EvidenceSheet

7.2.5.1 Application and system account access reviewed periodically

All access held by application and system accounts, together with their related privileges, must be reviewed periodically, at a frequency set by the entity's own targeted risk analysis carried out as Requirement 12.3.1 specifies. Each review must confirm that the account's access is still appropriate for the function it performs, address any inappropriate access, and record management's acknowledgement that the access remains appropriate. Objective under the customized approach: management periodically verifies that privilege assignments for application and system accounts 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, 7.2.5.1. 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.

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

  • Remediation tickets for excessive or unneeded service account privileges · Identity provider / directory

periodic reviewEvidence produced at each review

  • Targeted risk analysis defining the service account review frequency, prepared per 12.3.1 · Identity provider / directory
  • Completed service account review records at the defined frequency · Identity provider / directory
  • Management acknowledgement recorded for each review cycle · 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

7.2.5 Application and system accounts least privilege · 7.2.6 Query access to stored cardholder data restricted