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

9.4.5.1 Annual inventories of electronic media

Inventories of electronic media holding cardholder data must be carried out at least every 12 months to confirm the media records remain accurate. Applicability: all entities holding cardholder data on electronic media. Customized approach objective: media inventories are periodically checked.

Source: PCI DSS v4.0.1, 9.4.5.1. 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.

4
artefacts
0
held by a system
2
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

  • Reconciliation of physical count against the inventory log, with discrepancies investigated · Physical access / facilities
  • Follow-up records for missing or unaccounted media · Data governance / DLP tooling

governing documentDocuments that govern the control

  • Procedure setting the 12-month inventory cycle · Policy repository / GRC workspace
  • Signed inventory count results dated within the last 12 months · 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

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.

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9.4.5 Inventory logs of electronic media · 9.4.6 Destruction of hard-copy materials