4.2.1.1 Inventory of trusted transmission keys and certificates
The entity must keep an up-to-date inventory of its own trusted keys and certificates that protect PAN while it is transmitted. A useful inventory records key custodians, key strength, protocols, algorithms and expiry dates, and for certificates the issuing CA and expiration date, so the entity can react quickly when a weakness is found in encryption software, certificates or algorithms. Applicability: this was advisory only up to 31 March 2025 and is now required and fully assessed. Objective under the customized approach: every key and certificate that protects PAN in transit is known and confirmed as trusted. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.
Source: PCI DSS v4.0.1, 4.2.1.1. 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.
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
- Reconciliation record comparing the inventory against certificates discovered by a network or endpoint scan · Vulnerability scanner / patch tooling
periodic reviewEvidence produced at each review
- Records of recent inventory updates tied to certificate renewals or replacements · Policy repository / GRC workspace
governing documentDocuments that govern the control
- Documented procedure for adding, updating and retiring entries in the key and certificate inventory · Policy repository / GRC workspace
- The inventory itself listing each certificate or key, issuing CA, algorithm, key length, owner and expiry date · Policy repository / GRC workspace
First move
Common gaps auditors find
- Inventory covers public web certificates but omits certificates on APIs, load balancers or partner links
- Spreadsheet inventory not updated after renewals, so expiry dates are wrong
- No custodian recorded, so nobody is alerted before a certificate expires
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 sheet4.2.1 Strong cryptography safeguards PAN over public networks · 4.2.1.2 Wireless networks use strong cryptography