A3.2.4 Six-monthly penetration testing of segmentation controls
Where segmentation is in use, PCI DSS scope must be confirmed by: following the entity's methodology defined in Requirement 11.4.1; pen-testing the segmentation controls every six months at a minimum and after any change to segmentation controls or methods; testing covering all segmentation controls and methods in use; and testing showing the controls are operational and effective and keep every out-of-scope system separated from the CDE. PCI DSS reference: Requirement 11. Guidance: base PCI DSS normally expects segmentation pen-testing every twelve months, and testing as often as possible is encouraged. Applies only to designated entities. Customized approach objective: not eligible for the customized approach; only the defined approach can be used.
Source: PCI DSS v4.0.1, A3.2.4. 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
- Change records for segmentation changes and matching retests · Vulnerability scanner / patch tooling
periodic reviewEvidence produced at each review
- Two most recent semi-annual segmentation penetration test reports · Vulnerability scanner / patch tooling
- Remediation and retest evidence for segmentation failures · Vulnerability scanner / patch tooling
governing documentDocuments that govern the control
- Penetration testing methodology per Requirement 11.4.1 · Policy repository / GRC workspace
- Inventory of segmentation controls and methods cross-referenced to test coverage · Policy repository / GRC workspace
First move
Common gaps auditors find
- Segmentation tested only annually as in the base standard
- Changes to firewall segmentation rules not followed by a retest
- Test omits some segmentation methods such as cloud security groups or VLAN ACLs
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 sheetA3.2.3 Scope review after organizational structure changes · A3.2.5 Data-discovery methodology for cleartext PAN