What evidence do auditors commonly ask for on CEK-09 Encryption and Key Management Audit?

Audit plan including encryption and key management; Completed audit reports on key management with findings and tracking; Continuous monitoring output on KMS or HSM configuration; Records of audits triggered by security events.

What is the most common gap auditors find on CEK-09?

Key management never audited separately

CSA CCM v4.1 · CEK - Cryptography, Encryption & Key Management

`CEK-09` Encryption and Key Management Audit

Systems, policies and processes for encryption and key handling are audited at a frequency matched to the system's risk exposure, ideally continuously and at least once a year, and also after any security event.

Source: CSA CCM v4.1, CEK-09. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open CSA CCM v4.1 in the compliance library.

Version 4.1 adds 11 controls (among them API security, log sanitisation and a service bill of materials) and renumbers several domains. CSA accepts v4.0.x during its transition; if your STAR assessment is still on v4.0.1, check the numbering against it.

artefacts

held by a system

at each review

moderate

to go live

Key management / PKI

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

Continuous monitoring output on KMS or HSM configuration · Key management / PKI

periodic reviewEvidence produced at each review

Completed audit reports on key management with findings and tracking · Key management / PKI
Records of audits triggered by security events · Policy repository / GRC workspace

governing documentDocuments that govern the control

Audit plan including encryption and key management · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (Key management / PKI); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Key management never audited separately
No audit after a key-related security event
Findings not tracked to closure

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

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CEK-08 Service Customer Key Management Capability · CEK-10 Key Generation