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

3.7.5 Retirement, replacement or destruction of keys

Key-management policies and procedures must be in place for retiring, replacing or destroying keys that protect stored account data where necessary, when: (1) the key's defined cryptoperiod has ended; (2) the key's integrity is weakened, including when someone aware of a cleartext key component departs the organisation or moves out of the role that gave them that knowledge; (3) the key is believed or confirmed to be compromised. Keys that have been retired or replaced must not be used for encryption. Applicability: retired or replaced keys that must be kept are to be archived securely (for example wrapped with a key-encryption key). Guidance says archived keys should serve for decryption or verification alone, and a compromised key should be dealt with through the Requirement 12.10.1 incident response plan. Objective under the customized approach: keys are taken out of active use once their integrity is believed or confirmed to be weakened.

Source: PCI DSS v4.0.1, 3.7.5. 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
1
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

  • Key destruction certificates or HSM deletion logs · Key management / PKI

periodic reviewEvidence produced at each review

  • Records of key replacement after custodian departures · Document repository

governing documentDocuments that govern the control

  • Key retirement and destruction procedure listing the three triggers · Policy repository / GRC workspace
  • Archived key register showing secure storage and decrypt-only use · Policy repository / GRC workspace
  • Incident response plan section on key compromise · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Key management / PKI on a schedule; put the documents under version control with an owner and review date, and log each review 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

3.7.4 Key changes at end of cryptoperiod · 3.7.6 Split knowledge and dual control for manual key operations