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

6.5.4 Separate roles between production and pre-production

Roles and functions must be divided between production and pre-production environments so that accountability exists and only changes that have been reviewed and approved reach production. It applies to all entities. Applicability: where staff numbers are small and individuals hold several roles, the same aim can be met through extra procedural controls that create accountability; as an illustration, a developer could hold an elevated administrator account in development but a separate user-level account in production for developer tasks. Objective under the customized approach: job roles and accountability that distinguish pre-production work from production work are defined and managed to reduce the risk of unauthorised, unintentional or inappropriate actions.

Source: PCI DSS v4.0.1, 6.5.4. 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
1
held by a system
1
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

  • Production access list showing developers hold no or only user-level access · Identity provider / directory

periodic reviewEvidence produced at each review

  • Observation notes of a deployment demonstrating the approval gate · Source control / CI pipeline

governing documentDocuments that govern the control

  • Segregation of duties matrix for development, deployment and production administration · Policy repository / GRC workspace
  • CI/CD pipeline approval gates requiring reviewer approval before production deployment · Policy repository / GRC workspace
  • Documented compensating procedural controls for small teams · Document repository

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Identity provider / directory on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.

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.

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6.5.3 Separate pre-production from production · 6.5.5 No live PANs in pre-production