A3.1.2 Formal PCI DSS compliance program elements
The entity must run a formal compliance program for PCI DSS that covers: defined activities to maintain and monitor overall PCI DSS compliance, BAU activities included; processes for the annual PCI DSS assessment; processes that validate PCI DSS requirements on an ongoing basis (daily, weekly or quarterly, for instance, as each requirement demands); and a business-impact analysis process that identifies how strategic business decisions could affect PCI DSS. Related PCI DSS requirements: all twelve. Guidance: the program may stand alone or sit inside a broader compliance or governance program with a well-defined methodology such as PDCA; strategic decisions worth analysing include acquisitions and mergers, buying new technology and new payment-acceptance channels. Applies only to designated entities. Objective under the customized approach: not eligible for the customized approach; only the defined approach can be used.
Source: PCI DSS v4.0.1, A3.1.2. 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.
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
- Annual assessment process description and last assessment timeline · Document repository
governing documentDocuments that govern the control
- Compliance program document and methodology · Document repository
- Compliance activity calendar listing daily, weekly, quarterly and annual tasks · Document repository
- Business-impact analyses performed for recent strategic decisions · Document repository
- Continuous validation dashboards or trackers · Policy repository / GRC workspace
First move
Common gaps auditors find
- Program covers the annual assessment but no continuous validation
- Strategic decisions (acquisitions, new channels) not run through a PCI DSS impact analysis
- Activity calendar exists on paper but is not tracked in practice
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 sheetA3.1.1 Executive management responsibility for the PCI DSS compliance program · A3.1.3 Defined and assigned PCI DSS compliance roles