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

3.6.1.1 Service provider cryptographic architecture documented

Service providers only (an additional requirement): a written description of the cryptographic architecture is kept current and covers: (1) details of every algorithm, protocol and key used to protect stored account data, with key strength and expiry date; (2) prevention of the same cryptographic keys being used in both production and test environments; (3) how each key is used; and (4) an inventory of the HSMs, the key management systems (KMS) and any other secure cryptographic devices (SCDs) supporting key management, with device type and location, to support Requirement 12.3.4. Applicability: applies only when the assessed entity is a service provider; with cloud HSMs, responsibility for the architecture is split between cloud provider and cloud customer. Objective under the customized approach: correct, current information about the cryptographic architecture is maintained and can be produced. Future-dated (bullet on preventing the same keys being used in production and test): treated as a best practice up to 31 March 2025 and mandatory since then.

Source: PCI DSS v4.0.1, 3.6.1.1. 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
0
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

none for this control

periodic reviewEvidence produced at each review

  • Evidence of separate key sets for production and test (key IDs, KMS policies) · Key management / PKI

governing documentDocuments that govern the control

  • Cryptographic architecture document listing algorithms, protocols, keys, key strengths and expiry dates · Policy repository / GRC workspace
  • Key usage description for each key · Policy repository / GRC workspace
  • HSM, KMS and SCD inventory with type and physical or cloud location · Policy repository / GRC workspace
  • Cloud HSM shared responsibility matrix · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

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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3.6.1 Procedures protect keys against disclosure and misuse · 3.6.1.2 Permitted storage forms for secret and private keys