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

9.3.1.1 Personnel access to sensitive areas controlled

Physical entry by personnel into CDE sensitive areas must be controlled so that: access is approved and tied to the person's job function; access ends at once when the person leaves; and every physical access mechanism (keys, access cards and the like) is disabled or handed back on departure. The guidance adds that, where possible, policies and procedures should have these items disabled or collected as early as practicable when someone leaves. Applicability: all entities with sensitive areas inside the CDE. Objective under the customized approach: personnel without authorization are unable to reach sensitive areas.

Source: PCI DSS v4.0.1, 9.3.1.1. 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.

5
artefacts
2
held by a system
2
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

  • HR termination records reconciled against badge deactivation timestamps · Physical access / facilities
  • Key and access card return log for leavers · Physical access / facilities

periodic reviewEvidence produced at each review

  • Access request approvals linked to role · Physical access / facilities
  • Sample of recent leavers showing same-day badge revocation · Physical access / facilities

governing documentDocuments that govern the control

  • Physical access control list for each sensitive area with job-function justification for every holder · Policy repository / GRC workspace

First move

Start with the 2 of 5 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

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

9.3.1 Personnel physical access procedures for the CDE · 9.3.2 Visitor access procedures for the CDE