PCI DSS v4.0.1 is a detailed framework with specific guidelines on how organizations should protect cardholder data. The updated version includes enhancements and clarifications that address emerging security risks and technologies, ensuring that organizations stay ahead of evolving threats.
To understand the changes, we’ve reviewed the PCI DSS v4.0.1 Report on Compliance (ROC) reporting template that PCI Qualified Security Assessors (QSAs) use when assessing cardholder data environments. This helps us identify the new and updated testing requirements for compliance with PCI DSS v4.0.1.
We’ve compiled each piece of evidence from the ROC and aligned it with the relevant controls in Drata to provide clarity on what should be submitted when preparing for a PCI QSA audit under the new version of PCI DSS.
NOTE: This article was written for PCI DSS v4.0.1
Please note: An auditor may request additional evidence for each control.
DCF Code | PCI Requirement | Name | Example Evidence |
DCF-11 | 7.2.4, A3.4.1 | Periodic Access Review | Upload documentation of the most recent user access and permissions review.
Example: Screenshots of the user lists and permissions reviewed, evidence of sign-offs or approvals by at least two individuals (SOD), documentation of changes requested if any, and evidence that the changes requested were implemented.
The scope of the review should be discussed with your auditor as different auditors may have different expectations (based on the scope of the assessment, relevant framework(s), etc.) Auditors will generally require to see the following: - Evidence of the review inputs (what artifacts were reviewed?) such as screenshots of user lists with permissions. - Evidence that segregation of duties was maintained (e.g., two individuals sign-off the review so that no reviewer is approving their own access). - Changes identified were implemented (e.g., tickets documenting removal of accounts, updated user lists showing modifications in permissions, etc.) Auditors would generally expect to see these review activities done at least annually, with quarterly frequency being the most common. Auditors may also expect that the user access review includes a review of physical access rights, if applicable (e.g., reviews of active personnel in the badge system, etc.) |
DCF-22 | 1.2.3 | Network Diagram | Upload evidence of your current network diagram(s) and evidence of updates/reviews within the past year for accuracy (e.g., emails from responsible personnel confirming the accuracy and completeness of the network diagram(s), etc.) |
DCF-30 | 12.10.6, A3.5.1 | Incident response Lessons Learned | For an example security event deemed an incident, upload the incident documentation including evidence of internal tracking (e.g., internal ticket), root-cause analysis (RCA)/post-mortem, lessons learned, etc. |
DCF-56 | 12.8.1, 12.8.2 | Vendor Register & Agreements | Upload evidence of an example executed agreement with a vendor or service provider. |
DCF-57 | 12.8.4 | Vendor Compliance Monitoring | Screenshots from the vendor directory showing that vendors are categorized based on impact/risk. or Review documents showing that vendors’ SOC2 reports were reviewed (Drata can provide a review template for this). |
DCF-61 | 1.1.3 | Customer Data Segregation | Upload evidence showing customer data is segregated.
Example: screenshots from the database showing that unique identifiers are used to associate data to a specific customer, screenshots showing that separate databases/storage buckets are used for individual customers, etc. |
DCF-62 | 8.2.9 | Session Termination | Upload evidence of automated logoff for relevant systems/applications. For example: 1. Screenshots of users being logged out of the application when browser/tab is closed and being forced to re-authenticate upon next login. 2. Screenshots showing that a user is logged out after pre-defined activity timeout and being forced to authenticate upon next login (including application messages, parameters in the application code defining the inactivity period, etc.)
Relevant systems may include company-developed web applications and any system or application in use that allows for configuration of automated logoffs. If applicable, discuss scope with your chosen auditor. |
DCF-69 | 7.2.3, 7.2.2, 9.3.1.1, 9.3.1, 7.3.2, 7.2.1 | Access Provisioning | Upload an example record of access request and approval for a user to be granted permission to a system.
Example: Access request ticket with documented approval from system owner or manager, etc.
A process to request and approve user accounts and permissions must be in place. Auditors may request evidence of new hire access requests as well as request for changes in permissions to existing users (e.g., transfers, new administrative users, additional permissions to specific resources such as databases or repositories). |
DCF-106 | 9.4.1 | Clean Desk and Clear Screen Policies and Procedures | 1. Acceptable Use Policy -and- 2. (If applicable) Acknowledgement of the Acceptable Use Policy |
DCF-107 | 9.4.6 | Disposal of Sensitive Data on Paper | Observation of hard copy materials being disposed of. Note: This can be performed by auditors on-site or via virtual meeting. |
DCF-108 | 9.4.6, 9.4.1 | Secure Storage Mechanisms | Pictures of secure storage bins from office locations. |
DCF-150 | A3.2.6 | Data Loss Prevention (DLP) Mechanism | Upload evidence of the data leakage prevention (DLP) measures implemented in the organization (e.g., screenshots of DLP rules implemented in corporate email service, configurations from DLP tools in place, etc.) |
DCF-156 | 6.5.4, 6.2.3.1 | Change Releases Approved | For an example change release, upload evidence showing that the release was approved by authorized personnel prior to deployment to production (e.g., screenshot of a pull request/ticket showing approval for a release candidate by authorized personnel). |
DCF-171 | 1.1.1, 12.10.2, 2.1.1, 3.1.1, 4.1.1, 5.1.1, 6.1.1, 7.1.1, 8.1.1, 9.1.1, 10.1.1, 11.1.1
| Documented Operating Procedures | Upload examples of your documented operating procedures for information security activities/controls.
Documented procedures should be prepared for the organization’s operational activities associated with information security, for example: - when the activity needs to be performed in the same way by many people; - when the activity is performed rarely and when next performed the procedure is likely to have been forgotten; - when the activity is new and presents a risk if not performed correctly; and, - prior to handing over the activity to new personnel. |
DCF-188 | 6.3.1 | Communication with Advisor and Special Interest Group | Upload evidence showing that the organization and members of management maintain contact with special interest groups (e.g., security groups, privacy groups, etc.).
For example, screenshots or exports showing members of management receive newsletters and updates from professional association groups, email alerts from security advisories such as CISA, participation in conferences, threat advisories, etc.
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DCF-522 | 5.3.3 | Anti-Malware Scans of Media | Upload evidence showing that the implemented anti-malware solution is configured to perform automatic scans or continuous behavioral analysis of systems or processes when removable electronic media is inserted, connected, or logically mounted within the environment.
Example: Screenshots showing configuration settings from the anti-malware system showing settings for anti-malware scans of media. |
DCF-523 | 4.2.1.1 | Inventory of Trusted Keys and Certificates to Protect PAN During Transmission | Upload evidence showing the inventory of trusted keys and certificates used to protect PANs during transmission. This should include details such as issuing authority, expiration date, and usage.
Example:
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DCF-524 | 7.2.5.1 | Period Review of Application and System Accounts | Upload documentation showing records of periodic reviews of application and system accounts, including dates and details of each review. This should outline the accounts reviewed, associated privileges, and any changes made, such as access modifications or account removals.
Example:
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DCF-525 | 3.4.2 | Technical Controls to Prevent Copy/Relocation of PAN | Upload documentation such as policies, procedures, and configuration settings detailing technical controls to prevent the copy or relocation of Primary Account Numbers (PAN) on local hard drives or removable storage media during remote access. Example:
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DCF-557 | 8.2.2 | Shared Account Management | For any highly privileged shared accounts, upload evidence of the business justification and evidence of how these shared accounts are securely managed.
Example: Documentation of the business purpose of the shared account(s) with management approval and screenshots showing how the shared accounts are securely managed (e.g., through password vaults restricted to specific personnel, etc.). |
DCF-562 | 5.3.5 | Management of Utility Programs | Upload screenshots or exports of user lists (with a screenshot of parameters used for exporting) showing the users with administrative or privileged access to the systems (e.g., super users, administrators, power users, etc.) for relevant systems. Relevant systems may include cloud infrastructure provider, code repositories, identity provider, password vault systems, VPN clients, systems with stored customer data (e.g., database as a service), utility programs (e.g., antivirus consoles) and others based on the scope of the engagement. Discuss system scope with your chosen auditor. |
DCF-637 | 6.2.1 | Secure Development Process | Upload documentation of your organization's secure development processes.
Example: Internal wikis or other documentation that includes references to industry standards and/or best practices for secure development, security requirement considerations (for example, secure authentication and logging, etc.), and consideration of information security issues during each stage of the software development life cycle. |
DCF-681 | 12.6.3, 5.4.1 | Phishing Simulations | Upload evidence showing phishing simulations are conducted as part of the company's security awareness initiatives.
Example: Screenshots from phishing simulation campaign configurations, screenshots of dashboards showing results of the campaign, screenshot showing example simulated phishing email, etc. |
DCF-682 | 1.1.2, 2.1.2, 3.1.2, 4.1.2, 5.1.2, 6.1.2, 7.1.2, 8.1.2, 9.1.2, 10.1.2, 11.1.2
| Roles and Responsibilities for PCI DSS Compliance | Upload evidence to demonstrate that roles and responsibilities for PCI DSS compliance activities are documented, assigned, and reviewed at least annually, with acknowledgment from relevant personnel. Example:
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DCF-683 | 8.3.10.1 | Password Expiration Periods for Customer User Access | Upload evidence to demonstrate compliance with the PCI DSS requirement for either enforcing a 90-day password change policy or implementing dynamic access controls based on real-time security posture. Example:
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DCF-685 | 12.6.2 | Review of Security Awareness Program | Upload evidence demonstrating that your organization has a process in place to review and update the security awareness program annually, and that the program addresses new threats and vulnerabilities impacting the security of your environment and the protection of sensitive data. Examples:
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DCF-686 | 12.3.1, 12.10.4.1, 9.5.1.2.1, 10.4.2.1, 5.2.3.1, 5.3.2.1, 11.3.1.1
| PCI Targeted Frequency Risk Analysis | Upload the Risk analysis report that includes identification of assets, threats, factors contributing to likelihood and impact, and frequency justification for PCI DSS activities. |
DCF-687 | 5.4.1 | Email Protection Mechanisms | Upload evidence showing that phishing and spam detection mechanisms have been implemented in your organization.
Example: Screenshots showing SPF, DMARC, DKIM configurations enabled for email authentication. |
DCF-688 | 9.3.1.1, 9.3.1 | Return of Assets | For one recently terminated personnel, upload evidence showing that assets were returned to the company.
Example: Screenshots of offboarding checklists or internal tickets showing tracking of return of devices, badges, tokens, etc., upon termination, evidence of pre-paid labels sent to remote personnel for asset return and tracking, etc. |
DCF-689 | 12.10.3 | On-Call Team | Upload evidence of on-call rotation schedule.
Example: Screenshots from tools like PagerDuty or equivalent tool showing on-call schedule and teams assigned. |
DCF-690 | 12.3.2 | PCI Targeted Customed Approach Risk Analysis | Upload Targeted Risk Analysis document. |
DCF-698 | 10.4.1.1, A3.5.1 | Automated Mechanism for Audit Log Reviews | Upload evidence to demonstrate that your organization has implemented automated mechanisms for audit record reduction and log analysis. Examples:
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DCF-699 | 11.3.1.2 | Authenticated Scanning for Internal Vulnerability Scans | Upload vulnerability scan reports showing authenticated scans with credentials that have sufficient privileges, along with the company's credential management policies. Examples:
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DCF-700 | A3.3.2, 12.3.4 | Review of PCI Hardware and Software | Provide documentation of the annual review of hardware and software technologies, including a list of technologies evaluated and the findings of the review. Examples:
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DCF-701 | A3.2.3, 12.5.3 | Review of PCI Requirements Upon Organizational Structure Changes | Upload documentation of the formal internal review process for assessing the impact of organizational changes on PCI DSS scope and controls. Examples:
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DCF-702 | 12.5.2 | PCI Scope Validation (Annual) | Upload documentation of the formal review of the PCI DSS scope conducted at least annually or following significant environmental changes. Examples:
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DCF-703 | 12.5.2.1 | PCI Scope Validation for Service Providers (Semi-Annual) | Provide documentation of the formal review of the PCI DSS scope conducted at least every six months or following significant changes to the environment. Results of the review, including any changes, must be documented and retained. Examples:
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DCF-704 | A3.1.4 | PCI Compliance Training | Provide documentation showing that PCI DSS or specialized information security training is provided to all personnel with PCI DSS responsibilities at least once every 12 months. Include records of training attendance and the content covered. Examples:
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DCF-705 | A3.2.1 | PCI Scope Validation for Designated Entities (Quarterly) | Upload formal review documentation showing that the PCI DSS scope is performed at least once every three months and after significant environmental changes. Include records of the review and any changes, along with documentation of the results. Examples:
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DCF-706 | A1.1.1 | Multi-Tenant Segregation Between Provider and Customer | Provide documentation showing that logical separation is implemented for multi-tenant service providers. Examples:
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DCF-707 | 8..6.2 | Credentials for System Accounts Not Hard-Coded | Upload evidence showing that the organization has implemented mechanisms to validate that authentication credentials for any application and system accounts are not hard coded in scripts, configuration/property files, or bespoke and custom source code.
Example: Screenshots from source code repositories showing secret scanning is conducted as part of the CI/CD pipeline. |
DCF-708 | 6.3.2 | Software and Third Party Libraries Inventory | Upload evidence of your organization's software and third party libraries Inventory (i.e., software bill of materials).
Example: Screenshots from software composition analysis tools showing software bill of materials (SBOM). |
DCF-709 | 11/5/1/1 | IDS/IPS Addresses Covert Malware | Provide evidence of intrusion-detection and/or intrusion-prevention mechanisms that detect and alert on covert malware communication channels, such as DNS tunneling. Examples:
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DCF-710 | 11.4.7 | Multi-Tenant Service Provider Supports Customer Pentest Requests | Provide documentation showing access granted to customers for conducting tests or providing evidence of comparable testing. Examples:
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DCF-711 | A1.2.2 | Incident Procedures Support Customers Forensic Investigations | Provide evidence of documented processes or mechanisms that support a prompt forensic investigation of servers in the event of a suspected or confirmed security incident for any customer. Examples:
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DCF-712 | 6.2.3, 6.2.4 | Static Application Security Testing | Upload evidence that static application security testing (SAST) is conducted for software development testing.
Example: Screenshots from the CI/CD pipeline for relevant code repositories showing a SAST scan automatically executes every time new code is committed, screenshots of configurations and dashboards from SAST tools such as SonarCloud, etc. |
DCF-713 | 9.2.4 | Consoles in Sensitive Areas Locked | Upload evidence that console login screens for physical consoles in sensitive areas are locked to prevent unauthorized use. Examples:
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DCF-714 | 8.2.4 | Lifecycle Events for Users IDs and Authentication Factors Authorized | Upload evidence that changes to user IDs, authentication factors, and other identifier objects are made only with documented management approval. Examples:
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DCF-715 | 6.5.5 | Live PANs Not Used Outside of CDE | Provide evidence that live PANs are not used in pre-production environments unless those environments are within the scope of the PCI compliance program. Examples:
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DCF-716 | 7.2.5 | Application and System Accounts Authorized | Upload company’s access control policies, access request forms or approval tickets, access logs demonstrating privileges align with system needs, signed management approval for provisioning access, and periodic access review records. Examples:
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DCF-717 | 8.3.11 | Unique Authentication Factors | Upload records showing how authentication factors (e.g., tokens, smart cards, certificates) are assigned to individual users. Include logs, spreadsheets, and related policies or procedures. Also, provide screenshots or records showing physical or technical controls (e.g., PINs, biometrics) to ensure only the intended user can access these factors. Examples:
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DCF-718 | A2.1.1 | SSL and Early TLS Vulnerability Verification | Upload records or reports showing that the POS and POI terminals using SSL and/or early TLS have been inspected for known vulnerabilities. This may include vendor documentation, system configuration details, or network configuration reports that confirm the devices are not susceptible to known exploits. Can also provide screenshots or logs from security scanning tools or vulnerability assessment reports that demonstrate the inspection process. Additionally, include any related policies or procedures that outline how these inspections are performed and how evidence of compliance is retained. |
DCF-719 | A2.1.3 | SSL and Early TLS Secure Service Offering | Upload documentation showing the secure service offering provided to upgrade point-of-interaction (POI) terminals that use SSL and early TLS. This could include upgrade plans, project timelines, or communications that outline how and when the POIs will be upgraded to eliminate vulnerabilities associated with these protocols. Additionally, you may provide any vendor or third-party documentation that supports the upgrade process, as well as logs or records showing the completion of upgrades for affected terminals. |
DCF-720 | 11.6.1 | Unauthorized Changes on Payment Pages Detected | Upload screenshots of configuration settings showing the mechanism’s parameters, logs or reports that show alerts being triggered for unauthorized changes, and evidence of the periodic evaluation of the HTTP header and payment page, such as scan or review schedules based on the entity's targeted risk analysis.
Additionally, provide evidence such as system reports that demonstrate that the mechanism is evaluated at least weekly or as specified by the risk analysis. |
DCF-721 | 6.4.3 | Payment Page Scripts Inventory and Verification | Upload the inventory of all payment page scripts loaded in the consumer's browser, including a list of scripts and their business or technical justifications. Provide evidence of mechanisms confirming that the scripts are authorized, such as access control logs or approval workflows. To show script integrity, include reports or documentation demonstrating how integrity checks (e.g., hashes, digital signatures) are conducted and the tools or processes used to prevent tampering. Examples:
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DCF-722 | 12.9.2 | Service Provider Responds to PCI DSS Information Requests from Customers | Upload documentation such as a PCI DSS compliance status report that outlines your current compliance standing. Include a responsibility matrix (e.g., RACI) that clearly defines which PCI DSS requirements are your organization’s responsibility, the customer’s responsibility, and those that are shared. Examples:
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DCF-723 | A1.2.1 | Multi-Tenant Customers Log Availability | Upload the Audit Logging Policy or Log Management Policy, which outlines how audit logs are enabled by default for each customer’s environment. Include access control logs or permission settings that demonstrate log access is restricted to the owning customer. Provide customer-facing documentation (e.g., emails or notices) confirming that log locations are communicated to customers. Examples:
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DCF-724 | 12.10.7, A3.2.5.2 | Incident Response Procedures When Cleartext PAN Detected | Upload the Incident Response Policy or Incident Response Procedures document, which outlines the processes for responding to, analyzing, and addressing situations where cleartext PAN is detected in unexpected locations. Include records of past incidents or test scenarios demonstrating adherence to the documented procedures. Provide evidence of staff training or awareness regarding the detection and handling of cleartext PAN, if applicable. Examples:
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DCF-725 | 8.5.1 | MFA Configured to Prevent Misuse | Upload the MFA Policy or Configuration Procedure detailing how replay attacks are prevented, two-factor authentication is required, and MFA bypass is restricted. Include screenshots of system settings that show alignment with the policy. Also, provide documentation for any exceptions authorized by management, including justification and timeframes. Examples:
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DCF-726 | 8.6.1 | Interactive Use of System and Application Accounts Managed | Include screenshots of system settings that restrict interactive login, along with signed approval forms or emails for exceptional access. Provide business justification documentation and audit logs showing individual user actions taken during those exceptions. Examples:
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DCF-727 | 8.6.3 | Passwords for System and Application Accounts Changed Periodically | Provide the "Password Management Policy" or "Access Control Policy" that outlines password change procedures based on the entity's risk analysis and after a compromise. Examples:
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DCF-728 | A3.1.3 | Roles and Responsibilities for PCI DSS Compliance for Designated Entities | Upload a "PCI DSS Compliance Responsibility Policy" or "Roles and Responsibilities Matrix" that documents and assigns roles for PCI DSS activities. This should include responsibilities for ongoing compliance activities, assessments, and business-impact analysis. Example evidence:
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DCF-729 | A.3.1.2 | Formal PCI DSS Compliance Program in Place | Upload documentation of the compliance program, including detailed processes and examples of business-impact analysis reports. This should include meeting notes or discussions that address the PCI DSS impacts on business decisions. |
DCF-730 | 1.5.1 | Security Controls on Devices that Connect to the Internet | Evidence:
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DCF-731 | A3.2.5 | Documented PAN Discovery Methodology | Upload a document detailing the approach for identifying cleartext PAN within the environment, including both automated and manual mechanisms used. Examples:
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DCF-732 | 12.3.3 | Review of Cryptographic Suites and Protocols | Upload an inventory document that lists all cipher suites and protocols in use, including their purpose and where they are used within the environment. Examples:
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DCF-733 | A3.3.3 | Review of Business as Usual Activity | Upload documents such as the review records that show the reviews were performed every three months, including the names of personnel assigned to the PCI DSS compliance program. Examples:
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DCF-734 | A3.2.6.1 | Incident Response Procedures for Cleartext PAN Removal | Upload the documented incident response procedures that outline the steps to take when cleartext PAN is detected being removed from the CDE via unauthorized methods. Examples:
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DCF-735 | A2.1.2 | Migration Plan in Place for SSL and Early TSL POS POI | Upload the documented risk mitigation and migration plan that outlines the steps for addressing existing connection points to POS/POI terminals using SSL and/or early TLS. Examples:
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DCF-736 | A3.2.5.1 | PAN Discovery Mechanisms Assessed | Upload the documented process that outlines how the methods for data discovery are tested to ensure the effectiveness of identifying cleartext PAN. Examples:
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DCF-737 | 3.6.1.2 | Protected Storage of Secret and Private Keys for Account Data | Upload evidence related to secret and private keys stored in a secure cryptographic device (SCD). Examples:
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DCF-738 | 3.5.1.1 | Keyed Cryptographic Hashes of PAN | Upload evidence related to the management of keyed cryptographic hashes for PAN. Examples:
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DCF-739 | A3.2.2 | PCI DSS Scope Impact Assessment | Upload evidence related to the PCI DSS scope impact assessment for system or network changes. Examples:
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DCF-740 | 1.1.1, 2.1.1, 3.1.1, 4.1.1, 5.1.1, 6.1.1, 7.1.1, 8.1.1, 9.1.1, 10.1.1, 11.1.1
| PCI DSS Compliance Policy | Upload evidence of the documented policy outlining the company's requirements and activities related to PCI DSS compliance. Example:
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DCF-741 | 10.2.1 | Logging and Monitoring Policy | Upload Logging and Monitoring Policy. |
DCF-784 | 6.3.2 | Software Composition Analysis (SCA) | Upload evidence to show that your organization checks software components and libraries for policy and license compliance, security risks, and supported versions.
Example: Screenshots showing that software composition analysis tools are used as part of your CI/CD pipeline to check for vulnerabilities in third party libraries. |
DCF-814 | 6.5.1, 1.2.2 | Security Impact Assessment for Changes | Upload evidence of the documented process for evaluating the security impact of system changes and validating security requirements after implementation. Examples:
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DCF-832 | 12.8.3 | Review of Agreements and Contracts | Upload evidence of the process for reviewing third-party agreements for PCI DSS compliance. Examples:
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