EvidenceSheet
PCI DSS v4.0.1 · Req 12: Information Security Policies

12.1.2 Security policy reviewed annually and updated as needed

The overall information security policy must be reviewed on a cycle no longer than 12 months, plus revised whenever needed so that it keeps pace with shifts in business objectives or in the risks facing the environment. The guidance explains that, as threats and defences evolve quickly, an unrevised policy may fail to address new protective measures. Customized approach objective: the policy keeps mirroring the entity's strategic security aims and principles over time.

Source: PCI DSS v4.0.1, 12.1.2. 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
1
held by a system
2
at each review
moderate
to go live
SIEM / log platform
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

  • Policy change log linking updates to business or risk changes · SIEM / log platform

periodic reviewEvidence produced at each review

  • Dated review records or sign-off for the last 12-month cycle · Document repository
  • Meeting minutes of the governance forum approving the review · Policy repository / GRC workspace

governing documentDocuments that govern the control

  • Current and prior policy versions for comparison · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (SIEM / log platform); keep the periodic reviews but log each one as a dated record with a named reviewer.

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.

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12.1.1 Overall information security policy established and disseminated · 12.1.3 Security roles defined and acknowledged by all personnel