What evidence do auditors commonly ask for on 9.1.2 Requirement 9 roles and responsibilities assigned?

RACI matrix or role descriptions covering physical access, visitor management, media handling and POI inspection; Job descriptions or assignment letters naming owners of badge administration and media custody; Signed acknowledgements by role holders of their physical security duties; Interview records with facilities, security and store managers confirming their responsibilities.

What is the most common gap auditors find on 9.1.2?

No named owner for POI device inspections across stores

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

`9.1.2` Requirement 9 roles and responsibilities assigned

The duties involved in carrying out Requirement 9 activities must be written down, allocated to named roles or people, and understood by those who hold them. The guidance notes that roles may be recorded inside the policies and procedures or in separate documents, offers a responsibility assignment (RACI) matrix as one method, and suggests entities consider having staff acknowledge their assigned duties. Applicability: all entities. Customized approach objective: day-to-day duties for every Requirement 9 activity are allocated, and the people holding them are accountable for keeping these controls operating successfully and continuously.

Source: PCI DSS v4.0.1, 9.1.2. 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

hard

to go live

Policy repository / GRC workspace

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

none for this control

periodic reviewEvidence produced at each review

Signed acknowledgements by role holders of their physical security duties · Physical access / facilities
Interview records with facilities, security and store managers confirming their responsibilities · Physical access / facilities

governing documentDocuments that govern the control

RACI matrix or role descriptions covering physical access, visitor management, media handling and POI inspection · Policy repository / GRC workspace
Job descriptions or assignment letters naming owners of badge administration and media custody · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

No named owner for POI device inspections across stores
Badge administration handled informally by reception with no documented responsibility
Role holders unable to describe the Requirement 9 tasks allocated to them

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

9.1.1 Requirement 9 policies and procedures maintained · 9.2.1 Facility entry controls for CDE systems