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

6.5.5 No live PANs in pre-production

Live PANs must not be used in pre-production environments, unless those environments are inside the CDE and protected in line with every applicable PCI DSS requirement. A live PAN is a valid number issued by or for a payment brand, as opposed to a test number; the guidance notes that an expired card's PAN is often reissued with a new expiry date, and that it falls to the entity to confirm a PAN cannot transact or create fraud risk before treating it as out of scope. It applies to all entities. Customized approach objective: live PANs cannot exist in pre-production environments that sit outside the CDE.

Source: PCI DSS v4.0.1, 6.5.5. 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
0
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

  • Data discovery scan results for pre-production databases and file shares · Vulnerability scanner / patch tooling

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

  • Test data policy prohibiting live PANs in pre-production · Policy repository / GRC workspace
  • Test card numbers or synthetic data sets used by QA teams · Document repository
  • Masking or tokenisation procedure for any production data copied to test · Policy repository / GRC workspace
  • Scope documentation for any pre-production environment inside the CDE · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Vulnerability scanner / patch tooling 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.

Build my evidence sheet

6.5.4 Separate roles between production and pre-production · 6.5.6 Remove test data and accounts before production