What evidence do auditors commonly ask for on 12.6.2 Awareness program reviewed annually and updated?

Dated annual review record of awareness content; Content change history showing new threat topics added; Threat intelligence inputs used in the review; Current version of training materials.

What is the most common gap auditors find on 12.6.2?

Same content delivered for several years without review

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

`12.6.2` Awareness program reviewed annually and updated

The security awareness program needs a review, at least every 12 months, with updates made when required to address new threats and vulnerabilities that could affect cardholder data or sensitive authentication data, or to refresh what personnel are told about their part in safeguarding cardholder data. Objective under the customized approach: awareness material content is reviewed and refreshed periodically. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.

Source: PCI DSS v4.0.1, 12.6.2. 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.

artefacts

held by a system

at each review

moderate

to go live

HR system / LMS

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

Content change history showing new threat topics added · HR system / LMS

periodic reviewEvidence produced at each review

Dated annual review record of awareness content · HR system / LMS

governing documentDocuments that govern the control

Threat intelligence inputs used in the review · HR system / LMS
Current version of training materials · HR system / LMS

First move

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

Common gaps auditors find

Same content delivered for several years without review
Review occurred but emerging threats were not incorporated
No evidence tying updates to the threat environment

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 sheet

12.6.1 Formal security awareness program · 12.6.3 Security awareness training on hire and annually with acknowledgment