A3.4.1 Six-monthly review of user accounts and access privileges
User accounts and access privileges on in-scope system components must be reviewed at least every six months so the reviewer can confirm they are still appropriate for each person's job function and that every access right has been approved. Related PCI DSS requirement 7. Guidance: the review is also a chance to catch accounts of terminated users and third parties whose access is no longer needed. 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, A3.4.1. 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
- Revocation tickets raised from review findings · Identity provider / directory
periodic reviewEvidence produced at each review
- Two most recent semi-annual access review reports with approver sign-off · Identity provider / directory
governing documentDocuments that govern the control
- User and privilege listings extracted for review · Policy repository / GRC workspace
- Third-party account list checked against active contracts · Policy repository / GRC workspace
First move
Common gaps auditors find
- Review covers only application accounts, not OS or database accounts
- Managers rubber-stamp access without checking job function
- Findings from the review not actioned within a reasonable time
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 sheetA3.3.3 Quarterly review that BAU activities are followed · A3.5.1 Methodology for prompt detection of attack patterns