What evidence do auditors commonly ask for on 3.6.1.4 Cryptographic keys kept in fewest locations?

Key location inventory showing every copy of each key; Rationale for each storage location (primary, disaster recovery); Scan results for key material in code repositories, backups and file shares; Observation notes of key storage handling.

What is the most common gap auditors find on 3.6.1.4?

Keys duplicated across multiple application servers and backups without justification

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

`3.6.1.4` Cryptographic keys kept in fewest locations

Cryptographic keys must be kept in as few locations as possible. Guidance explains that this helps the entity track and monitor where keys reside and reduces the chance of exposure to unauthorized parties. Customized approach objective: keys are held only where they are needed.

Source: PCI DSS v4.0.1, 3.6.1.4. 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

moderate

to go live

Vulnerability scanner / patch tooling

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

Scan results for key material in code repositories, backups and file shares · Vulnerability scanner / patch tooling

periodic reviewEvidence produced at each review

Observation notes of key storage handling · Document repository

governing documentDocuments that govern the control

Key location inventory showing every copy of each key · Policy repository / GRC workspace
Rationale for each storage location (primary, disaster recovery) · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (Vulnerability scanner / patch tooling); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Keys duplicated across multiple application servers and backups without justification
Stale key copies left on decommissioned systems
Key material found in source repositories

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

3.6.1.3 Cleartext key component access limited to minimum custodians · 3.7.1 Generation of strong cryptographic keys