12.3.1 Targeted risk analysis for flexible-frequency requirements
Wherever a PCI DSS requirement calls for a targeted risk analysis, that analysis must be documented and contain: the assets being protected; the threats the requirement guards against; factors that raise how likely a threat is to materialise and/or how much harm it would do; a resulting analysis that sets, and justifies, how the frequency or processes chosen by the entity reduce that likelihood or harm; a check of every such analysis (minimum cadence: at least every 12 months) deciding whether results still hold or a new analysis is needed; and performance of updated analyses when that annual review shows the need. Objective under the customized approach: current knowledge and evaluation of risks to the CDE are kept up to date. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.
Source: PCI DSS v4.0.1, 12.3.1. 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.
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
- Annual TRA review records and any updated analyses · Document repository
governing documentDocuments that govern the control
- Targeted risk analysis methodology or procedure · Policy repository / GRC workspace
- Completed TRA documents per applicable requirement showing assets, threats and likelihood/impact factors · Document repository
- Justification of chosen frequencies in each TRA · Document repository
First move
Common gaps auditors find
- Enterprise risk register used in place of requirement-specific analyses
- Chosen frequency stated without any justification
- TRAs not revisited within 12 months
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 sheet12.2.1 Rules for acceptable use of end-user technology · 12.3.2 Targeted risk analysis for each customized-approach requirement