What evidence do auditors commonly ask for on 5.2.3.1 Targeted risk analysis sets evaluation frequency?

Targeted risk analysis document stating the evaluation frequency and the reasoning behind it; Evidence the analysis follows the 12.3.1 structure and was reviewed and approved; Dated evaluation records showing the defined frequency was met over the assessment period; Interview notes with the person performing the evaluations.

What is the most common gap auditors find on 5.2.3.1?

Frequency chosen without any documented targeted risk analysis

PCI DSS v4.0.1 · Req 5: Anti-Malware

`5.2.3.1` Targeted risk analysis sets evaluation frequency

How often the periodic evaluations under 5.2.3 are carried out for components considered not at risk from malware must be fixed by a targeted risk analysis of the entity, and that analysis must be performed according to every element specified in Requirement 12.3.1. Criteria such as environment complexity and the number of system types to evaluate can inform the chosen period. Applicability: this was advisory only up to 31 March 2025 and is now required and fully assessed. Objective under the customized approach: systems with no known malware risk get re-evaluated at a frequency that matches the entity's risk. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.

Source: PCI DSS v4.0.1, 5.2.3.1. 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.

artefacts

held by a system

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 the analysis follows the 12.3.1 structure and was reviewed and approved · Document repository
Dated evaluation records showing the defined frequency was met over the assessment period · Document repository
Interview notes with the person performing the evaluations · Document repository

governing documentDocuments that govern the control

Targeted risk analysis document stating the evaluation frequency and the reasoning behind it · 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

Frequency chosen without any documented targeted risk analysis
Risk analysis exists but missing elements required by 12.3.1
Evaluations performed less often than the frequency the analysis sets

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

5.2.3 Periodic evaluation of components not at risk from malware · 5.3.1 Anti-malware kept current through automatic updates