11.4.3 External penetration testing annually and after change
External 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 (good practice): when selecting a tester, entities can weigh specialist penetration testing certifications and prior experience such as years in the field and the type and scope of past engagements. Objective under the customized approach: technical testing following the defined methodology verifies external 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, 11.4.3. 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
- Independence confirmation for the tester · Vulnerability scanner / patch tooling
governing documentDocuments that govern the control
- Latest external penetration test report, scope and engagement letter · Policy repository / GRC workspace
- Tests triggered by significant changes to internet-facing infrastructure or applications · Policy repository / GRC workspace
- Tester qualifications (certifications, experience summary) · Policy repository / GRC workspace
- External asset inventory used to define scope · Policy repository / GRC workspace
First move
Common gaps auditors find
- External test scoped to a handful of IPs, missing web applications
- New internet-facing application launched without a test
- Test report older than 12 months at assessment time
- A vulnerability scan presented as an external penetration test
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 sheet11.4.2 Internal penetration testing annually and after change · 11.4.4 Correct exploitable findings from penetration tests