4.2.1 Strong cryptography safeguards PAN over public networks
Wherever PAN crosses open, public networks (such as the Internet, Wi-Fi, Bluetooth, cellular and satellite links), PAN must be protected with strong cryptography and security protocols, arranged so that: only keys and certificates that are trusted are accepted; certificates guarding PAN in transit are confirmed as valid and neither revoked nor expired; the protocol permits only secure versions or configurations and cannot use or fall back to any insecure version, algorithm, key size or implementation; and encryption strength suits the encryption method chosen. Protection may be at the data level, the session level, or both. Applicability: a self-signed certificate can be acceptable when an internal CA of the organisation issued it, its author is confirmed, it is verified (for instance by hash or signature) and it has not expired. The bullet on confirming certificates are valid and neither revoked nor expired was advisory only up to 31 March 2025; the remaining bullets were already mandatory. Objective under the customized approach: nobody can read or capture cleartext PAN from traffic over open, public networks. 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. 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
- TLS configuration exports or scan results showing allowed protocol versions and cipher suites, with no downgrade path · Key management / PKI
- Certificate validation settings (CRL or OCSP checking, pinning) for servers and client integrations · Cloud console / configuration management
periodic reviewEvidence produced at each review
- Packet capture or transmission sample showing PAN is encrypted end to end · Document repository
- Test result showing a connection with an untrusted or expired certificate is refused · Source control / CI pipeline
governing documentDocuments that govern the control
- Data-flow diagram marking every point where PAN enters or leaves over open, public networks · Document repository
First move
Common gaps auditors find
- Legacy endpoint or API still negotiates an early TLS version or weak cipher when the client requests it
- Integration client code disables certificate verification, accepting any certificate
- Expired or revoked certificate still in use on a payment endpoint because no revocation checking is configured
- A secondary transmission path (file transfer or partner link) missed from the data-flow diagram and left unencrypted
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 sheet4.1.2 Requirement 4 roles and responsibilities assigned · 4.2.1.1 Inventory of trusted transmission keys and certificates