7.3.3 Access control default deny all
The access control systems must be configured to deny all access by default, so that nobody receives access unless a rule specifically grants it. The guidance warns that some products ship with an allow-all default that permits access until a deny rule is written, so checking the default configuration matters. Customized approach objective: privileges and access rights are forbidden unless explicitly permitted.
Source: PCI DSS v4.0.1, 7.3.3. 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.
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
- Configuration export or screenshot showing the default deny setting for each access control system · Identity provider / directory
periodic reviewEvidence produced at each review
- Test record showing a new account with no roles cannot reach protected resources · Identity provider / directory
governing documentDocuments that govern the control
- Vendor documentation describing default behaviour · Policy repository / GRC workspace
- Hardening standard requiring deny-all defaults · Policy repository / GRC workspace
First move
Common gaps auditors find
- Application authorization layer grants read access to any authenticated user by default
- File share permissions default to allowing everyone read access
- Default behaviour was never verified after a product upgrade
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 sheet7.3.2 Access control system enforces role-based permissions · 8.1.1 Requirement 8 policies and procedures maintained