EvidenceSheet

12.5.3 Scope review after significant organisational change

Service providers only: when the organisational structure changes significantly, the entity must carry out and document an internal review of the effect on PCI DSS scope and on which controls apply, and report the results to executive management. The guidance gives examples of such changes: mergers or acquisitions and major changes or reassignments of personnel responsible for security controls. Applicability: applies only when the assessed entity is a service provider. Objective under the customized approach: scope gets reconfirmed after a major organisational change. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.

Source: PCI DSS v4.0.1, 12.5.3. 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.

4
artefacts
0
held by a system
2
at each review
hard
to go live
Policy repository / GRC workspace
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

none for this control

periodic reviewEvidence produced at each review

  • Procedure triggering scope review on organisational change · Policy repository / GRC workspace
  • Meeting minutes or memos communicating results to executives · Policy repository / GRC workspace

governing documentDocuments that govern the control

  • Impact review document for recent mergers, acquisitions or restructures · Document repository
  • List of organisational changes in the period · Document repository

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

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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12.5.2.1 Six-monthly scope confirmation for service providers · 12.6.1 Formal security awareness program