What evidence do auditors commonly ask for on 10.2.1.5 Logs capture changes to identification and authentication credentials?

Directory service audit settings for account creation and group membership changes; Sample events showing new account creation and privilege escalation; Logs of additions, changes and deletions of administrative accounts; Identity management system change history for in-scope applications.

What is the most common gap auditors find on 10.2.1.5?

Application-local accounts created outside the directory are not logged

PCI DSS v4.0.1 · Req 10: Logging and Monitoring

`10.2.1.5` Logs capture changes to identification and authentication credentials

Audit logs must record every change to identification and authentication credentials, including at minimum: the creation of new accounts; any elevation of privileges; and every change, addition or deletion affecting accounts that hold administrative access. Applies to all entities. The guidance notes these records leave residual evidence if someone tries to misuse credentials to get around them or to impersonate a legitimate account. Customized approach objective: every change to identification and authentication credentials leaves a record.

Source: PCI DSS v4.0.1, 10.2.1.5. 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.

artefacts

held by a system

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

Directory service audit settings for account creation and group membership changes · Identity provider / directory
Sample events showing new account creation and privilege escalation · Identity provider / directory
Logs of additions, changes and deletions of administrative accounts · Identity provider / directory
Identity management system change history for in-scope applications · Policy repository / GRC workspace

periodic reviewEvidence produced at each review

none for this control

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

Application-local accounts created outside the directory are not logged
Addition to privileged groups is logged but direct permission grants are not
Password resets on administrative accounts not captured

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

10.2.1.4 Logs capture invalid logical access attempts · 10.2.1.6 Logs capture initialization and stopping of audit logs