EvidenceSheet
PCI DSS v4.0.1 · Req 6: Secure Systems and Software

6.2.3.1 Manual code review independence and approval

Where bespoke and custom software is reviewed manually before it goes to production, each code change must be: examined by someone other than the person who wrote it, who is knowledgeable about secure coding practice and techniques for reviewing code; and reviewed and approved by management before release. It applies to all entities that perform manual code reviews. Applicability: manual reviews may be carried out by knowledgeable internal staff or knowledgeable third parties; a person formally given accountability for release control, who is neither the author nor the reviewer, counts as management for this purpose. Objective under the customized approach: the manual review process cannot be skipped and reliably uncovers security vulnerabilities.

Source: PCI DSS v4.0.1, 6.2.3.1. 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.

5
artefacts
0
held by a system
4
at each review
hard
to go live
Source control / CI pipeline
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

  • Manual code review procedure defining reviewer qualifications and independence · Source control / CI pipeline
  • Review records showing reviewer identity differs from the commit author · Source control / CI pipeline
  • Management or release-controller approval records dated before production deployment · Source control / CI pipeline
  • Evidence of reviewer competence such as training records or review checklists · HR system / LMS

governing documentDocuments that govern the control

  • Designation of the individual holding release control accountability · 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

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

6.2.3 Code review before release · 6.2.4 Engineering techniques against common software attacks