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.
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
Common gaps auditors find
- Merger or reorganisation occurred with no documented scope review
- Review done but results not reported to executive management
- Procedure lacks a definition of significant organisational change
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 sheet12.5.2.1 Six-monthly scope confirmation for service providers · 12.6.1 Formal security awareness program