What evidence do auditors commonly ask for on A3.2.5 Data-discovery methodology for cleartext PAN?

Documented data-discovery methodology; Quarterly data-discovery scan reports including out-of-CDE systems; Tool configuration showing target systems and data stores; Change-triggered discovery run records; Findings register of cleartext PAN locations.

What is the most common gap auditors find on A3.2.5?

Discovery scans run only inside the defined CDE

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

`A3.2.5` Data-discovery methodology for cleartext PAN

A data-discovery methodology must be in place that: confirms PCI DSS scope; locates every source and location of cleartext PAN every three months at a minimum and after any significant change to the CDE or to processes; and addresses the possibility that cleartext PAN resides on networks and systems beyond the CDE as currently defined. Linked to the PCI DSS scoping section. Guidance: unexpected places include error logs or memory dumps, and methods may be commercial tools, in-house programs, manual searches, or a mix. 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, A3.2.5. 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

easy

to go live

Vulnerability scanner / patch tooling

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

Quarterly data-discovery scan reports including out-of-CDE systems · Vulnerability scanner / patch tooling
Tool configuration showing target systems and data stores · Cloud console / configuration management
Change-triggered discovery run records · Document repository

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

Documented data-discovery methodology · Document repository
Findings register of cleartext PAN locations · Policy repository / GRC workspace

First move

Automate the pull from your Vulnerability scanner / patch tooling. Scan schedule, findings and remediation age straight from the scanner; patch compliance from the patch console.

Common gaps auditors find

Discovery scans run only inside the defined CDE
Quarterly cadence missed or no run after major changes
Unstructured stores such as file shares and email archives excluded

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

A3.2.4 Six-monthly penetration testing of segmentation controls · A3.2.5.1 Annual confirmation of data-discovery effectiveness