EvidenceSheet
PCI DSS v4.0.1 · Appendix A3: Designated Entities Supplemental Validation (DESV)

A3.2.3 Scope review after organizational structure changes

Any change to the organizational structure must trigger a formal internal review of how it affects PCI DSS scope and which controls apply. Related PCI DSS requirement 12. Guidance: such changes include mergers, acquisitions, and major moves or reassignments of staff who own security controls, which can remove resources supporting controls or bring in new responsibilities without controls. 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, A3.2.3. 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
3
at each review
hard
to go live
Document repository
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

  • Policy clause requiring scope review on organizational change · Policy repository / GRC workspace
  • Impact review reports for recent reorganizations, mergers or acquisitions · Document repository
  • Updated control ownership records after reassignments · Document repository

governing documentDocuments that govern the control

  • HR or leadership change notifications routed to the compliance program · HR system / LMS

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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A3.2.2.1 Post-change confirmation that PCI DSS controls are in place · A3.2.4 Six-monthly penetration testing of segmentation controls