What evidence do auditors commonly ask for on 3.6.1 Procedures protect keys against disclosure and misuse?

Key management policy and procedures covering custodian limits, KEK strength, separation and storage; Key inventory listing each DEK and KEK with strength and storage location; Custodian list for each key; Architecture showing KEK and DEK storage separation.

What is the most common gap auditors find on 3.6.1?

KEK weaker than the DEK it wraps (for example 2048-bit RSA wrapping AES-256 with no strength analysis)

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

`3.6.1` Procedures protect keys against disclosure and misuse

The entity defines and carries out procedures to shield the keys securing stored account data against misuse and disclosure, covering: (1) key access limited to the smallest number of custodians needed; (2) no key-encrypting key is weaker than any data-encrypting key it wraps; (3) key-encrypting keys kept apart from data-encrypting keys; and (4) keys held securely in as few locations and forms as possible. Applicability: covers keys protecting stored account data and key-encrypting keys that protect data-encrypting keys; both kinds need protection, and key-encrypting keys need especially strong measures because one may unlock many data-encrypting keys. Guidance recommends a centralized, standards-based key management system. Objective under the customized approach: processes guarding stored-data keys against misuse and disclosure are defined and running.

Source: PCI DSS v4.0.1, 3.6.1. 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.

artefacts

held by a system

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

none for this control

governing documentDocuments that govern the control

Key management policy and procedures covering custodian limits, KEK strength, separation and storage · Policy repository / GRC workspace
Key inventory listing each DEK and KEK with strength and storage location · Policy repository / GRC workspace
Custodian list for each key · Policy repository / GRC workspace
Architecture showing KEK and DEK storage separation · 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

KEK weaker than the DEK it wraps (for example 2048-bit RSA wrapping AES-256 with no strength analysis)
KEK and DEK held in the same configuration file
Procedures silent on minimizing locations and forms of keys

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

3.5.1.3 Disk encryption access independent of OS authentication · 3.6.1.1 Service provider cryptographic architecture documented