What evidence do auditors commonly ask for on 3.3.3 Issuer SAD storage limited, justified and encrypted?

Documented business justification for each category of SAD retained by issuing functions; Data inventory of issuing systems holding SAD (card personalisation, PIN management); Encryption configuration and key management records for stored SAD; Access control lists restricting who can reach stored SAD; Interview records with issuing operations owners.

What is the most common gap auditors find on 3.3.3?

Justification is generic and does not tie each SAD element to a specific issuing function

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

`3.3.3` Issuer SAD storage limited, justified and encrypted

Extra obligation for card issuers, and for firms supporting issuing services, that hold SAD: any SAD they keep must (1) be restricted to what a legitimate issuing business need requires and be secured, and (2) be encrypted with strong cryptography. Applicability: applies only to issuers and firms supporting issuing services that store SAD; such entities often create and control SAD as part of issuing and may store it only where a legitimate business need exists, meaning one necessary to perform the function delivered by or for the issuer. Objective under the customized approach: SAD is kept only as far as issuing functions require it and is protected against unauthorized access. Future-dated (bullet requiring strong encryption of stored SAD): treated as a best practice up to 31 March 2025 and mandatory since then.

Source: PCI DSS v4.0.1, 3.3.3. 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.

artefacts

held by a system

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 and key management records for stored SAD · Key management / PKI

periodic reviewEvidence produced at each review

Interview records with issuing operations owners · Document repository

governing documentDocuments that govern the control

Documented business justification for each category of SAD retained by issuing functions · Document repository
Data inventory of issuing systems holding SAD (card personalisation, PIN management) · Policy repository / GRC workspace
Access control lists restricting who can reach stored SAD · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Key management / PKI 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

Justification is generic and does not tie each SAD element to a specific issuing function
SAD retained in personalisation data files longer than the issuing process needs
Stored issuer SAD still unencrypted after the bullet became mandatory

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

3.3.2 Pre-authorization SAD stored electronically is strongly encrypted · 3.4.1 PAN masked on display except for authorized roles