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

3.7.4 Key changes at end of cryptoperiod

Key-management policies and procedures must be in place to change each key when its cryptoperiod ends, as set by the relevant application vendor or key owner and informed by industry best practice and guidelines, including: (1) a defined cryptoperiod for every key type in use; and (2) a process for changing keys when that cryptoperiod ends. Guidance defines a cryptoperiod as the span during which a key may be used for its purpose, often expressed as active time and/or volume of ciphertext produced, and cites algorithm strength, key length, compromise risk and data sensitivity as factors, referring to Revision 5 of NIST SP 800-57 Part 1. Objective under the customized approach: keys are not used after their defined cryptoperiod.

Source: PCI DSS v4.0.1, 3.7.4. 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.

4
artefacts
1
held by a system
1
at each review
moderate
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

  • KMS or HSM records showing key creation and rotation dates · Key management / PKI

periodic reviewEvidence produced at each review

  • Evidence of the most recent rotation for sample keys · Key management / PKI

governing documentDocuments that govern the control

  • Cryptoperiod table per key type with basis for each period · Policy repository / GRC workspace
  • Key rotation procedure · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (Key management / PKI); keep the periodic reviews but log each one 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.

Build my evidence sheet

3.7.3 Secure storage of cryptographic keys · 3.7.5 Retirement, replacement or destruction of keys