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

3.7.3 Secure storage of cryptographic keys

Key-management policies and procedures must be in place covering how keys that protect stored account data are stored securely. Guidance suggests wrapping data-encrypting keys with a key-encrypting key or holding keys in an HSM, and says secret or private keys able to decrypt data should never appear in source code. Guidance explains that keys stored without proper protection could let an attacker decrypt and expose account data. Customized approach objective: keys are protected while in storage.

Source: PCI DSS v4.0.1, 3.7.3. 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.

4
artefacts
2
held by a system
1
at each review
easy
to go live
Key management / PKI
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

  • HSM or KMS configuration evidence · Key management / PKI
  • Code scanning results showing no embedded secret keys · Vulnerability scanner / patch tooling

periodic reviewEvidence produced at each review

  • Observation notes of key storage mechanisms · Document repository

governing documentDocuments that govern the control

  • Key storage procedure referencing HSM, KMS or KEK wrapping · Policy repository / GRC workspace

First move

Automate the pull from your Key management / PKI. Key inventory, rotation dates and certificate expiry from the KMS or PKI.

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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3.7.2 Secure distribution of cryptographic keys · 3.7.4 Key changes at end of cryptoperiod