What evidence do auditors commonly ask for on 12.6.3.1 Awareness training covers phishing and social engineering?

Training module content on phishing and social engineering; Phishing simulation campaign results; Reporting procedure for suspected phishing; Completion records for the module.

What is the most common gap auditors find on 12.6.3.1?

Content covers phishing but not broader social engineering such as phone pretexting

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

`12.6.3.1` Awareness training covers phishing and social engineering

Security awareness training must address threats and vulnerabilities that could affect cardholder data or sensitive authentication data, covering at minimum phishing (and attacks related to it) plus social engineering. Applicability: technical and automated anti-phishing controls under Requirement 5.4.1 are a separate and distinct requirement; meeting one does not satisfy the other. Objective under the customized approach: personnel understand their own human weaknesses and how attackers try to exploit them, and can obtain help and guidance when needed. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.

Source: PCI DSS v4.0.1, 12.6.3.1. 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.

artefacts

held by a system

at each review

easy

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

Phishing simulation campaign results · HR system / LMS
Completion records for the module · HR system / LMS

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

Training module content on phishing and social engineering · HR system / LMS
Reporting procedure for suspected phishing · HR system / LMS

First move

Automate the pull from your HR system / LMS. Joiner, mover, leaver and training-completion records exported from the HR system and LMS.

Common gaps auditors find

Content covers phishing but not broader social engineering such as phone pretexting
Entity treats its email filtering as satisfying this requirement
No instruction on how and where to report suspected attempts

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

12.6.3 Security awareness training on hire and annually with acknowledgment · 12.6.3.2 Awareness training covers acceptable use of end-user technologies