11.4.2 Internal penetration testing annually and after change
Internal penetration testing must be performed: using the methodology the entity has defined; no less than annually; after every significant upgrade or change to infrastructure or applications; by a qualified tester, whether an internal resource or an external third party; and with organizational independence of the tester (a QSA or ASV is not required). Guidance (purpose): internal testing finds vulnerabilities and misconfigurations an attacker with some internal foothold could use, and can expose previously unknown systems that indicate change control failures. Objective under the customized approach: technical testing following the defined methodology verifies internal defenses as often as needed to keep pace with new and evolving attacks and to confirm that significant changes bring in no unknown vulnerabilities.
Source: PCI DSS v4.0.1, 11.4.2. 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.
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
- Latest internal penetration test report with scope of work and dates · Vulnerability scanner / patch tooling
- Test reports for significant infrastructure or application changes in the period · Vulnerability scanner / patch tooling
- Tester CVs or certifications showing qualification · Vulnerability scanner / patch tooling
- Mapping of the test against the 11.4.1 methodology · Vulnerability scanner / patch tooling
governing documentDocuments that govern the control
- Statement or org chart evidence of tester independence · Policy repository / GRC workspace
First move
Common gaps auditors find
- More than 12 months between internal tests
- Major infrastructure upgrade not followed by a test
- Internal tester reports to the team that owns the tested systems
- Test scope excludes parts of the CDE
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 sheet11.4.1 Penetration testing methodology defined and implemented · 11.4.3 External penetration testing annually and after change