EvidenceSheet

7.2.4 User accounts and privileges reviewed every six months

All user accounts and their related access privileges, including third-party and vendor accounts, must be reviewed at least every six months. The review must confirm that accounts and access remain appropriate for each person's job function, any inappropriate access must be dealt with, and management must acknowledge that the remaining access is appropriate. The guidance notes the review is also a chance to catch terminated users and third parties whose access was missed. Applicability: covers every user account and related privilege, including accounts of personnel, of vendors and of other third parties and accounts used to reach third-party cloud services; application and system accounts are handled instead by Requirement 7.2.5 (and its sub-requirement) and by 8.6.1 to 8.6.3. Objective under the customized approach: management periodically verifies that account privilege assignments are correct and remediates nonconformities. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.

Source: PCI DSS v4.0.1, 7.2.4. 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.

4
artefacts
1
held by a system
3
at each review
moderate
to go live
Identity provider / directory
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

  • Inventory of third-party, vendor and cloud-service accounts included in the review scope · Identity provider / directory

periodic reviewEvidence produced at each review

  • Semi-annual user access review records for each in-scope system, with review dates · Identity provider / directory
  • Evidence that inappropriate access found was removed or corrected, such as closed tickets · Identity provider / directory
  • Management sign-off acknowledging access remains appropriate · Identity provider / directory

governing documentDocuments that govern the control

none for this control

First move

Start with the 1 of 4 artefacts that already live in a system (Identity provider / directory); keep the periodic reviews but log each one 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

7.2.3 Privileges approved by authorized personnel · 7.2.5 Application and system accounts least privilege