What evidence do auditors commonly ask for on CEK-12 Key Rotation?

Cryptoperiod calculation per key type; KMS rotation settings and rotation logs with dates; Inventory showing keys inside the rotation process; Legal or regulatory rotation requirements recorded.

What is the most common gap auditors find on CEK-12?

Rotation set on a default schedule with no cryptoperiod analysis

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

`CEK-12` Key Rotation

Cryptographic keys are rotated according to the calculated cryptoperiod, which takes account of the risk of information disclosure and of legal and regulatory requirements.

Source: CSA CCM v4.1, CEK-12. 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

KMS rotation settings and rotation logs with dates · Key management / PKI

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

Cryptoperiod calculation per key type · Policy repository / GRC workspace
Inventory showing keys inside the rotation process · Policy repository / GRC workspace
Legal or regulatory rotation requirements recorded · 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

Rotation set on a default schedule with no cryptoperiod analysis
Some keys excluded from rotation
No logs of rotation events

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.

Build my evidence sheet

CEK-11 Key Purpose · CEK-13 Key Revocation