A3.3.3 Quarterly review that BAU activities are followed
Reviews must be carried out at least every three months, by PCI DSS compliance program personnel identified under A3.1.3, to verify BAU activities are followed. They must include: confirmation that all BAU activities, including those required by A3.3.1, A3.2.2 and A3.2.6, are happening; confirmation that staff follow security policies and operating procedures (for example reviewing logs each day, reviewing NSC rulesets, and applying configuration standards to newly built systems); documentation of how the reviews were done, including how each BAU activity was verified; collection of documented evidence needed for the annual assessment; review and sign-off of the results by compliance program personnel per A3.1.3; and retention of records and documentation covering all BAU activities for at least 12 months. Related PCI DSS requirements: all twelve. Guidance: the aim is to confirm activities occur, not to redo them. 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, A3.3.3. 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.
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
- Four most recent quarterly BAU review reports with sign-off · Document repository
- Evidence packs gathered for the annual assessment · Document repository
governing documentDocuments that govern the control
- BAU activity checklist covering A3.3.1, A3.2.2 and A3.2.6 tasks · Document repository
- Record retention schedule showing 12 months of BAU documentation · Policy repository / GRC workspace
- Notes explaining how each BAU activity was verified · Document repository
First move
Common gaps auditors find
- Reviews performed by the teams doing the work rather than compliance program staff
- Quarter missed, or intervals longer than three months
- Review records do not show how each activity was verified
- BAU records purged before 12 months
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 sheetA3.3.2 Annual review of hardware and software technologies · A3.4.1 Six-monthly review of user accounts and access privileges