EvidenceSheet
PCI DSS v4.0.1 · Req 3: Protect Stored Account Data

3.3.2 Pre-authorization SAD stored electronically is strongly encrypted

Any SAD kept in electronic form before authorization completes must be encrypted with strong cryptography. Guidance suggests using a different key for SAD than the one used for PAN, without needing to separately encrypt PAN embedded within SAD such as track data. Applicability: whether SAD may be stored before authorization at all is decided by the bodies running compliance programmes (for example payment brands and acquirers), who may set further criteria; the requirement covers all SAD storage even where no PAN is present; Requirement 3.2.1 adds retention obligations for pre-authorization SAD; issuers and issuing-service companies with a legitimate, documented business need are exempt and follow 3.3.3; it does not change how PIN blocks are managed nor require a correctly encrypted PIN block to be encrypted again. Objective under the customized approach: none, this requirement cannot be met through the customized approach. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.

Source: PCI DSS v4.0.1, 3.3.2. 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.

5
artefacts
1
held by a system
2
at each review
hard
to go live
Document repository
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

  • Encryption configuration for those stores showing algorithm and key length · Cloud console / configuration management

periodic reviewEvidence produced at each review

  • Key assignment record showing a separate key for SAD versus PAN where adopted · Document repository
  • Payment brand or acquirer approval for pre-authorization SAD storage · Document repository

governing documentDocuments that govern the control

  • Inventory of systems that hold SAD before authorization (for example store-and-forward or deferred authorization queues) · Policy repository / GRC workspace
  • Vendor documentation for payment application encryption of pre-authorization data · Vendor register / contract repository

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Cloud console / configuration management on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.

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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3.3.1.3 PIN and PIN block not retained after authorization · 3.3.3 Issuer SAD storage limited, justified and encrypted