What evidence do auditors commonly ask for on A1.1.2 Customers limited to their own cardholder data and CDE?

Tenant access control policy and role model; IAM policy or RBAC configuration per tenant; Sample of tenant account privilege listings; Database or storage ACLs showing per-tenant scoping; Cross-tenant access test results.

What is the most common gap auditors find on A1.1.2?

Shared database schema relies only on application logic for tenant filtering

PCI DSS v4.0.1 · Appendix A1: Additional requirements for multi-tenant service providers

`A1.1.2` Customers limited to their own cardholder data and CDE

The provider must implement controls ensuring every customer is permitted to access only its own cardholder data and its own cardholder data environment (CDE), never another tenant's. Guidance example: in an IaaS-style offering the customer CDE may include virtual servers, virtual network devices, operating systems, files and memory that the customer configures and manages itself. Applies to multi-tenant service providers. Customized approach objective: one customer is unable to reach any other customer's environment.

Source: PCI DSS v4.0.1, A1.1.2. 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

IAM policy or RBAC configuration per tenant · Cloud console / configuration management

periodic reviewEvidence produced at each review

Sample of tenant account privilege listings · Identity provider / directory
Cross-tenant access test results · Source control / CI pipeline

governing documentDocuments that govern the control

Tenant access control policy and role model · Policy repository / GRC workspace
Database or storage ACLs showing per-tenant scoping · Document repository

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Cloud console / configuration management 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

Shared database schema relies only on application logic for tenant filtering
Wildcard IAM roles grant one tenant visibility of another tenant's storage buckets
Documentation defines tenant isolation but configurations were never checked against it

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

A1.1.1 Logical separation between provider and customer environments · A1.1.3 Customers restricted to their allocated resources