What evidence do auditors commonly ask for on 9.1.1 Requirement 9 policies and procedures maintained?

Physical security policy and procedures covering facility access, visitors, media and POI devices, with version history and approval dates; Document review log showing updates made after process or facility changes; Distribution or acknowledgement records showing affected staff received the procedures; Interview notes from security, facilities and store staff describing how they apply the procedures.

What is the most common gap auditors find on 9.1.1?

Physical security policy last revised years ago and silent on POI devices or media destruction

PCI DSS v4.0.1 · Req 9: Restrict Physical Access

`9.1.1` Requirement 9 policies and procedures maintained

Every security policy and operational procedure called for under Requirement 9 (physical access, visitor handling, media protection and point-of-interaction device protection) must meet four conditions: it is written down; it is kept current; it is actually followed in daily operation; and every affected party knows about it. The guidance (not the requirement) suggests revising these documents soon after a change in processes, technology or business goals instead of only on a periodic cycle. Applicability: all entities assessed against PCI DSS. Customized approach objective: personnel understand and follow the expectations, controls and oversight for Requirement 9 activities, and those activities run in a repeatable, consistent way that reflects management intent.

Source: PCI DSS v4.0.1, 9.1.1. 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.

artefacts

held by a system

at each review

moderate

to go live

Physical access / facilities

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

Document review log showing updates made after process or facility changes · Physical access / facilities

periodic reviewEvidence produced at each review

Distribution or acknowledgement records showing affected staff received the procedures · HR system / LMS
Interview notes from security, facilities and store staff describing how they apply the procedures · Physical access / facilities

governing documentDocuments that govern the control

Physical security policy and procedures covering facility access, visitors, media and POI devices, with version history and approval dates · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (Physical access / facilities); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Physical security policy last revised years ago and silent on POI devices or media destruction
Procedures exist on an intranet but facilities or retail staff have never seen them
Documents describe a badge system or courier process that has since been replaced

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

8.6.3 System account passwords protected against misuse · 9.1.2 Requirement 9 roles and responsibilities assigned