12.4.1 Executive responsibility for a PCI DSS compliance program
Service providers only: executive management must set up responsibility for protecting cardholder data and for a PCI DSS compliance program, covering: overall accountability for keeping PCI DSS compliance; and defining a charter for the compliance program along with communication to executive management. Applicability: applies only where the assessed entity is a service provider. Executive management can mean C-level roles, the board or an equivalent, with titles depending on the organisation's structure; responsibility for the program may be allocated to individual roles and/or business units. Customized approach objective: executives are answerable and accountable for cardholder data security.
Source: PCI DSS v4.0.1, 12.4.1. 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.
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
- Records of charter communication to executive management · Policy repository / GRC workspace
governing documentDocuments that govern the control
- PCI DSS compliance program charter · Policy repository / GRC workspace
- Board or executive resolution assigning overall accountability · Policy repository / GRC workspace
- Organisation chart showing program ownership · Document repository
First move
Common gaps auditors find
- Charter drafted but never communicated to executives
- Accountability sits with the security team without executive sponsorship
- Business units running in-scope services not named in the program
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 sheet12.3.4 Annual review of hardware and software technologies · 12.4.2 Quarterly reviews that personnel follow security procedures