What evidence do auditors commonly ask for on A3.2.6 Mechanisms to detect and block cleartext PAN leaving the CDE?

DLP policy and rule set for PAN patterns; DLP deployment coverage map (email, endpoint, removable media, print, web); DLP health and agent status report; Sample DLP alerts and audit logs with investigation notes.

What is the most common gap auditors find on A3.2.6?

DLP deployed in monitor-only mode, so nothing is blocked

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

`A3.2.6` Mechanisms to detect and block cleartext PAN leaving the CDE

The entity must have mechanisms that spot cleartext PAN leaving the CDE by any channel, method or process that is not authorized, and stop it; those mechanisms must be: running actively; configured to both detect and block such movements of cleartext PAN; and producing audit logs and alerts whenever such an outbound movement of cleartext PAN is spotted. Linked to the PCI DSS scoping section, Requirement 12. Guidance: coverage should include email, downloads to removable media and printing; DLP tools and manual procedures are typical examples. 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, A3.2.6. 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

Data governance / DLP 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

DLP policy and rule set for PAN patterns · Data governance / DLP tooling
DLP health and agent status report · Data governance / DLP tooling
Sample DLP alerts and audit logs with investigation notes · SIEM / log platform

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

DLP deployment coverage map (email, endpoint, removable media, print, web) · Policy repository / GRC workspace

First move

Automate the pull from your Data governance / DLP tooling. DLP policy hits, retention job logs and disposal certificates from the tooling.

Common gaps auditors find

DLP deployed in monitor-only mode, so nothing is blocked
Removable media or print channels not covered
Alerts generated but not reviewed by anyone

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

A3.2.5.2 Response procedures when cleartext PAN is found outside the CDE · A3.2.6.1 Response procedures for attempted removal of cleartext PAN