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

3.5.1.1 PAN hashes are keyed cryptographic hashes

Where hashing is used to make PAN unreadable (the first method listed in Requirement 3.5.1), the hashes must be keyed cryptographic hashes over the entire PAN, supported by key-management processes and procedures that meet Requirements 3.6 and 3.7. Applicability: all applicability notes for 3.5.1 also apply; key-management processes (3.6 and 3.7) are not needed for components that produce a single keyed PAN hash to compare against another system if those components hold only one hash value at a time (no hashes stored on them) AND no other account data sits on the same system. Guidance cites transit turnstiles that hash PAN for a backend as an example, while noting the backend itself, seeing many hashes, must meet 3.6 and 3.7. Once effective, this requirement replaces the one-way hash bullet in 3.5.1. Objective under the customized approach: cleartext PAN cannot be worked out from PAN hashes. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.

Source: PCI DSS v4.0.1, 3.5.1.1. 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.

5
artefacts
1
held by a system
1
at each review
hard
to go live
Policy repository / GRC workspace
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

  • Code or configuration showing salt/key handling · Cloud console / configuration management

periodic reviewEvidence produced at each review

  • Key management records for the hashing key under 3.6 and 3.7 · Key management / PKI

governing documentDocuments that govern the control

  • Hashing design specifying a keyed algorithm (for example HMAC) over the whole PAN · Document repository
  • Sample hashed values from repositories and logs · Policy repository / GRC workspace
  • Architecture diagram identifying any single-hash comparison components claimed as exempt · Policy repository / GRC workspace

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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3.5.1 Stored PAN rendered unreadable · 3.5.1.2 Disk or partition encryption only on removable media