support daily reconciliation.

When payment records are tied to policies and customers with time-stamped logs, reconciliation becomes faster and more accurate. 

5. Make Exceptions Easy to See and Prove

Refunds, chargebacks, and adjustments are part of every payment operation. But when they aren’t documented or visible, they become compliance risks.

Finance teams should ensure:

• All exceptions are tracked with complete transaction history.
• Refunds follow standardized and documented workflows.
• Chargebacks remain visible in reporting.
• Exceptions do not bypass approval or logging controls.

Auditors focus on the moments when processes break. That’s why visibility matters.

Exception workflows should stay connected to the original transaction and remain visible to the full team. This makes it easier to demonstrate control, even when workflows don’t follow the standard path.

6. Confirm Third-Party and Vendor PCI Compliance

Third-party vendors are part of your compliance footprint. As industry coverage regularly highlights, payment complexity in insurance often increases when responsibility for data handling and reporting is spread across multiple platforms and partners. Finance leaders should verify each vendor’s PCI status and document third-party service provider responsibilities across data handling, reporting, and audit support.

Key areas to confirm include:

• Each vendor’s current PCI certification and scope.
• Which party captures, processes, tokenizes, or stores card data.
• How vendors support audits, including access to evidence and documentation.
• Where responsibility shifts between internal teams and external partners.

When vendors manage payment data correctly, finance teams stay in control without taking on extra compliance work. The right platform provides visibility, reporting, and audit support without adding PCI scope to your internal systems. 

The right partner keeps finance in control without adding technical PCI risk. In this short video, Chase Courtney from AndDone shares how their team helps reduce audit complexity by managing tokenization, routing, and reconciliation in one system.

7. Maintain PCI Evidence and Audit Readiness

Audit readiness depends on evidence that reflects how your business actually operates.

Finance teams should centralize:

• PCI policies and procedures.
• Access logs and activity records.
• Transaction and reconciliation reports.
• Vendor compliance documentation.

Evidence should remain current and aligned with live workflows, because faulty or outdated records can directly lead to compliance problems and audit obstacles. When documentation matches real operating conditions, audits move faster. 

8. Schedule Ongoing PCI Reviews for the Year

PCI compliance in your insurance agency must remain current as systems, vendors, and workflows change.

Finance leaders should:

• Align PCI reviews with monthly close cycles.
• Reassess PCI scope whenever payment systems, vendors, or workflows change.
• Review vendor compliance on a regular cadence.
• Update documentation proactively as processes evolve.

Routine reviews prevent compliance drift and reduce last-minute remediation. Keeping PCI oversight tied to financial operations supports consistent audit readiness throughout the year.