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

3.7.9 Key guidance for service provider customers

Extra requirement applying to service providers alone: if cryptographic keys for storing or transmitting account data are shared between the provider and its customers, it must document guidance on securely transmitting, storing and updating those keys and distribute that guidance to its customers. Applicability: applies only when the assessed entity is a service provider. Objective under the customized approach: customers receive suitable key management guidance whenever they are given shared keys.

Source: PCI DSS v4.0.1, 3.7.9. 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
0
held by a system
1
at each review
hard
to go live
Document repository
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

  • Evidence of distribution (onboarding pack, portal publication, delivery records) · HR system / LMS

governing documentDocuments that govern the control

  • Customer-facing key management guide covering transmission, storage and update of shared keys · Policy repository / GRC workspace
  • List of customers receiving shared keys · Document repository
  • Mapping of the guide to 3.7.1 to 3.7.8 · Document repository

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

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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3.7.8 Key custodians formally acknowledge responsibilities · 4.1.1 Requirement 4 policies and procedures maintained and communicated