What evidence do auditors commonly ask for on 5.1.2 Requirement 5 roles and responsibilities assigned?

RACI covering anti-malware administration, alert triage, periodic evaluations and phishing controls; Role descriptions for the endpoint security team or managed security provider; Staff acknowledgements of assigned Requirement 5 duties; Interview records with the anti-malware administrator confirming responsibilities.

What is the most common gap auditors find on 5.1.2?

Anti-malware console alerts go to a mailbox with no assigned reviewer

PCI DSS v4.0.1 · Req 5: Anti-Malware

`5.1.2` Requirement 5 roles and responsibilities assigned

Duties for carrying out each Requirement 5 activity (deploying and updating anti-malware, evaluating systems considered not at risk, reviewing malware logs, approving temporary disablement, operating anti-phishing controls) must be written down, allocated, and understood by those who hold them. They may be recorded within policies or in a separate document such as a RACI matrix, and staff may acknowledge their assigned duties. Applicability: applies to every entity in scope, with no special notes. Customized approach objective: daily Requirement 5 work is allocated, and the people who own it answer for its continuous, successful operation.

Source: PCI DSS v4.0.1, 5.1.2. 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.

artefacts

held by a system

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

none for this control

periodic reviewEvidence produced at each review

Staff acknowledgements of assigned Requirement 5 duties · Identity provider / directory
Interview records with the anti-malware administrator confirming responsibilities · Endpoint management (MDM / EDR)

governing documentDocuments that govern the control

RACI covering anti-malware administration, alert triage, periodic evaluations and phishing controls · Policy repository / GRC workspace
Role descriptions for the endpoint security team or managed security provider · Policy repository / GRC workspace

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

Anti-malware console alerts go to a mailbox with no assigned reviewer
Responsibility split with an outsourced provider is undocumented
Nobody owns the periodic evaluation of systems without anti-malware

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

5.1.1 Requirement 5 policies and procedures maintained and communicated · 5.2.1 Anti-malware deployed on all system components