What evidence do auditors commonly ask for on 7.3.2 Access control system enforces role-based permissions?

Group and role configuration exports from the access control system; Report of permissions assigned directly to individual accounts rather than via groups; Mapping of groups to job classifications and functions; Vendor documentation describing permission enforcement.

What is the most common gap auditors find on 7.3.2?

Numerous permissions granted directly to user objects, bypassing role groups

PCI DSS v4.0.1 · Req 7: Restrict Access by Need to Know

`7.3.2` Access control system enforces role-based permissions

The access control systems must be set up so that they enforce the permissions granted to people, applications and systems, with those permissions driven by job classification and function. The guidance explains that restricting privileged access through the access control system lowers the chance of mistakes when permissions are handed out. Customized approach objective: individual accounts receive their rights and privileges over systems, applications and data solely by inheriting them from the groups they belong to.

Source: PCI DSS v4.0.1, 7.3.2. 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.

artefacts

held by a system

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

Group and role configuration exports from the access control system · Identity provider / directory

periodic reviewEvidence produced at each review

Report of permissions assigned directly to individual accounts rather than via groups · Identity provider / directory

governing documentDocuments that govern the control

Mapping of groups to job classifications and functions · Policy repository / GRC workspace
Vendor documentation describing permission enforcement · Policy repository / GRC workspace

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

Numerous permissions granted directly to user objects, bypassing role groups
Groups are named for functions but contain permissions unrelated to that function
Application accounts receive ad hoc permissions not tied to a defined role

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

7.3.1 Need-to-know access control system covers all components · 7.3.3 Access control default deny all