Does your system store, transmit, process card holder data along with PAN number?
If you answer yes to at least one statement then your system is in scope and will need to be PCI compliant.
It is possible that this account number might be an PAN from a credit
card
It doesn't seem to be clear to you what this account number is, but if it helps you understand the compliance scope:
- if every account number is a full PAN, then the system is in scope.
- if 1/100 account number is a full PAN, then the system is in scope.
- if 1/1000 account number is a full PAN, then the system is in scope.
if 1/n account number is a full PAN, then your system is in scope.
if no account number is a full PAN, then your system is out of scope
- if the PAN contains only a subset of the full card number, such as the last four or the first six and the last four the your system is out of scope.
Please keep in mind the statements above apply to your account numbers (might be a PAN) being stored, transmitted or process by your system.
Even if you do not process or take payment and you do store PAN for any purpose (account number) your system will be in scope.