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

9.2.1 Facility entry controls for CDE systems

The entity must operate suitable facility entry controls that limit physical access to systems within the cardholder data environment. The guidance gives examples such as controls at each data center, computer room and other location holding CDE systems, badge readers, or lock and key backed by a current register of key holders, and advises that whichever mechanism is chosen be sufficient for the organization to confirm only authorized people gain entry. Applicability: does not cover locations that are open to consumers (cardholders). Customized approach objective: people without authorization are unable to physically reach CDE system components.

Source: PCI DSS v4.0.1, 9.2.1. 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.

5
artefacts
1
held by a system
2
at each review
hard
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

  • Badge reader configuration and access group listings for server rooms and data centers · Physical access / facilities

periodic reviewEvidence produced at each review

  • Observation notes from walkthrough of CDE entry points · Physical access / facilities
  • Third-party data center access reports for colocation cages · Physical access / facilities

governing documentDocuments that govern the control

  • Site plan or inventory of rooms and areas housing CDE systems with the entry control used at each · Policy repository / GRC workspace
  • Current key holder register for any areas secured by lock and key · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Physical access / facilities on a schedule; put the documents under version control with an owner and review date, and log each review 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

9.1.2 Requirement 9 roles and responsibilities assigned · 9.2.1.1 Monitoring of entry to sensitive areas