EvidenceSheet

10.2.1.2 Logs capture all administrative actions

Audit logs must record every action carried out by anyone who holds administrative access, and this includes any interactive session run under an application account or a system account. Applies to all entities. The guidance explains that without such records mistakes or misuse of privilege cannot be traced to the specific action and account, and it defines administrative functions as those going beyond what ordinary users do in routine business work (see Appendix G). Customized approach objective: every action by individuals holding elevated privileges leaves a record.

Source: PCI DSS v4.0.1, 10.2.1.2. 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 PCI DSS v4.0.1 in the compliance library.

Version 4.0.1 is the active version; 4.0 has been retired. Appendix A1 applies only to multi-tenant service providers, A2 only to card-present POS POI terminals that still use SSL or early TLS, and A3 only when a payment brand or acquirer requires it. Which requirements apply to you follows your validation type.

4
artefacts
2
held by a system
2
at each review
easy
to go live
Identity provider / directory
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

  • Command or session logging configuration for administrators (sudo logs, privileged session recordings) · Identity provider / directory
  • Sample log entries of administrative actions attributed to named admin IDs · Identity provider / directory

periodic reviewEvidence produced at each review

  • Evidence that interactive logons with service or system accounts are recorded · Identity provider / directory
  • Privileged access management tool audit reports · Identity provider / directory

governing documentDocuments that govern the control

none for this control

First move

Automate the pull from your Identity provider / directory. Scheduled export of users, roles and MFA state from the directory; access-review completion pulled from the IdP, not a spreadsheet.

Common gaps auditors find

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

10.2.1.1 Logs capture individual user access to cardholder data · 10.2.1.3 Access to the audit logs is itself logged