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Commerce Security Authority

PCI DSS v4.0 · Requirement 3 Key Management

Know exactly what your QSA will pull on key management

Signed custodian forms, ceremony scripts, attendance logs, HSM co-authentication, the evidence assessors request, listed.

Get the reference guide

The real finding

The finding isn't the algorithm, it's the evidence

Teams securing cardholder data know they need strong encryption. But PCI DSS v4.0 Requirement 3 hinges on key management discipline, and that is where most assessment findings actually surface. If you can't produce the ceremony records and custodian forms your assessor expects, dual control and documented lifecycles become gaps you discover mid-assessment. This reference tells you what to have on file before the QSA asks.

Inside the reference

What's inside the 17-page reference

The exact audit evidence assessors request for dual control compliance
Signed custodian acknowledgment forms, ceremony scripts, and attendance logs, explained
Requirement 3.6.1 / 3.7.1 / 3.7.2 obligations at a glance
A controls-to-scope matrix tying each control to its PCI DSS v4.0 requirement
Operational patterns for KEK loading, HSM init, backup, and destruction ceremonies
The documentation your key register must contain to survive review

Before the assessment

What this lets you do before the assessment

Assemble evidence before they ask

Walk in with the artifacts assessors pull already gathered, rather than scrambling for them during fieldwork.

Trace every control to a citation

Point to which requirement each control satisfies, from 3.5.1 through 3.7.6, without guessing what a finding would hinge on.

Settle acceptable-vs-not questions fast

Decide algorithms, key lengths, AES modes, and storage methods against concrete tables instead of vague guidance.

Cover the whole key lifecycle

Work from entropy and generation through rotation, retirement, and compromise response, so no phase is left undocumented.

Grounded in the standards

Grounded in the standards your assessor uses

Cited requirements

Cites PCI DSS v4.0 Requirements 3.5.1, 3.6.1, 3.7.1, 3.7.2, and 3.7.6 throughout.

Named standards

References FIPS 140-2/140-3, NIST SP 800-90A (DRBG), NIST SP 800-186 (curves), ANSI X9.24, PKCS#11, RFC 3394, and TR-39.

Structured tables

Reference tables for algorithms and key lengths, AES modes, key hierarchy roles, crypto-periods, and controls-to-scope mapping.

Frequently asked

It aligns to PCI DSS v4.0 Requirement 3 specifically, including the 3.7.x key management obligations and the definition of strong cryptography introduced in v4.0.

PCI DSS v4.0 Requirement 3

Have the evidence ready before your QSA asks

Get the 17-page reference and know exactly which key management artifacts your assessor will pull. Written for practitioners, not marketers.