What evidence do auditors commonly ask for on 9.4.5 Inventory logs of electronic media?

Electronic media inventory procedure; Current electronic media inventory log with identifiers, location and custodian; Evidence of inventory updates when media is created, moved or destroyed; Interview notes with media custodians.

What is the most common gap auditors find on 9.4.5?

Inventory tracks backup tapes but not removable drives or exported files on portable media

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

`9.4.5` Inventory logs of electronic media

The entity must keep inventory logs covering all electronic media that contains cardholder data. The guidance explains that without this, media that is lost or stolen might never be noticed. Applicability: all entities holding cardholder data on electronic media. Objective under the customized approach: the entity keeps an accurate record of the electronic media it stores.

Source: PCI DSS v4.0.1, 9.4.5. 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

SIEM / log platform

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

Current electronic media inventory log with identifiers, location and custodian · SIEM / log platform

periodic reviewEvidence produced at each review

Evidence of inventory updates when media is created, moved or destroyed · Data governance / DLP tooling
Interview notes with media custodians · Data governance / DLP tooling

governing documentDocuments that govern the control

Electronic media inventory procedure · Policy repository / GRC workspace

First move

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

Common gaps auditors find

Inventory tracks backup tapes but not removable drives or exported files on portable media
Log not updated when media is destroyed, leaving phantom entries
No single inventory, with each team keeping its own partial list

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

9.4.4 Management approval for media leaving facility · 9.4.5.1 Annual inventories of electronic media