EvidenceSheet

11.4.1 Penetration testing methodology defined and implemented

The entity must define, document and implement a penetration testing methodology that includes: industry-accepted testing approaches; coverage of critical systems and of the entire CDE perimeter; tests run from both outside and inside the network; tests validating any scope-reduction and segmentation controls; tests at the application layer that find at least the vulnerability types listed under Requirement 6.2.4; tests at the network layer covering every component supporting network functions plus operating systems; a review of the threats and vulnerabilities the entity met over the past 12 months; a documented approach for assessing and addressing risk from exploitable vulnerabilities and weaknesses the testing finds; and keeping the results of testing and of remediation for a minimum of 12 months. Applicability: internal testing means testing within the CDE and into it from trusted and untrusted internal networks; external testing means testing the exposed outer edge of trusted networks, and of critical systems that are reachable from or connected to public network infrastructure. Objective under the customized approach: a formal methodology exists for thorough technical testing in which a competent manual attacker tries to exploit vulnerabilities and weaknesses through simulated attacks.

Source: PCI DSS v4.0.1, 11.4.1. 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.

5
artefacts
0
held by a system
2
at each review
hard
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

none for this control

periodic reviewEvidence produced at each review

  • Threat and vulnerability review from the prior 12 months used as test input · Vulnerability scanner / patch tooling
  • Archived test reports and remediation records going back at least 12 months · Vulnerability scanner / patch tooling

governing documentDocuments that govern the control

  • Documented penetration testing methodology referencing an industry approach (for example OSSTMM or OWASP) · Policy repository / GRC workspace
  • Scope definitions covering CDE perimeter, critical systems, internal and external vantage points · Policy repository / GRC workspace
  • Methodology sections for application-layer, network-layer and segmentation testing · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

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

11.3.2.1 External scans after significant change · 11.4.2 Internal penetration testing annually and after change