What evidence do auditors commonly ask for on CEK-21 Key Inventory Management?

Key inventory report from the KMS; Status change history for sampled keys; Reconciliation of inventory against systems using keys; Periodic key inventory reports to management.

What is the most common gap auditors find on CEK-21?

Keys created outside the KMS not tracked

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

`CEK-21` Key Inventory Management

Processes, procedures and technical measures are defined, implemented and evaluated so that the key management system tracks and reports all cryptographic material and its status changes, taking legal and regulatory requirements into account.

Source: CSA CCM v4.1, CEK-21. 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

Policy repository / GRC workspace

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

Status change history for sampled keys · Policy repository / GRC workspace

periodic reviewEvidence produced at each review

Key inventory report from the KMS · Key management / PKI
Reconciliation of inventory against systems using keys · Policy repository / GRC workspace
Periodic key inventory reports to management · Policy repository / GRC workspace

governing documentDocuments that govern the control

none for this control

First move

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

Common gaps auditors find

Keys created outside the KMS not tracked
Inventory lacks status history
No reconciliation with applications using keys

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-20 Key Recovery · DCS-01 Physical and Environmental Security Policy and Procedures