PCI PIN Security v3.1

PIN Security Requirements:
1-2 Key-injection facilities must only inject keys using equipment that conforms to the requirements for SCDs.
Testing Procedures:
1-2. Examine documented procedures and system documentation to verify that key-injection platforms and systems used for managing cryptographic keys are required to conform to the requirements for SCDs. 

PIN Security Requirements:
1-3 Ensure that all hardware security modules (HSMs) are either: 

PIN Security Requirements:
1-4 The approval listing must match the deployed devices in the following characteristics: 

1-4.a For all PCI-approved HSMs used, examine HSM devices and examine the PCI SSC list of Approved PCI PTS Devices to verify that all of the following device characteristics match the PCI PTS listing for each HSM: 

1-4.b For all FIPS-approved HSMs used, examine HSM devices and review the NIST Cryptographic Module Validation Program (CMVP) list to verify that all of the following device characteristics match the FIPS140-2 or FIPS 140-3 Level 3 (or higher) approval listing for each HSM: 

PIN Security Requirements:
1-5 The KIF platform provider maintains documentation detailing the KIF architecture and key-management flows. The platform provider must: 

1-5.a Interview relevant personnel and examine documentation to verify that procedures exist for maintaining documentation that describes and/or illustrates the architecture of the KIF.
1-5.b Interview relevant personnel and examine documentation that describes and/or illustrates the architecture of the KIF to verify that all KIF components, key-management flows, and personnel interaction with key-management flows are identified and documented.
1-5.c Examine the key-management flows and interview personnel to verify: 

PIN Security Requirements:
5-1 Keys must be generated so that it is not feasible to determine that certain keys are more probable than other keys from the set of all possible keys. Generation of cryptographic keys or key components must occur within an SCD. They must be generated by one of the following: 

Note: Random number generation is critical to the security and integrity of all cryptographic systems. All cryptographic key-generation relies upon good quality, randomly generated values.
Testing Procedures:
5-1.a Examine key-management policy documentation to verify that it requires that all devices used to generate cryptographic keys meet one of the following 

5-1.b Examine certification letters or technical documentation to verify that all devices used to generate cryptographic keys or key components meet one of the following 

5-1.c Examine procedures to be used for future generations and logs of past key generations to verify devices used for key generation are those as noted above, including validation of the firmware used. 

PIN Security Requirements:
6-1.1 Any clear-text output of the key-generation process must be managed under dual control. Only the assigned custodian can have direct access to the clear text of any key component/share. Each custodian’s access to clear-text output is limited to the individual component(s)/share(s) assigned to that custodian, and not the entire key.
6-1.1.a Examine documented procedures to verify the following: 

6-1.1.b Observe key-generation process demonstration and interview responsible personnel to verify: 

PIN Security Requirements:
6-1.2 There must be no point in the key-generation process where a single individual has the ability to determine, obtain, or ascertain any part of a clear-text key or all the components for a key.
Note: Key shares derived using a recognized secret-sharing algorithm or full-length key components are not considered key parts and do not provide any information regarding the actual cryptographic key.
Testing Procedures:
6-1.2.a Examine documented procedures for all key-generation methods and observe demonstrations of the key-generation process from end to end to verify there is no point in the process where a single person has the ability to determine, obtain, or ascertain any part of a clear-text key or all the components for a key.
6-1.2.b Examine key-generation logs to verify that: 

PIN Security Requirements:
6-1.3 Devices used for generation of clear-text key components that are output in the clear must either be powered off when not in use or require re-authentication whenever key generation is invoked.
Logically partitioned devices used concurrently for other processes— e.g., providing services simultaneously to host systems, such as for transaction processing—must have key-generation capabilities disabled when not in use and other activities are continuing.
Testing Procedures:
6-1.3 Examine documented procedures for all key-generation methods. Verify procedures require that: 

PIN Security Requirements:
6-1.4 Key-generation equipment used for generation of clear-text key components must not show any signs of tampering (for example, unknown cables) and must be inspected prior to the initialization of key-generation activities. Ensure there isn’t any mechanism that might disclose a clear-text key or key component (e.g., a tapping device) between the key-generation device and the device or medium receiving the key or key component.
Note: This does not apply to logically partitioned devices located in data centers that are concurrently used for other purposes, such as transaction processing.
Testing Procedures:
6-1.4.a Examine documented procedures for all key-generation methods to verify they include inspections of the key-generation equipment for evidence of tampering, prior to use⎯including verification that there is a validation step to ensure no unauthorized mechanism exists that might disclose a clear-text key or key component (e.g., a tapping device).
6-1.4.b Observe key-generation set-up processes for all key types to verify that key-generation equipment is inspected prior to use, to ensure equipment does not show any signs of tampering⎯including verification that there is a validation step to ensure no unauthorized mechanism exists that might disclose a clear-text key or key component (e.g., a tapping device). 

PIN Security Requirements:
6-3.1 The room must have walls made of solid materials. The walls do not have to extend from true floor to true ceiling but do need to extend from floor to ceiling.
Testing Procedures:
6-3.1 Inspect the secure room designated for printing clear-text key components to verify that the walls are made of solid materials and extend from floor to ceiling. 

PIN Security Requirements:
6-3.2 Any windows into the secure room must be: 

6-3.2.a Observe all windows in the secure room to verify they are: 

6-3.2.b Examine configuration of window sensors to verify that the alarm mechanism is active. 

PIN Security Requirements:
6-3.3 An electronic access control system (for example, badge and/or biometrics) must be in place that: 

Testing Procedures:
6-3.3.a Observe authorized personnel entering the secure room to verify that a badge-control system is in place that enforces the following requirements: 

6-3.3.b Examine alarm mechanisms and interview alarm-response personnel to verify that the badge-control system supports generation of an alarm when one person remains alone in the secure room for more than 30 seconds. 

PIN Security Requirements:
6-3.4 CCTV cameras must record all activity, including recording events during dark periods through the use of infrared CCTV cameras or automatic activation of floodlights in case of any detected activity. This recording may be motion-activated, in which case the recording must continue for at least a minute after the last pixel of activity subsides.
Testing Procedures:
6-3.4 Inspect CCTV configuration and examine a sample of recordings to verify that CCTV monitoring is in place on a 24/7 basis, including the ability to record events during dark periods, and verify that, if motion-activated, recording continues for at least a minute after the last pixel of activity subsides. 

PIN Security Requirements:
6-3.5 Monitoring must be supported on a continuous (24/7) basis such that alarms can be resolved by authorized personnel.
Testing Procedures:
6-3.5 Inspect configuration of monitoring systems and interview monitoring personnel to verify that monitoring is supported on a continuous (24/7) basis and alarms can be resolved by authorized personnel. 

PIN Security Requirements:
6-3.6 The CCTV server and digital storage must be secured in a separate secure location that is not accessible to personnel who have access to the secure room.
Testing Procedures:
6-3.6.a Inspect location of the CCTV server and digital storage to verify they are located in a secure location that is separate from the secure room.
6-3.6.b Inspect access-control configurations for the CCTV server/storage secure location and the key-injection secure room to identify all personnel who have access to each area. Compare access lists to verify that personnel with access to the secure room do not have access to the CCTV server/storage secure location. 

PIN Security Requirements:
6-3.7 The CCTV cameras must be positioned to monitor: 

Testing Procedures:
6-3.7 Inspect CCTV positioning and examine a sample of recordings to verify that CCTV cameras are positioned to monitor: 

PIN Security Requirements:
6-3.8 CCTV cameras must be positioned so they do not monitor any combination locks, PIN pads, or keyboards used to enter passwords/authentication codes or other authentication credentials.
Testing Procedures:
6-3.8 Inspect CCTV positioning and examine a sample of recordings to verify that CCTV cameras do not monitor any combination locks, PIN pads, or keyboards used to enter passwords/authentication codes or other authentication credentials. 

PIN Security Requirements:
6-3.9 Images recorded from the CCTV system must be securely archived for a period of no less than 45 days. If digital-recording mechanisms are used, they must have sufficient storage capacity and redundancy to prevent the loss of information necessary to reconstruct events for the most recent 45-day period.
Testing Procedures:
6-3.9.a If digital-recording mechanisms are used, examine system configurations to verify that the systems have sufficient redundancy to prevent the loss of information necessary to reconstruct events for the most recent 45-day period.
6-3.9.b Examine storage of captured recordings to verify that at least the most recent 45 days of images are securely archived. 

PIN Security Requirements:
6-4 Any residue that may contain clear-text keys or components must be destroyed or securely deleted—depending on media—immediately after generation of that key, to prevent disclosure of a key or the disclosure of a key component to an unauthorized individual.
Examples of where such key residue may exist include (but are not limited to): 

6-4.a Examine documented procedures to identify all locations where key residue may exist. Verify procedures ensure the following: 

Examine logs of past destructions and deletions to verify that procedures are followed. 

6-4.b Observe the destruction process of each identified type of key residue and verify the following: 

PIN Security Requirements:
6-5 Asymmetric-key pairs must either be: 

6-5.a Examine documented procedures for asymmetric-key generation to confirm that procedures are defined to ensure that asymmetric-key pairs are either: 

6-5.b Observe key-generation processes to verify that asymmetric-key pairs are either: 

PIN Security Requirements:
6-6 Policy and procedures must exist to ensure that clear-text private or secret keys or their components/shares are not transmitted across insecure channels. Preclusions include but are not limited to: 

6-6.a Examine documented policy and procedures to verify that they include language that prohibits transmitting clear-text private or secret keys or their components/shares across insecure channels, including but not limited to: 

6-6.b From observation of key-management processes verify that clear-text private or secret keys or their components are not transmitted across insecure channels, including but not limited to: 

PIN Security Requirements:
7-1 Written key-generation policies and procedures must exist, and all affected parties (key custodians, supervisory staff, technical management, etc.) must be aware of those procedures. All key-creation events performed by a key-injection facility must be documented. Procedures for creating all keys must be documented.
Testing Procedures:
7-1.a Examine documented key-generation procedures to confirm that they include all aspects of key-generation operations and address all keys in scope.
7-1.b Interview those responsible for the key-generation processes (including key custodians, supervisory staff, technical management, etc.) to verify that the documented procedures are known and understood by all affected parties.
7-1.c Observe key-generation ceremonies whether actual or for demonstration purposes and verify that the documented procedures are demonstrably in use. 

PIN Security Requirements:
7-2 Logs must exist for the generation of higher-level keys such as KEKs exchanged with other organizations and MFKs and BDKs. The minimum log contents include date and time, object name/identifier, purpose, name and signature of individual(s) involved, and tamperevident package number(s) and serial number(s) of device(s) involved.
Testing Procedures:
7-2.a Examine documented key-generation procedures to verify that all key-generation events for higher-level keys (e.g., KEKs shared with other organizations or otherwise manually loaded as components and MFKs and BDKs) must be logged.
7-2.b Observe demonstrations for all types of key-generation events to verify that all key-generation events are logged.
7-2.c Examine logs of key generation to verify that exchanges of higher-level keys with other organizations have been recorded and that all required elements were captured. 

PIN Security Requirements:
8-1 Keys must be transferred either encrypted, as two or more full-length clear-text components, key shares, or within an SCD. 
Clear-text key components/shares must be transferred in SCDs or using tamper-evident, authenticable packaging. 

Note: Components of encryption keys must be transferred using different communication channels, such as different courier services. It is not sufficient to send key components for a specific key on different days using the same communication channel.
Testing Procedures:
8-1.a Determine whether keys are transmitted encrypted, as clear-text components/shares, or within an SCD.
8-1.b If key components are transmitted in clear text using pre-numbered, tamperevident, authenticable packaging, perform the following: 

 8-1.c Where SCDs are used to convey components/shares, 

8-1.d Where an SCD is conveyed with pre-loaded secret and/or private keys, perform the following: 

PIN Security Requirements:
8-2 A person with access to one component or share of a secret or private key, or to the media conveying this value, must not have access to other components or shares of this key or to any other medium containing other components or shares sufficient to form the necessary threshold to derive the key.
Note: An m-of-n scheme is a component- or share-allocation scheme where m is the number of shares or components necessary to form the key, and n is the number of the total set of shares or components related to the key. Management of the shares or components must be sufficient to ensure that no one person can gain access to enough of the item to form the key alone.
E.g., in an m-of-n scheme (which must use a recognized secret-sharing scheme such as Shamir), such that any three key components or shares (i.e., m = 3) can be used to derive the key, no single individual can have access to more than two components/shares.
Testing Procedures:
8-2.a Examine documented procedures to verify they include controls to ensure that no single person can gain access to components or shares of this key or to any other medium containing other components or shares of this key that are sufficient to form the necessary threshold to derive the key. Verify procedures include: 

8-2.b Observe key-transfer processes and interview personnel to verify that controls are implemented to ensure that no single person can gain access to components or shares of this key or to any other medium containing other components or shares of this key that are sufficient to form the necessary threshold to derive the key. Verify the implemented controls ensure the following: 

8-2.c Examine records of past key transfers to verify that the method used did not allow for any personnel to have access to components or shares sufficient to form the key. 

PIN Security Requirements:
8-3 E-mail shall not be used for the conveyance of secret or private keys or their components/shares, even if encrypted, unless the key (or component/share) has already been encrypted in accordance with these requirements—i.e., in an SCD. This is due to the existence of these key values in memory just prior to encryption or subsequent to decryption. In addition, corporate e-mail systems allow the recovery by support staff of the clear text of any encrypted text or files conveyed through those systems.
Other similar mechanisms, such as SMS, fax, or telephone shall not be used to convey clear-text key values.
Testing Procedures:
8-3 Validate through interviews, observation, and log inspection that e-mail, SMS, fax, or telephone or similar communication is not used as means to convey secret or private keys or key components/shares. 

PIN Security Requirements:
8-4 Public keys must be conveyed in a manner that protects their integrity and authenticity. Examples of acceptable methods include: 

PIN Security Requirements:
9-1 During the process to convey it, any single clear-text secret or private key component/share must at all times be either: 

Note: No single person shall be able to access or use all components or a quorum of shares of a single secret or private cryptographic key.
Testing Procedures:
9-1.a Examine documented procedures for transmission, conveyance, or movement of keys between any two locations to verify that any single clear-text key component must at all times be either: 

9-1.b Observe key-management processes, examine associated logs, and interview responsible personnel to verify processes are implemented to ensure that any single clear-text key component is at all times either: 

PIN Security Requirements:
9-2 Packaging or mailers (i.e., pre-numbered, tamper-evident packaging) containing clear-text key components are examined for evidence of tampering before being opened. Any sign of package tampering indicating a component was potentially compromised must be assessed and the analysis formally documented. If compromise is confirmed, and the result is that one person could have knowledge of the key, it must result in the destruction and replacement of: 

9-2.a Verify documented procedures include requirements for all packaging or mailers containing clear-text key components to be examined for evidence of tampering before being opened.
9-2.b Interview responsible personnel and observe processes to verify that all packaging or mailers containing clear-text key components are examined for evidence of tampering before being opened.
9-2.c Verify documented procedures require that any sign of package tampering is identified, reported and if compromise is confirmed ultimately results in the destruction and replacement of both: 

9-2.d Interview responsible personnel and observe processes to verify that if a package shows signs of tampering indicating a component was potentially compromised, processes are implemented to identify the tampering, report/escalate it, and ,if compromise is confirmed, ultimately results in the destruction and replacement of both: 

9-2.e Examine records related to any escalated transmittal event. Verify that if compromise is confirmed it resulted in the destruction and replacement of both: 

PIN Security Requirements:
9-3 Only an authorized key custodian⎯and designated backup(s)⎯shall have physical access to a key component prior to being secured in transmittal packaging and upon removal of a secured key component from transmittal packaging.
Testing Procedures:
9-3.a Verify that a list(s) of key custodians⎯and designated backup(s)⎯authorized to have physical access to key components prior to being secured in transmittal packaging and upon removal of a secured key component from transmittal packaging.
9-3.b Observe implemented access controls and processes to verify that only those authorized key custodians⎯and designated backup(s)⎯have physical access to key components prior to being secured in transmittal packaging and upon removal of a secured key component from transmittal packaging.
9-3.c Examine physical access logs (e.g., to security containers for key components) to verify that only the authorized individual(s) have access to each component. 

PIN Security Requirements:
9-4 Mechanisms must exist to ensure that only authorized custodians: 

9-4.a Verify that a list(s) of key custodians authorized to perform the following activities is defined and documented: 

9-4.b Observe implemented mechanisms and processes and examine logs to verify that only the authorized key custodians can perform the following: 

PIN Security Requirements:
9-5 Pre-numbered, tamper-evident, authenticable bags shall be used for the conveyance of clear-text key components not in an SCD. Out-of-band mechanisms must be used to verify receipt of the appropriate bag numbers.
Note: Numbered courier bags are not sufficient for this purpose
Testing Procedures:
9-5 Verify that pre-numbered, tamper-evident, authenticable bags are used for the conveyance of clear-text key components and perform the following: 

PIN Security Requirements:
9-6 If components or shares of multiple keys are being sent simultaneously between the same sending and receiving custodians, the component/shares for a specific custodian or custodian group can be shipped in the same TEA bag provided that: 

9-6.a If components or shares of multiple keys are being sent simultaneously between the same sending and receiving custodians, the component/shares for a specific custodian or custodian group can be shipped in the same TEA bag provided that: 

9-6.b Examine logs to verify that procedures are followed. 

PIN Security Requirements:
10-1 All key-encryption keys used to encrypt for transmittal or conveyance of other cryptographic keys must be at least as strong as the key being sent, as delineated in Annex C except as noted below for RSA keys used for key transport. 

PIN Security Requirements:
11-1 Written procedures must exist and be known to all affected parties.
Testing Procedures:
11-1.a Verify documented procedures exist for all key transmission and conveyance processing.
11-1.b Interview responsible personnel to verify that the documented procedures are known and understood by all affected parties for key transmission and conveyance processing.

PIN Security Requirements:
11-2 Methods used for the conveyance or receipt of keys must be documented.
Testing Procedures:
11-2 Verify documented procedures include all methods used for the conveyance or receipt of keys. 

PIN Security Requirements:
12-1 The loading of secret or private keys, when loaded from the individual key components, must be managed using the principles of dual control and split knowledge. Note: Manual key loading may involve the use of media such as paper, smart cards, or other physical tokens.
Testing Procedures:
12-1.a Using the summary of cryptographic keys, identify keys that are loaded from components and examine documented process to load each key type (MFK, TMK, PEK, etc.) from components to ensure dual control and split knowledge are required.
12-1.b Interview appropriate personnel to determine the number of key components for each manually loaded key.
12-1.c Witness a structured walk-through/demonstration of various key-loading processes for all key types (MFKs, TMKs, PEKs. etc.). Verify the number and length of the key components against information provided through verbal discussion and written documentation.
12-1.d Verify that the process includes the entry of individual key components by the designated key custodians.
12-1.e Ensure key-loading devices can only be accessed and used under dual control 

PIN Security Requirements:
12-2 Procedures must be established that will prohibit any one person from having access to components sufficient to form an encryption key when components are removed from and returned to storage for key loading.
Testing Procedures:
12-2 Examine logs of access to security containers for key components/shares to verify that only the authorized custodian(s) have accessed. Compare the number on the current tamper-evident and authenticable package for each component to the last log entry for that component. 
Trace historical movement of higher-order keys (MFK, KEK, and BDK) in and out of secure storage to ensure there is no break in the package-number chain that would call into question authorized handling and sufficient storage of the component or share. This must address at a minimum the time frame from the date of the prior audit. 

PIN Security Requirements:
12-3 The loading of clear-text cryptographic keys using a key-loading device requires dual control to authorize any key-loading session. It shall not be possible for a single person to use the key-loading device to load clear keys alone. 
Dual control must be implemented using one or more of, but not limited to, the following techniques: 

Note: For devices that do not support two or more passwords/authentication codes, this may be achieved by splitting the single password used by the device into two halves, each half controlled by a separate authorized custodian. Each half must be a minimum of five characters. Note: Passwords/authentication codes to the same object may be assigned to a custodian group team⎯e.g., custodian team for component A. Note: The addition of applications that replace or disable the PCI-evaluated firmware functionality invalidates the device approval for each such implementation unless those applications are validated for compliance to PTS POI Security Requirements and listed as such in the approval listings.
Testing Procedures:
12-3.a Identify instances where a key-loading device is used to load clear-text keys. Examine documented procedures for loading of clear-text cryptographic keys, including public keys, to verify: 

12-3.b For each type of production SCDs loaded with a key-loading device, observe the processes (e.g., a demonstration) of loading clear-text cryptographic keys and interview personnel. Verify that: 

12-3.c Examine documented records of key-loading to verify the presence of two authorized persons during each type of key-loading activity.
12-3.d Ensure that any default dual-control mechanisms (e.g., default passwords/authentication codes—usually printed in the vendor's manual—in a key-loading device) have been disabled or changed. 

PIN Security Requirements:
12-4 Key components for symmetric keys must be combined using a process such that no active bit of the key can be determined without knowledge of the remaining components. (For example, via XOR‘ing of full-length components.)
Note: Concatenation of key components together to form the key is unacceptable; e.g., concatenating two 8-hexadecimal character halves to form a 16-hexadecimal secret key.
The resulting key must only exist within the SCD.
Testing Procedures:
12-4.a Examine documented procedures for combining symmetric key components and observe processes to verify that key components are combined using a process such that no active bit of the key can be determined without knowledge of the remaining components⎯e.g. only within an SCD.
12-4.b Confirm key-component lengths through interview and examination of blank component forms and documented procedures. Examine device configuration settings and interview personnel to verify that key components used to create a key are the same length as the resultant key. 

PIN Security Requirements:
12-5 Hardware security module (HSM) Master File Keys, including those generated internal to the HSM and never exported, must be at least doublelength keys and use the TDEA (including parity bits) or AES using a key size of at least 128 bits.
Testing Procedures:
12-5 Examine vendor documentation describing options for how the HSM MFK is created and verify the current MFK was created using AES or double- or triplelength TDEA. Corroborate this via observation of processes, with information gathered during the interview process, and procedural documentation provided by the entity under review. 

PIN Security Requirements:
12-6 Any other SCD loaded with the same key components must combine all entered key components using the identical process.
Testing Procedures:
12-6 Through examination of documented procedures, interviews, and observation, confirm that any devices that are loaded with the same key components use the same mathematical process to derive the final key, 

PIN Security Requirements:
12-7 The initial terminal master key (TMK) or initial DUKPT key must be loaded to the device using either asymmetric key-loading techniques or manual techniques—e.g., the device keypad, IC cards, key-loading device, etc. Subsequent loading of the terminal master key may use techniques described in this document such as: 

For AES DUKPT, using the option to derive a key-encryption key called the DUKPT Update Key, so that the host can send a device a new initial key encrypted under that key. Note this also requires that a new initial key ID is also sent.
Keys shall not be reloaded by any methodology in the event of a compromised device and must be withdrawn from use.
Testing Procedures:
12-7.a Examine documented procedures for the loading of TMKs and initial DUKPT keys to verify that they require asymmetric key-loading techniques or manual techniques for initial loading and allowed methods for replacement TMK or initial DUKPT key loading.
12-7.b Examine documented procedures to verify that keys are withdrawn from use if they were loaded to a device that has been compromised or went missing. 

PIN Security Requirements:
12-8 If key-establishment protocols using public-key cryptography are used to distribute secret keys, these must meet the requirements detailed in Annex A of this document. For example: 

PIN Security Requirements:
12-9 Key-injection facilities must implement dual control and split-knowledge controls for the loading of keys into devices (for example, POIs and other SCDs).
Note: Such controls may include but are not limited to: 

12-9.a Examine documented key-injection procedures to verify that the procedures define use of dual control and split knowledge controls for the loading of keys into devices. 

12-9.b Interview responsible personnel and observe key-loading processes and controls to verify that dual control and split-knowledge controls are in place for the loading of keys into devices.
12-9.c Examine records of key-loading processes and controls to verify that the loading of keys does not occur without dual control and split knowledge. 

PIN Security Requirements:
13-1 Clear-text secret and private keys and key components must be transferred into an SCD only when it can be ensured that: 

13-1 Observe key-loading environments, processes, and mechanisms (for example, terminals, PIN pads, key guns, etc.) used to transfer keys and key components. Perform the following: 

PIN Security Requirements:
13-2 Only SCDs shall be used in the loading of clear-text secret or private keys or their components outside of a secure key-loading facility, as delineated in the requirements in this Annex. For example, ATM controller (computer) keyboards or those attached to an HSM shall never be used for the loading of clear-text secret or private keys or their components.
Note: The addition of applications⎯e.g., component, share, or key-loading applications⎯that replace or disable the PCI evaluated firmware functionality invalidates the device approval for each such implementation unless those applications are validated for compliance to PTS POI Security Requirements and listed as such in the approval listings.
Testing Procedures:
13-2.a Examine documentation to verify that only SCDs are used in the loading of clear-text secret or private keys or their components, outside of a secure key-loading facility, as delineated in this Annex. For example, ATM keyboards or keyboards attached to an HSM shall never be used for the loading of clear-text secret or private keys or their components.
13-2.b Observe a demonstration of key loading to verify that only SCDs are used in the loading of clear-text secret or private keys or their components outside of a secure key-loading facility. 

PIN Security Requirements:
13-3 The loading of plaintext secret or private key components or shares from an electronic medium—e.g., smart card, thumb drive, fob or other devices used for data transport—directly into a cryptographic device (and verification of the correct receipt of the component, if applicable) results in either of the following: 

13-3.a Examine documented procedures for the loading of secret or private key components from an electronic medium to a cryptographic device. Verify that procedures define specific instructions to be followed as a result of key loading, including: 

13-3.b Observe key-loading processes to verify that the loading process results in one of the following: 

13-3.c Examine records/logs of erasures to confirm that: 

PIN Security Requirements:
13-4.1 The key-loading device must be a physically secure SCD, designed and implemented in such a way that any unauthorized disclosure of the key is prevented or detected.
Note: A PCI-approved KLD meets this requirement for a SCD.
Testing Procedures:
13-4.1 Verify the key-loading device is a physically secure SCD designed and implemented in such a way that any unauthorized disclosure of the key is prevented or detected. 

PIN Security Requirements:
13-4.2 The key-loading device must be under the supervision of a person authorized by management or stored in a secure container such that no unauthorized person can have access to it.
Testing Procedures:
13-4.2 Verify the key-loading device is under the supervision of a person authorized by management or stored in a secure container such that no unauthorized person can have access to it. 

PIN Security Requirements:
13-4.3 The key-loading device must be designed or controlled so that only authorized personnel under dual control can use and enable it to output a key into another SCD. Such personnel must ensure that a key-recording device is not inserted between the SCDs.
Testing Procedures:
13-4.3.a Verify the key-loading device is designed or controlled so that only authorized personnel under dual control can use and enable it to output a key into another SCD.
13-4.3.b Verify that both authorized personnel involved in key-loading activity inspect the key-loading device prior to use to ensure that a key-recording device has not been inserted between the SCDs. 

PIN Security Requirements:
13-4.4 The key-loading device must not retain any information that might disclose the key⎯e.g., allow replay of the key for injection into a non-SCD⎯that was installed in the device or a key that it has successfully transferred.
Testing Procedures:
13-4.4 Verify the key-loading device does not retain any information that might disclose the key or a key that it has successfully transferred. For example, attempt to output the same value more than one time from the device or cause the device to display check values for its contents both before and after injection and compare. 

PIN Security Requirements:
13-5 Any media (electronic or otherwise) containing secret or private key components or shares used for loading cryptographic keys must be maintained in a secure storage location and accessible only to authorized custodian(s).
When removed from the secure storage location, media or devices containing key components or used for the injection of clear-text cryptographic keys must be in the physical possession of only the designated component holder(s), and only for the minimum practical time necessary to complete the key-loading process.
The media upon which a component resides must be physically safeguarded at all times when removed from secure storage.
Key components that can be read/displayed (for example, those printed on paper or stored on magnetic cards, PROMs, or smartcards) must be managed so they are never used in a manner that would result in the component being displayed in clear text to anyone who is not a designated custodian for that component.
Testing Procedures:
13-5.a Interview personnel and observe media locations to verify that the media is maintained in a secure storage location accessible only to custodian(s) authorized to access the key components.
13-5.b Examine documented procedures for removing media or devices containing key components—or that are otherwise used for the injection of cryptographic keys—from the secure storage location. Verify procedures include the following: 

13-5.c Interview designated component holder(s) and examine key-management logs to verify that media or devices removed from secure storage are in the physical possession of only the designated component holder.
13-5.d Interview key-injection personnel and examine logs for the removal of media/devices from secure storage to verify they are removed only for the minimum practical time necessary to complete the key-loading process. 

PIN Security Requirements:
13-6 If the component is in human-readable form (e.g., printed within a PIN-mailer type document), it must be visible only to the designated component custodian and only for the duration of time required for this person to privately enter the key component into an SCD.
Testing Procedures:
13-6 Validate through interview and observation that printed key components are not opened until just prior to entry into the SCD. Plaintext secret and/or private keys and/or their components are visible only to key custodians for the duration of loading into an SCD. 

PIN Security Requirements:
13-7 Written or printed key-component documents must not be opened until immediately prior to use.
Testing Procedures:
13-7.a Examine documented procedures and confirm that printed/written key-component documents are not opened until immediately prior to use.
13-7.b Observe key-loading processes and verify that printed/written key components are not opened until immediately prior to use. 

PIN Security Requirements:
13-8 A person with access to any component or share of a secret or private key, or to the media conveying this value, must not have access to other components or shares of this key or to any other medium containing other components or shares of this key that are sufficient to form the necessary threshold to derive the key.
E.g., in an m-of-n scheme (which must use a recognized secret-sharing scheme such as Shamir), such that any three key components or shares (i.e., m = 3) can be used to derive the key, no single individual can have access to more than two components/shares.
Testing Procedures:
13-8.a Examine documented procedures for the use of key components to verify that procedures ensure that any individual custodian only has access to their assigned components and never has access to sufficient key components to reconstruct a cryptographic key.
13-8.b Examine key-component access controls and access logs to verify that any single authorized custodians can and has only had access to their assigned component(s) and cannot access sufficient key components to reconstruct a cryptographic key. 

PIN Security Requirements:
13-9.1 PCs and similar devices must be: 

PIN Security Requirements:
13-9.2 All hardware used in key loading (including the PC) must be managed under dual control. Key-injection must not occur unless there are minimally two individuals in the key-injection room at all times during the process. If a situation arises that would cause only one person to be in the room, all individuals must exit until at least two can be inside.
Testing Procedures:
13-9.2 Verify through interviews and observation that: 

PIN Security Requirements:
13-9.3 PC access and use must be monitored, and logs of all key loading must be maintained. These logs must be retained for a minimum of three years. The logs must be regularly (no less frequently than weekly) reviewed by an authorized person who does not have access to the room or to the PC. The reviews must be documented. The logs must include but not be limited to: 

13-9.3.a Verify through interviews and observation that logs of key-loading activities are maintained and meet the following: 

13-9.3.b Verify through interviews and observation that logs of key-loading activities are maintained and meet the following: 

PIN Security Requirements:
13-9.4.1 Cable attachments and the key-loading device must be examined before each use to ensure the equipment is free from tampering.
Testing Procedures:
13-9.4.1 Cable attachments and the key-loading device are examined before each use to ensure the equipment is free from tampering. 

PIN Security Requirements:
13-9.4.2 The key-loading device must be started from a powered-off position every time key-loading activities occur.
Testing Procedures:
13-9.4.2 The key-loading device is started from a powered-off position every time key-loading activities occur. 

PIN Security Requirements:
13-9.4.3 The software application must load keys without recording any clear-text values on portable media or other unsecured devices.
Testing Procedures:
13-9.4.3 The software application loads keys without recording any clear-text values on portable media or other unsecured devices.

PIN Security Requirements:
13-9.4.4 Clear-text keys must not be stored except within an SCD.
Testing Procedures:
13-9.4.4 Clear-text keys are not stored except within an SCD. 

PIN Security Requirements:
13-9.4.5 The personnel responsible for the systems administration of the PC (e.g., a Windows administrator who configures the PC’s user IDs and file settings, etc.) must not have authorized access into the room—they must be escorted by authorized key-injection personnel—and they must not have user IDs or passwords/authentication codes to operate the key-injection application.
Testing Procedures:
13-9.4.5 Personnel responsible for the systems administration of the PC do not have authorized access into the room—i.e., they are escorted by authorized key-injection personnel—and do not have user IDs or passwords/authentication codes to operate the key-injection application. 

PIN Security Requirements:
13-9.4.6 The key-injection personnel must not have system-administration capability at either the O/S or the application level on the PC.
Testing Procedures:
13-9.4.6 Key-injection personnel do not have system-administration capability at either the O/S or the application level on the PC. 

PIN Security Requirements:
13-9.4.7 The PC must not be able to boot from external media (e.g., USB devices or CDs). It must boot from the hard drive only.
Testing Procedures:
13-9.4.7 The PC is not able to boot from external media (e.g., USB devices or CDs). It must boot from the hard drive only. 

PIN Security Requirements:
13-9.4.8 Key-injection facilities must cover all openings on the PC that are not used for key-injection with security seals that are tamper-evident and serialized. Examples include but are not limited to PCMCIA, network, infrared and modem connections on the PC, and access to the hard drive and memory. The seals must be recorded in a log, and the log must be maintained along with the other key-loading logs in a dualcontrol safe. Verification of the seals must be performed prior to key-loading activities.
Testing Procedures:
13-9.4.8 All openings on the PC that are not used for key-injection are covered with security seals that are tamper-evident and serialized. The seals are recorded in a log, and the log is maintained along with the other keyloading logs in a dual-control safe. Verification of the seals must be performed prior to key-loading activities. 

PIN Security Requirements:
13-9.4.9 If the PC application reads or stores clear-text key components, for example, BDKs or TMKs, from portable electronic media (e.g., smart cards), the media must be secured as components under dual control when not in use. The key components must be manually entered at the start of each key-injection session from components that are maintained under dual control and split knowledge.
Note: For DUKPT implementations, the BDK must be loaded from components each time and this requires manual tracking of the device ID counter and serial numbers from the previous key-loading session. Key-injection facilities with PC applications that require passwords/authentication codes to be used to initiate decryption of keys on portable electronic media (e.g., smart cards) must ensure the passwords/authentication codes are maintained under dual control and split knowledge.
Testing Procedures:
13-9.4.9 If the PC application reads or stores keys (e.g., BDKs or TMKs) from portable electronic media (e.g., smart cards), the media is secured as components under dual control when not in use. The key components are manually entered at the start of each key-injection session from components that are maintained under dual control and split knowledge. 

PIN Security Requirements:
13-9.4.10 Manufacturer’s default passwords/authentication codes for PC-based applications must be changed.
Testing Procedures:
13-9.4.10 Manufacturer’s default passwords/authentication codes for PC-based applications are changed. 

PIN Security Requirements:
14-1 Any hardware and passwords/authentication codes used in the key-loading function must be controlled and maintained in a secure environment under dual control. Resources (e.g., passwords/authentication codes and associated hardware) must be managed such that no single individual has the capability to enable key loading. This is not to imply that individual access authentication mechanisms must be managed under dual control.
Testing Procedures:
14-1.a Examine documented procedures to verify they require the following: 

14-1.b Observe key-loading environments and controls to verify the following: 

PIN Security Requirements:
14-2 All cable attachments over which clear-text keying material traverses must be examined at the beginning of an entity's key-activity operations (system power on/authorization) to ensure they have not been tampered with or compromised.
Testing Procedures:
14-2.a Examine documented procedures to ensure they require that cable attachments are examined at the beginning of an entity's key-activity operations (system power on/authorization).
14-2.b Observe key-loading processes to verify that all cable attachments are properly examined at the beginning of an entity's key-activity operations (system power on/authorization). 

PIN Security Requirements:
14-3 Key-loading equipment usage must be monitored, and a log of all key-loading activities maintained for audit purposes containing at a minimum date, time, personnel involved, and number of devices keys are loaded to.
Testing Procedures:
14-3.a Observe key-loading activities to verify that key-loading equipment usage is monitored.
14-3.b Verify logs of all key-loading activities are maintained and contain all required information. 

PIN Security Requirements:
14-4 Any physical tokens (e.g., brass keys or chip cards) used to enable key-loading must not be in the control or possession of any one individual who could use those tokens to load secret or private cryptographic keys under single control. These tokens must be secured in a manner similar to key components including tamper-evident authenticable packaging and the use of access-control logs for when removed or placed into secure storage.
Testing Procedures:
14-4.a Examine documented procedures for the use of physical tokens (e.g., brass keys or chip cards) to enable key loading. Verify procedures require that physical tokens must not be in the control or possession of any one individual who could use those tokens to load secret or private cryptographic keys under single control.
14-4.b Inspect locations and controls for physical tokens to verify that tokens used to enable key loading are not in the control or possession of any one individual who could use those tokens to load secret or private cryptographic keys under single control.
14-4.c Examine storage locations for physical tokens to determine adequacy to ensure that only the authorized custodian(s) can access their specific tokens.
14-4.d Verify that access-control logs exist and are in use, including notation of tamper-evident authenticable bag numbers.
14-4.e Reconcile storage contents to access-control logs. 

PIN Security Requirements:
14-5 Default passwords/authentication codes used to enforce dual control must be changed, and documented procedures must exist to require that these password/PINs be changed when assigned personnel change.
Testing Procedures:
14-5.a Verify that documented procedures require default passwords/authentication codes used to enforce dual control are changed.
14-5.b Verify that documented procedures exist to require that these passwords/authentication codes be changed when assigned personnel change 

PIN Security Requirements:
15-1 A cryptographic-based validation mechanism must be in place to ensure the authenticity and integrity of keys and/or their components (for example, testing key check values, hashes, or other similar unique values that are based upon the keys or key components being loaded). See ISO 11568.
Where check values are used, recorded, or displayed, key-component check values and key check values shall be generated by a cryptographic process such that all portions of the key or key component are involved in generating the check value. The check value shall be in accordance with the following note.
Note:. Check values may be computed by two methods. TDEA may use either method. AES must only use the CMAC method. In the first method, check values are computed by encrypting an all binary zeros block using the key or component as the encryption key, using the leftmost n-bits of the result; where n is at most 24 bits (6 hexadecimal digits/3 bytes). In the second method the KCV is calculated by MACing an all binary zeros block using the CMAC algorithm as specified in ISO 9797-1 (see also NIST SP 800-38B). The check value will be the leftmost n-bits of the result, where n is at most 40 bits (10 hexadecimal digits). The block cipher used in the CMAC function is the same as the block cipher of the key itself. A TDEA key or a component of a TDEA key will be MACed using the TDEA block cipher, while a 128-bit AES key or component will be MACed using the AES-128 block cipher.
Testing Procedures:
15-1.a Examine documented procedures to verify a cryptographic-based validation mechanism is in place to ensure the authenticity and integrity of keys and/or components.
15-1.b Observe the key-loading processes to verify that the defined cryptographic-based validation mechanism used to ensure the authenticity and integrity of keys and components is being used and are verified by the applicable key custodians.
15-1.c Verify that the methods used for key validation are consistent with ISO 11568—for example, if check values are used, they are in accordance with this requirement. 

PIN Security Requirements:
15-2 The public key must have its authenticity and integrity ensured. In order to ensure authenticity and integrity, a public key must be encrypted, or if in plaintext form, must: 

PIN Security Requirements:
16-1 Documented key-loading procedures must exist for all devices (e.g., HSMs and POIs), and all parties involved in cryptographic key loading must be aware of those procedures.
Testing Procedures:
16-1.a Verify documented procedures exist for all key-loading operations.
16-1.b Interview responsible personnel to verify that the documented procedures are known and understood by all affected parties for all key-loading operations.
16-1.c Observe key-loading process for keys loaded as components and verify that the documented procedures are demonstrably in use. This may be done as necessary on test equipment—e.g., for HSMs. 

PIN Security Requirements:
16-2 All key-loading events must be documented. Audit trails must be in place for all key-loading events.
Testing Procedures:
16-2 Examine log files and observe logging processes to verify that audit trails are in place for all key-loading events. 

PIN Security Requirements:
18-2 To prevent or detect usage of a compromised key, key-component packaging, or containers that show signs of tampering indicating a component was potentially compromised must be assessed and the analysis formally documented. If compromise is confirmed, it must result in the discarding and invalidation of the component and the associated key at all locations where they exist.
Testing Procedures:
18-2.a Verify that documented procedures require that key-component packaging/containers showing signs of tampering indicating a component was potentially compromised are assessed and the analysis is formally documented. If compromise is confirmed, it must result in the destruction and invalidation of all associated key components and the resultant cryptographic key(s) at all locations where they exist.
18-2.b Interview personnel and observe processes to verify procedures are implemented to require that key-component packaging/containers showing signs of tampering indicating a component was potentially compromised are assessed and the analysis is formally documented. If compromise is confirmed, it results in the destruction and invalidation of all associated key components and the resultant cryptographic key(s) at all locations where they exist. 

PIN Security Requirements:
18-3 Encrypted symmetric keys must be managed in structures called key blocks. The key usage must be cryptographically bound to the key using accepted methods
The phased implementation dates are as follows: 
Phase 1 – Implement Key Blocks for internal connections and key storage within Service Provider Environments – this would include all applications and databases connected to hardware security modules (HSM). Effective date: 1 June 2019. 
Phase 2 – Implement Key Blocks for external connections to Associations and Networks. Effective date: 1 January 2023. 
Phase 3 – Implement Key Block to extend to all merchant hosts, point-of-sale (POS) devices, and ATMs. Effective date: 1 January 2025. 
Acceptable methods of implementing the integrity requirements include, but are not limited to: 

18-3 Using the cryptographic-key summary to identify secret keys conveyed or stored, examine documented procedures and observe key operations to verify that secret cryptographic keys are managed as key blocks using mechanisms that cryptographically bind the key usage to the key at all times via one of the acceptable methods or an equivalent. 
Where key blocks are not implemented, identify and examine project plans to implement in accordance with the prescribed timeline. 

PIN Security Requirements:
18-6 Controls must be in place to prevent and detect the loading of unencrypted private and secret keys or their components by any one single person. Note: Controls include physical access to the room, logical access to the key-loading application, video surveillance of activities in the key-injection room, physical access to secret or private cryptographic key components or shares, etc.
Testing Procedures:
18-6.a Examine documented key-injection procedures to verify that controls are defined to prevent and detect the loading of keys by any one single person.
18-6.b Interview responsible personnel and observe key-loading processes and controls to verify that controls—for example, viewing CCTV images—are implemented to prevent and detect the loading of keys by any one single person. 

PIN Security Requirements:
18-7 Key-injection facilities must implement controls to protect against unauthorized substitution of keys and to prevent the operation of devices without legitimate keys. Examples include but are not limited to: 

18-7.a Examine documented procedures to verify they include: 

18-7.b Interview responsible personnel and observe key-loading processes and controls to verify that: 

PIN Security Requirements:
19-1 Encryption keys must be used only for the purpose they were intended⎯i.e., key-encryption keys must not to be used as PIN-encryption keys, PIN-encryption keys must not be used for account data, etc. Derivation Keys may be derived into multiple keys, each with its own purpose. For example, a DUKPT Initial Key may be used to derive both a PIN encryption key and a data encryption key. The derivation key would only be used for its own purpose, key derivation. This is necessary to limit the magnitude of exposure should any key(s) be compromised. Using keys only as they are intended also significantly strengthens the security of the underlying system.
Testing Procedures:
19-1.a Examine key-management documentation (e.g., the cryptographic key inventory) and interview key custodians and key-management supervisory personnel to verify that cryptographic keys are defined for a specific purpose.
19-1.b Using a sample of device types, validate via examination of check values, terminal definition files, etc. that keys used for key encipherment or PIN encipherment are not used for any other purpose. 

PIN Security Requirements:
19-2 Private keys: 

Note: The restriction does not apply to certificate signing requests e.g., PKCS #10.
 Testing Procedures:
19-2 Examine key-management documentation and interview key custodians and key-management supervisory personnel to verify that private keys are: • Used only to create digital signatures or to perform decryption operations. 

PIN Security Requirements:
19-3 Public keys must only be used for a single purpose—a public key must only be used for either encryption or for verifying digital signatures, but not both (except for transaction-originating POI devices).
Testing Procedures:
19-3 Examine key-management documentation and interview key custodians and key-management supervisory personnel to verify that public keys are only used: 

PIN Security Requirements:
19-4 Keys must never be shared or substituted between production and test/development systems:
Key used for production keys must never be present or used in a test system, and
Keys used for testing keys must never be present or used in a production system.
Note: For logically partitioned HSMs and computing platforms, if one or more logical partitions of a physical device are used for production and one or more other logical partitions are used for testing, including QA or similar, the entire configuration that is impacted⎯computing platform(s) and networking equipment⎯must be managed and controlled as production.
Testing Procedures:
19-4.a Examine key-management documentation and interview key custodians and key-management supervisory personnel to verify that cryptographic keys are never shared or substituted between production and development systems.
19-4.b Observe processes for generating and loading keys into in production systems to ensure that they are in no way associated with test or development keys.
19-4.c Observe processes for generating and loading keys into test systems to ensure that they are in no way associated with production keys.
19-4.d Compare check, hash, cryptogram, or fingerprint values for production and test/development keys for higher-level keys (e.g., MFKs, KEKs shared with other network nodes, and BDKs) to verify that development and test keys have different key values. 

PIN Security Requirements:
19-5 If a business rationale exists, a production platform (HSM and server/standalone computer) may be temporarily used for test purposes. However, all keying material must be deleted from the HSM(s) and the key-injection server/computer platforms prior to testing. Subsequent to completion of testing, all keying materials must be deleted, the server/computer platforms must be wiped and rebuilt from read-only media, and the relevant production keying material restored using the principles of dual control and split knowledge as stated in these requirements. At all times the HSMs and servers/computers must be physically and logically secured in accordance with these requirements.
Note: This does not apply to HSMs that are never intended to be used for production.
Testing Procedures:
19-5 Interview personnel to determine whether production platforms are ever temporarily used for test purposes. If they are, verify that documented procedures require that: 

PIN Security Requirements:
20-1 POI devices must implement unique secret and private keys for any function directly or indirectly related to PIN protection. These keys must be known only in that device and in hardware security modules (HSMs) at the minimum number of facilities consistent with effective system operations.
Disclosure of the key in one such device must not provide any information that could be feasibly used to determine the key in any other such device.
This means that not only the PIN-encryption key(s), but also keys that are used to protect other keys, firmware-authentication keys, payment application authentication, and display-prompt control keys. As stated in the requirement, this does not apply to public keys resident in the device.
POI private keys must not exist anywhere but the specific POI they belong to, except where generated external to the POI and prior to the injection into the POI.
Testing Procedures:
20-1.a Examine documented procedures for the generation, loading, and usage of all keys used in transaction-originating POI devices. Verify the procedures ensure that all private and secret keys used in transaction-originating POI devices are: 

20-1.b Observe HSM functions and procedures for generating and loading secret and private keys for use in transaction-originating POIs to verify that unique keys are generated and used for each POI device.
20-1.c Examine check values, hashes, or fingerprint values for a sample of cryptographic keys from different POI devices to verify private and secret keys are unique for each POI device. This can include comparing a sample of POI public keys (multiple devices for each POI vendor used) to determine that the associated private keys stored in the POI devices are unique per device—i.e., the public keys are unique. 

PIN Security Requirements:
20-2 If a transaction-originating terminal (for example POI device) interfaces with more than one acquiring organization, the transaction-originating terminal SCD must have a completely different and unique key or set of keys for each acquiring organization. These different keys, or sets of keys, must be totally independent and not variants of one another.
Testing Procedures:
20-2a Determine whether any transaction-originating terminals interface with multiple acquiring organizations. If so: 

20-2b Observe processes for generation and injection of keys into a single POI for more than one acquiring organization, to verify: 

PIN Security Requirements:
20-3 Keys that are generated by a derivation process and derived from the same Base (master) Derivation Key must use unique data for the derivation process as defined in ISO 11568 so that all such cryptographic devices receive unique initial secret keys. Base derivation keys must not ever be loaded onto POI devices—i.e., only the derived key is loaded to the POI device.
This requirement refers to the use of a single “base” key to derive initial keys for many different POIs, using a key-derivation process as described above. This requirement does not preclude multiple unique keys being loaded on a single device, or for the device to use a unique key for derivation of other keys once loaded, for example, as done with DUKPT.
Note: The same BDK with the same KSN installed in multiple injection systems or installed multiple times within the same injection system will not meet uniqueness requirements.
Testing Procedures:
20-3.a Examine documented procedures and observe processes for generating initial keys. Verify the following is implemented where initial keys are generated by a derivation process and derived from the same Base Derivation Key: 

20-3.b Verify that derivation keys used to generate keys for multiple devices are never loaded into a POI device. 

PIN Security Requirements:
20-4 Entities processing or injecting DUKPT or other key-derivation methodologies must incorporate a segmentation strategy in their environments. Segmentation must use one or more of the following techniques: 

20-4.a Examine documented key-generation and injection procedures to verify that entities processing or injecting DUKPT or other key-derivation methodologies incorporate a segmentation strategy in their environments using one or more of the following techniques: 

20-4.b Examine documented key-generation and injection procedures to verify that key-injection vendors use at least one unique Base Derivation Key (BDK) per acquiring organization and are able to support segmentation of multiple BDKs of acquiring organizations. 

PIN Security Requirements:
20-5 Key-injection facilities that load DUKPT keys for various POI types for the same entity must use separate BDKs per terminal type if the terminal IDs can be duplicated among the multiple types of terminals. In other words, the key-injection facility must ensure that any one given key cannot be derived for multiple devices except by chance.
Testing Procedures:
20-5.a If the key-injection facility loads DUKPT keys, examine documented procedures for generation and use of BDKs to verify they require use of separate BDKs per terminal type.
20-5.b Observe key-loading processes for a sample of terminal types used by a single entity, to verify that separate BDKs are used for each terminal type. 

PIN Security Requirements:
20-6 Remote Key-Establishment and Distribution Applications The following requirements apply to key-injection facilities participating in remote key-establishment and distribution applications: 

20-6.a For techniques involving public key cryptography, examine documentation and develop a schematic to illustrate the process, including: 

20-6.b If key-establishment protocols using public-key cryptography are used to distribute secret keys, verify that: 

PIN Security Requirements:
21-1 Secret or private keys must only exist in one or more of the following forms: 

PIN Security Requirements:
21-2.1 Knowledge of any one key component/share does not convey any knowledge of any part of the actual cryptographic key.
Testing Procedures:
21-2.1 Examine processes for creating key components to verify that knowledge of any one key component or share does not convey any knowledge of any part of the actual cryptographic key. 

PIN Security Requirements:
21-2.2 Construction of the cryptographic key requires the use of at least two key components/shares.
Testing Procedures:
21-2.2 Observe processes for constructing cryptographic keys to verify that at least two key components/shares are required for each key construction. 

PIN Security Requirements:
21-2.3 Each key component/share has one or more specified authorized custodians.
Testing Procedures:
21-2.3.a Examine documented procedures for the use of key components and interview key custodians and key-management supervisory personnel to verify that each key component or share is assigned to a specific individual, or set of individuals, who are designated as key custodians for that component/share.
21-2.3.b Observe key-component access controls and key-custodian authorizations/assignments to verify that all individuals with access to key components or shares are designated as key custodians for those particular components/shares. 

PIN Security Requirements:
21-2.4 Procedures exist to ensure that no custodian ever has access to sufficient key components or shares of a secret or private key to reconstruct a cryptographic key.
For example, in an m-of-n scheme (which must use a recognized secretsharing scheme such as Shamir), where only two of any three shares are required to reconstruct the cryptographic key, a custodian must not have current or prior knowledge of more than one share. If a custodian was previously assigned share A, which was then reassigned, the custodian must not then be assigned share B or C, as this would give them knowledge of two shares, which gives them ability to recreate the key.
In an m-of-n scheme where n=5 and where all three shares are required to reconstruct the cryptographic key, a single custodian may be permitted to have access to two of the key shares (for example, share A and share B); and a second custodian (with, in this example, share C) would be required to reconstruct the final key, ensuring that dual control is maintained.
Testing Procedures:
21-2.4.a Examine documented procedures for the use of key components/shares to verify that procedures ensure that no custodian ever has access to sufficient key components or shares to reconstruct a secret or private cryptographic key.
21-2.4.b Examine key-component access controls and access logs to verify that authorized custodians cannot access sufficient key components or shares to reconstruct a secret or private cryptographic key. 

PIN Security Requirements:
21-3.1 Key components that exist in clear text outside of an SCD must be sealed in individual opaque, pre-numbered, tamper-evident, authenticable packaging that prevents the determination of the key component without noticeable damage to the packaging.
Note: Tamper-evident, authenticable packaging (opacity may be envelopes within tamper-evident packaging) used to secure key components must ensure that the key component cannot be determined. For components written on paper, opacity may be sufficient, but consideration must be given to any embossing or other possible methods to “read” the component without opening of the packaging. Similarly, if the component is stored on a magnetic card, or other media that can be read without direct physical contact, the packaging should be designed to prevent such access to the key component.
Testing Procedures:
21-3.1.a Examine key components and storage locations to verify that components are stored in individual opaque, pre-numbered, tamper-evident packaging that prevents the determination of the key component without noticeable damage to the packaging.
21-3.1.b Inspect any tamper-evident packaging used to secure key components—e.g., is the package sufficiently opaque to prevent reading of a component—and ensure that it prevents the determination of the key component without visible damage to the packaging.
21-3.1.c Interview responsible personnel to determine that clear-text key components do not exist in non-secure containers such as databases or in software programs.
21-3.1.d Confirm that start-up instructions and other notes used by service technicians do not contain initialization-key values written in the clear (e.g., at the point in the checklist where the keys are entered). 

PIN Security Requirements:
21-3.2 Key components/shares for each specific custodian must be stored in a separate secure container that is accessible only by the custodian and/or designated backup(s).
Note: Furniture-based locks or containers with a limited set of unique keys— for example, desk drawers—are not sufficient to meet this requirement.
Components/shares for a specific key that are stored in separate envelopes, but within the same secure container, place reliance upon procedural controls and do not meet the requirement for physical barriers.
Testing Procedures:
21-3.2 Inspect each key component/share storage container and verify the following: 

PIN Security Requirements:
21-3.3 If a key component/share is stored on a token, and an access code (e.g., a PIN or similar access-control mechanism) is used to access the token, only that token’s owner⎯or designated backup(s)⎯must have possession of both the token and its access code.
Testing Procedures:
21-3.3 Interview responsible personnel and observe implemented processes to verify that if a key is stored on a token, and an access code (PIN or similar mechanism) is used to access the token, only that token’s owner—or designated backup(s)—has possession of both the token and its access code. 

PIN Security Requirements:
22-1.1 Key components/shares are never reloaded when there is any suspicion that either the originally loaded key or the SCD has been compromised.
Testing Procedures:
22-1.1 Interview responsible personnel and observe implemented processes to verify key components are never reloaded when there is any suspicion that either the originally loaded key or the SCD has been compromised. 

PIN Security Requirements:
22-1.2 If unauthorized alteration is suspected, new keys are not installed until the SCD has been inspected and assurance reached that the equipment has not been subject to any form of unauthorized modification.
Testing Procedures:
22-1.2 Interview responsible personnel and observe implemented processes to verify that if unauthorized alteration is suspected, new keys are not installed until the SCD has been inspected and assurance reached that the equipment has not been subject to any form of unauthorized modification. 

PIN Security Requirements:
22-1.3 A secret or private cryptographic key must be replaced with a new key whenever the compromise of the original key is known. Suspected compromises must be assessed, and the analysis formally documented. If compromise is confirmed, the key must be replaced. In addition, all keys encrypted under or derived using that key must be replaced with a new key within the minimum feasible time. The replacement key must not be a variant or an irreversible transformation of the original key. Compromised keys must not be used to facilitate replacement with a new key(s).
Note: The compromise of a key must result in the replacement and destruction of that key and all variants and non-reversible transformations of that key, as well as all keys encrypted under or derived from that key.
Known or suspected substitution of a secret key must result in the replacement of that key and based on an analysis of how the key was substituted, any associated key-encipherment keys that may have been compromised.
Testing Procedures:
22-1.3 Interview responsible personnel and observe implemented processes to verify that if compromise of the cryptographic key is suspected, an assessment and analysis is performed. If compromise is confirmed, all the following are performed: 

PIN Security Requirements:
22-1.4 A documented escalation process and notification to organizations that currently share or have previously shared the key(s), including: 

22-1.4.a Interview responsible personnel and examine documented procedures to verify key personnel are identified and that the escalation process includes notification to organizations that currently share or have previously shared the key(s).
22-1.4.b Verify notifications include the following: 

PIN Security Requirements:
22-1.5 Identification of specific events that would indicate a compromise may have occurred. Such events must include but are not limited to: 

Testing Procedures:
22-1.5 Interview responsible personnel and examine documented procedures to verify that specific events that may indicate a compromise are identified. This must include, as a minimum, the following events: 

PIN Security Requirements:
22-2 If attempts to load a secret key or key component into a KLD or POI fail, the same key or component must not be loaded into a replacement device unless it can be ensured that all residue of the key or component has been erased from or otherwise destroyed in the original KLD or POI
Testing Procedures:
22-2 Interview responsible personnel and observe implemented processes to verify that if attempts to load a secret key or key component into a KLD or POI fail, the same key or component is not loaded into a replacement device unless it can be ensured that all residue of the key or component has been erased from or otherwise destroyed in the original KLD or POI. 

PIN Security Requirements:
23-1 Any key generated with a reversible process (such as a variant of a key) of another key must be protected in the same manner as the original key—that is, under the principles of dual control and split knowledge. Variants of the same key may be used for different purposes but must not be used at different levels of the key hierarchy. For example, reversible transformations must not generate key-encipherment keys from PIN keys.
Note: Exposure of keys that are created using reversible transforms of another (key-generation) key can result in the exposure of all keys that have been generated under that key-generation key. To limit this risk posed by reversible key calculation, such as key variants, the reversible transforms of a key must be secured in the same way as the original key-generation key.
Testing Procedures:
23-1.a Examine documented procedures and interview responsible personnel to determine whether keys are generated using reversible key-calculation methods.
23-1.b Observe processes to verify that any key generated using a reversible process of another key is protected under the principles of dual control and split knowledge. 

PIN Security Requirements:
23-2 An MFK used by host processing systems for encipherment of keys for local storage—and variants of the MFK—must not be used external to the (logical) configuration that houses the MFK itself. For example, MFKs and their variants used by host processing systems for encipherment of keys for local storage shall not be used for other purposes, such as key conveyance between platforms that are not part of the same logical configuration.
Testing Procedures:
23-2.a Interview responsible personnel to determine which host MFKs keys exist as variants.
Note: Some HSMs may automatically generate variants or control vectors for specific keys, but it is still up to the entity to specify exact usage.
23-2.b Examine vendor documentation to determine support for key variants.
23-2.c Via examination of the network schematic detailing transaction flows with the associated key usage and identification of the sources of the keys used, determine that variants of the MFK are not used external to the logical configuration that houses the MFK. 

PIN Security Requirements:
23-3 Reversible key transformations are not used across different levels of the key hierarchy. For example, reversible transformations must not generate working keys (e.g., PEKs) from key-encrypting keys.
Such transformations are only used to generate different types of key-encrypting keys from an initial key-encrypting key or working keys with different purposes from another working key.
Note: Using transformations of keys across different levels of a key hierarchy— for example, generating a PEK key from a key-encrypting key—increases the risk of exposure of each of those keys.
It is acceptable to use one “working” key to generate multiple reversible transforms to be used for different working keys, such as a PIN key, MAC key(s), and data key(s) (where a different reversible transform is used to generate each different working key). Similarly, it is acceptable to generate multiple key-encrypting keys from a single key-encrypting key. However, it is not acceptable to generate working keys from key-encrypting keys.
Testing Procedures:
23-3 Examine documented key-transformation procedures and observe implemented processes to verify that reversible key transformations are not used across different levels of the key hierarchy, as follows: 

PIN Security Requirements:
24-1 Instances of secret or private keys, and their key components, that are no longer used or that have been replaced by a new key must be destroyed.
Testing Procedures:
24-1.a Verify documented procedures are in place for destroying secret or private keys, and their key components that are no longer used or that have been replaced by a new key.
24-1.b Identify a sample of keys and key components that are no longer used or have been replaced. For each item in the sample, interview responsible personnel and examine key-history logs and key-destruction logs to verify that all keys have been destroyed.
24-1.c Examine storage locations for the sample of destroyed keys to verify they are no longer kept. 

PIN Security Requirements:
24-2.1 Keys on all other storage media types in all permissible forms— physically secured, enciphered (except for electronic DB backups of cryptograms), or components—must be destroyed following the procedures outlined in ISO–9564 or ISO–11568.
For example, keys (including components or shares) maintained on paper must be burned, pulped, or shredded in a crosscut shredder.
Testing Procedures:
24-2.1.a Examine documented procedures for destroying keys and confirm that keys on all other storage media types in all permissible forms—physically secured, enciphered, or components—must be destroyed following the procedures outlined in ISO–9564 or ISO–11568.
24-2.1.b Observe key-destruction processes to verify that keys on all other storage media types in all permissible forms—physically secured, enciphered, or components—are destroyed following the procedures outlined in ISO–9564 or ISO–11568. 

PIN Security Requirements:
24-2.2 The key-destruction process must be observed by a third party other than the custodians of any component of that key. I.e., the third party must not be a key custodian for any part of the key being destroyed. The third-party witness must sign an affidavit of destruction and this affidavit is retained for a minimum of two years.
Testing Procedures:
24-2.2.a Observe the key-destruction process and verify that it is witnessed by a third party other than a key custodian for any component of that key.
24-2.2.b Inspect key-destruction logs and verify that a third-party, non-key-custodian witness signs an affidavit as a witness to the key destruction process. 

PIN Security Requirements:
24-2.3 Key components for keys other than the HSM or KLD MFKs that have been successfully loaded and confirmed as operational must also be destroyed, unless the HSM does not store the encrypted values on a database but only stores the subordinate keys internal to the HSM. BDKs used in KLDs may also be stored as components where necessary to reload the KLD.
Testing Procedures:
24-2.3.a Verify documented procedures exist for destroying key components of keys, once the keys are successfully loaded and validated as operational.
24-2.3.b Observe key-conveyance/loading processes to verify that any key components are destroyed once the keys are successfully loaded and validated as operational. 

PIN Security Requirements:
25-1.1 Designate key custodian(s) for each component, such that the fewest number (e.g., a primary and a backup) of key custodians are assigned as necessary to enable effective key management. Key custodians must be employees or contracted personnel
Testing Procedures:
25-1.1 Examine key-custodian assignments for each component to verify that: 

PIN Security Requirements:
25-1.2 Document this designation by having each custodian and backup custodian sign a key-custodian form.
Testing Procedures:
25-1.2.a Examine completed key-custodian forms to verify that key custodians sign the form.
25-1.2.b Examine completed key-custodian forms to verify that backup custodians sign the form. 

PIN Security Requirements:
25-1.3 Each key-custodian form provides the following: 

25-1.3 Examine all key-custodian forms to verify that they include the following: 

PIN Security Requirements:
25-1.4 In order for key custodians to be free from undue influence in discharging their custodial duties, key custodians sufficient to form the necessary threshold to create a key must not directly report to the same individual.
For example, for a key managed as three components, at least two individuals report to different individuals. In an m-of-n scheme (which must use a recognized secret-sharing scheme such as Shamir), such as three of five key shares to form the key, key custodians sufficient to form the threshold necessary to form the key must not report to the same individual. 
The components collectively held by an individual and his or her direct reports shall not constitute a quorum (or shall not provide any information about the value of the key that is not derivable from a single component). 
Custodians must not become a custodian for a component/share of a key where the custodian has previously been or is currently a custodian for another component/share of that key if that would collectively constitute a quorum to form the actual key. 
When the overall organization is of insufficient size such that the reporting structure cannot support this requirement, procedural controls can be implemented.
Organizations that are of insufficient size that they cannot support the reporting-structure requirement must: 

25-1.4.a Examine key-custodian assignments and organization charts to confirm the following: 

25-1.4.b For organizations that are such a small, modest size that they cannot support the reporting-structure requirement, ensure that documented procedures exist and are followed to: 

PIN Security Requirements:
26-1 Logs must be kept whenever keys, key components, or related materials are removed from secure storage or loaded to an SCD. These logs must be archived for a minimum of two years subsequent to key destruction. 
At a minimum, logs must include the following: 

26-1.a Examine log files and audit log settings to verify that logs are kept for any time that keys, key components, or related materials are: 

26-1.b Examine logs and verify they are: 

26-1.c Examine log files and audit log settings to verify that logs include the following: 

PIN Security Requirements:
27-1 If backup copies of secret and/or private keys exist, they must be maintained in accordance with the same requirements as are followed for the primary keys.
Testing Procedures:
27-1 Interview responsible personnel and examine documented procedures and backup records to determine whether any backup copies of keys or their components exist. Perform the following: 

PIN Security Requirements:
27-2 If backup copies are created, the following must be in place: 

27-2 Interview responsible personnel and observe backup processes to verify the following: 

PIN Security Requirements:
28-1 Written procedures must exist, and all affected parties must be aware of those procedures. All activities related to key administration must be documented. This includes all aspects of key administration, as well as: 

28-1.a Examine documented procedures for key-administration operations to verify they include: 

28-1.b Interview personnel responsible for key-administration operations to verify that the documented procedures are known and understood.
28-1.c Interview personnel to verify that security-awareness training is provided for the appropriate personnel.
28-1.d Interview responsible HR personnel to verify background checks are conducted (within the constraints of local laws). 

PIN Security Requirements:
29-1.1.1 Access to all POIs and other SCDs is documented, defined, logged, and controlled such that unauthorized individuals cannot access, modify, or substitute any device without detection.
The minimum log contents include date and time, object name/identifier, purpose, name of individual(s) involved, signature or electronic capture (e.g., badge) of individual involved and if applicable, tamper-evident package number(s) and serial number(s) of device(s) involved. Electronic logging⎯e.g., using bar codes⎯is acceptable for device tracking.
Testing Procedures:
29-1.1.1.a Examine access-control documentation and device configurations to verify that access to all POIs and key-injection/loading devices is defined and documented.
29-1.1.1.b For a sample of POIs and other SCDs, observe authorized personnel accessing devices and examine access logs to verify that access to all POIs and other SCDs is logged.
29-1.1.1.c Examine implemented access controls to verify that unauthorized individuals cannot access, modify, or substitute any POI or other SCD. 

PIN Security Requirements:
29-1.1.2 All personnel with access to POIs and other SCDs prior to deployment are documented in a formal list and authorized by management. A documented security policy must exist that requires the specification of personnel with authorized access to all secure cryptographic devices. This includes documentation of all personnel with access to POIs and other SCDs as authorized by management. The list of authorized personnel is reviewed at least annually.
Testing Procedures:
29-1.1.2.a Examine documented authorizations for personnel with access to devices to verify that prior to deployment: 

29-1.1.2.b For a sample of POIs and other SCDs, examine implemented access controls to verify that only personnel documented and authorized in an auditable manner have access to devices. 

PIN Security Requirements:
29-1.2 POIs and other SCDs must not use default keys or data (such as keys that are pre-installed for testing purposes) or passwords/authentication codes.
Testing Procedures:
29-1.2.a Examine vendor documentation or other information sources to identify default keys (such as keys that are pre-installed for testing purposes), passwords, or data.
29-1.2.b Observe implemented processes and interview personnel to verify that default keys or passwords are not used. 

PIN Security Requirements:
29-3 Implement physical protection of devices from the manufacturer’s facility up to the point of key-insertion and deployment, through one or more of the following: 

29-3.a Examine documented procedures to confirm that they require physical protection of devices from the manufacturer’s facility up to the point of key-insertion and deployment, through one or more of the defined methods.
29-3.b Interview responsible personnel to verify that one or more of the defined methods are in place to provide physical device protection for devices, from the manufacturer’s facility up to the point of key-insertion and deployment. 

PIN Security Requirements:
29-4.1 HSM serial numbers must be compared to the serial numbers documented by the sender (sent using a different communication channel from the device) to ensure device substitution has not occurred. A record of device serial-number verification must be maintained.
Note: Documents used for this process must be received via a different communication channel—i.e., the control document used must not have arrived with the equipment. An example of how serial numbers may be documented by the sender includes but is not limited to the manufacturer’s invoice or similar document.
Testing Procedures:
29-4.1.a Interview responsible personnel to verify that device serial numbers are compared to the serial number documented by the sender.
29-4.1.b For a sample of received devices, examine sender documentation sent via a different communication channel than the device’s shipment (for example, the manufacturer’s invoice or similar documentation) used to verify device serial numbers. Examine the record of serial-number validations to confirm the serial number for the received device was verified to match that documented by the sender. 

PIN Security Requirements:
29-4.2 The security policy enforced by the HSM must not allow unauthorized or unnecessary functions. HSM API functionality and commands that are not required to support specified functionality must be disabled before the equipment is commissioned. 

PIN Security Requirements:
29-4.3 When HSMs are connected to online systems, controls are in place to prevent the use of an HSM to perform privileged or sensitive functions that are not available during routine HSM operations.
Examples of sensitive functions include but are not limited to: loading of key components, outputting clear-text key components, and altering HSM configuration.
Testing Procedures:
29-4.3 Examine HSM configurations and observe processes to verify that HSMs are not enabled in a sensitive state when connected to online systems. 

PIN Security Requirements:
29-4.4.1 Running self-tests to ensure the correct operation of the device
Testing Procedures:
29-4.4.1 Examine records of device inspections and test resu lts to verify that self-tests are run on devices to ensure the correct operation of the device. 

PIN Security Requirements:
29-4.4.2 Installing (or re-installing) devices only after confirming that the device has not been tampered with or compromised
Testing Procedures:
29-4.4.2 Observe inspection processes and interview responsible personnel to verify that devices are installed, or reinstalled, only after confirming that the device has not been tampered with or compromised. 

PIN Security Requirements:
29-4.4.3 Physical and/or functional tests and visual inspection to confirm that physical and logical controls and anti-tamper mechanisms are not modified or removed
Testing Procedures:
29-4.4.3 Observe inspection processes and interview responsible personnel to confirm processes include physical and/or functional tests and visual inspection to verify that physical and logical controls and anti-tamper mechanisms are not modified or removed 

PIN Security Requirements:
29-4.4.4 Maintaining records of the tests and inspections, and retaining records for at least one year
Testing Procedures:
29-4.4.4.a Examine records of inspections and interview responsible personnel to verify records of the tests and inspections are maintained.
29-4.4.4.b Examine records of inspections to verify records are retained for at least one year. 

PIN Security Requirements:
29-5 Maintain HSMs in tamper-evident packaging or in secure storage until ready for installation.
Testing Procedures:
29-5.a Examine documented procedures to verify they require devices be maintained in tamper-evident packaging until ready for installation.
29-5.b Observe a sample of received devices to verify they are maintained in tamper-evident packaging until ready for installation. 

PIN Security Requirements:
30-3 Processes must exist to ensure that key-injection operations are performed and reconciled on an inventory of pre-authorized devices. Processes must include the following: 

Note: The KIF platform must ensure that only authorized devices can ever be injected or initialized with authorized keys. Processes must prevent (1) substitution of an authorized device with an unauthorized device, and (2) insertion of an unauthorized device into a production run.
Testing Procedures:
30.3.a Obtain and examine documentation of inventory control and monitoring procedures. Determine that the procedures cover: 

30.3.b Interview applicable personnel to determine that procedures are known and followed. 

PIN Security Requirements:
31-1.1 HSMs require dual control (e.g., to invoke the system menu) to implement for all critical decommissioning processes.
Testing Procedures:
31-1.1.a Examine documented procedures for removing HSM from service to verify that dual control is implemented for all critical decommissioning processes.
31-1.1.b Interview personnel and observe demonstration (if HSM is available) of processes for removing HSM from service to verify that dual control is implemented for all critical decommissioning processes 

PIN Security Requirements:
31-1.2 Keys are rendered irrecoverable (for example, zeroized) for SCDs. If data cannot be rendered irrecoverable, devices must be physically destroyed under dual control to prevent the disclosure of any sensitive data or keys.
Testing Procedures:
31-1.2 Interview personnel and observe demonstration of processes for removing SCDs from service to verify that all keying material is rendered irrecoverable (for example, zeroized), or that devices are physically destroyed prior to leaving the dual-control area to prevent the disclosure of any sensitive data or keys. 

PIN Security Requirements:
31-1.3 SCDs being decommissioned are tested and inspected to ensure keys have been rendered irrecoverable.
Testing Procedures:
31-1.3 Interview personnel and observe processes for removing SCDs from service to verify that tests and inspections of devices are performed to confirm that keys have been rendered irrecoverable or the devices are physically destroyed. 

PIN Security Requirements:
31-1.4 Affected entities are notified before devices are returned.
Testing Procedures:
31-1.4 Interview responsible personnel and examine device-return records to verify that affected entities are notified before devices are returned. 

PIN Security Requirements:
31-1.5 Devices are tracked during the return process.
Testing Procedures:
31-1.5 Interview responsible personnel and examine device-return records to verify that devices are tracked during the return process. 

PIN Security Requirements:
31-1.6 Records of the tests and inspections maintained for at least one year.
Testing Procedures:
31-1.6 Interview personnel and observe records to verify that records of the tests and inspections are maintained for at least one year. 

PIN Security Requirements:
32-1.1 Devices must not be authorized for use except under the dual control of at least two authorized people.
Note: Dual control consists of logical and/or physical characteristics. For example, dual control may be implemented for logical access via two individuals with two different passwords/authentication codes at least five characters in length, or for physical access via a physical lock that requires two individuals, each with a different high-security key. For devices that do not support two or more passwords/authentication codes, this may be achieved by splitting the single password used by the device into two halves, each half controlled by a separate authorized custodian. Each half must be a minimum of five characters. Physical keys, authorization codes, passwords/authentication codes, or other enablers must be managed so that no one person can use both the enabler(s) and the device, which can create cryptograms of known keys or key components under a key-encipherment key used in production.
Testing Procedures:
32-1.1 Observe dual-control mechanisms and device-authorization processes to confirm that logical and/or physical characteristics are in place that prevent the device being authorized for use except under the dual control of at least two authorized people. 

PIN Security Requirements:
32-1.2 Passwords/authentication codes used for dual control must each be of at least five numeric and/or alphabetic characters.
Testing Procedures:
32-1.2 Observe password policies and configuration settings to confirm that passwords/authentication codes used for dual control must be at least five numeric and/or alphabetic characters. 

PIN Security Requirements:
32-1.3 Dual control must be implemented for the following: 

32-1.3 Examine dual-control mechanisms and observe authorized personnel performing the defined activities to confirm that dual control is implemented for the following: 

PIN Security Requirements:
32-1.4 Devices must not use default passwords/authentication codes.
Testing Procedures:
32-1.4.a Examine password policies and documented procedures to confirm default passwords/authentication codes must not be used for HSMs, KLDs, and other SCDs used to generate or load cryptographic keys.
32-1.4.b Observe device configurations and interview device administrators to verify that HSMs, KLDs, and other SCDs used to generate or load cryptographic keys do not use default passwords/authentication codes. 

PIN Security Requirements:
32-1.5 To detect any unauthorized use, devices are at all times within a secure room and either: 

Note: POI devices may be secured by storage in the dual-control access key injection room.
Testing Procedures:
32-1.5.a Examine documented procedures to confirm that the documented procedures require devices are within a secure room and either: 

32-1.5.b Interview responsible personnel and observe devices and processes to confirm that devices are either: 

PIN Security Requirements:
32-8.2 The KIF must implement mutually authenticated channels for communication between distributed KIF functions—for example, between a host used to generate keys and a host used to distribute keys.
Testing Procedures:
32-8.2 Examine documented procedures to confirm they specify the establishment of a channel for mutual authentication of the sending and receiving devices. 

PIN Security Requirements:
32-8.5 The KIF must implement a mutually authenticated channel for establishment of enciphered secret or private keys between POI devices and an HSM at the KIF.
Testing Procedures:
32-8.5 Examine documented procedures to confirm they specify the establishment of a mutually authenticated channel for establishment of enciphered secret or private keys between sending and receiving devices— e.g., POI devices and HSMs. 

PIN Security Requirements:
32-8.6 Mutual authentication of the sending and receiving devices must be performed. 

32-8.6 Interview responsible personnel and observe processes for establishment of enciphered secret or private keys between sending and receiving devices to verify: 

PIN Security Requirements:
32-8.7 Mechanisms must exist to prevent a non-authorized host from injecting keys into POIs or an unauthorized POI from establishing a key with a legitimate KIF component.
Testing Procedures:
32-8.7 Examine documented procedures to confirm they define mechanisms to prevent an unauthorized host from performing key transport, key exchange, or key establishment with POIs. 

PIN Security Requirements:
32-9.2 Any windows into the secure room must be locked and protected by alarmed sensors.
Testing Procedures:
32-9.2.a Observe all windows in the secure room to verify they are locked and protected by alarmed sensors.
32-9.2.b Examine configuration of window sensors to verify that the alarm mechanism is active. 

PIN Security Requirements:
32-9.3 Any windows must be covered, rendered opaque, or positioned to prevent unauthorized observation of the secure room.
Testing Procedures:
32-9.3 Observe all windows in the secure room to verify they are covered, rendered opaque, or positioned to prevent unauthorized observation of the secure room. 

PIN Security Requirements:
32-9.4 A solid-core door or a steel door must be installed to ensure that door hinges cannot be removed from outside the room.
Testing Procedures:
32-9.4 Inspect the secure room to verify that it is only accessed through a solid-core or a steel door, with door hinges that cannot be removed from outside the room. 

PIN Security Requirements:
32-9.5 An electronic access control system (for example, badge and/or biometrics) must be in place that enforces: 

32-9.5 Observe authorized personnel entering the secure room to verify that a badge-control system is in place that enforces the following requirements: 

PIN Security Requirements:
32-9.6 The badge-control system must support generation of an alarm when one person remains alone in the secure room for more than 30 seconds.
Note: Examples of alarm-generation mechanisms include but are not limited to motion detectors, login/logout controls, biometrics, badge sensors, etc.
Testing Procedures:
32-9.6 Examine alarm mechanisms and interview alarm-response personnel to verify that the badge-control system supports generation of an alarm when one person remains alone in the secure room for more than 30 seconds. 

PIN Security Requirements:
32-9.7 CCTV cameras must record all activity, including recording events during dark periods through the use of infrared CCTV cameras or automatic activation of floodlights in case of any detected activity. This recording may be motion-activated. The recording must continue for at least a minute after the last pixel of activity subsides.
Testing Procedures:
32-9.7 Inspect CCTV configuration and examine a sample of recordings to verify that CCTV monitoring is in place on a 24/7 basis, including the ability to record events during dark periods, and if motion activated verify that recording continues for at least a minute after the last pixel of activity subsides. 

PIN Security Requirements:
32-9.8 Monitoring must be supported on a continuous (24/7) basis such that alarms can be resolved by authorized personnel.
Testing Procedures:
32-9.8 Inspect configuration of monitoring systems and interview monitoring personnel to verify that monitoring is supported on a continuous (24/7) basis and alarms can be resolved by authorized personnel. 

PIN Security Requirements:
32-9.9 The CCTV server and digital storage must be secured in a separate secure location that is not accessible to personnel who have access to the key-injection secure room.
Testing Procedures:
32-9.9.a Inspect location of the CCTV server and digital-storage to verify they are located in a secure location that is separate from the key-injection secure room.
32-9.9.b Inspect access-control configurations for the CCTV server/storage secure location and the key-injection secure room to identify all personnel who have access to each area. Compare access lists to verify that personnel with access to the key-injection secure room do not have access to the CCTV server/storage secure location. 

PIN Security Requirements:
32-9.10 The CCTV cameras must be positioned to monitor: 

32-9.10 Inspect CCTV positioning and examine a sample of recordings to verify that CCTV cameras are positioned to monitor: 

PIN Security Requirements:
32-9.11 CCTV cameras must be positioned so they do not monitor any combination locks, PIN pads, or keyboards used to enter passwords/authentication codes or other authentication credentials.
Testing Procedures:
32-9.11 Inspect CCTV positioning and examine a sample of recordings to verify that CCTV cameras do not monitor any combination locks, PIN pads, or keyboards used to enter passwords/authentication codes or other authentication credentials. 

PIN Security Requirements:
32-9.12 Images recorded from the CCTV system must be securely archived for a period of no less than 45 days. If digital-recording mechanisms are used, they must have sufficient storage capacity and redundancy to prevent the loss of information necessary to reconstruct events for the most recent 45-day period.
Testing Procedures:
32-9.12.a Examine storage of captured recordings to verify that at least the most recent 45 days of images are securely archived.
32-9.12.b If digital-recording mechanisms are used, examine system configurations to verify that the systems have sufficient redundancy to prevent the loss of information necessary to reconstruct events for the most recent 45-day period. 

PIN Security Requirements:
33-1 Written procedures must exist, and all affected parties must be aware of those procedures. Records must be maintained of the tests and inspections performed by key-injection facilities on PIN-processing devices before they are placed into service, as well as devices being decommissioned.
Testing Procedures:
33-1.a Examine documented procedures/processes and interview responsible personnel to verify that all affected parties are aware of required processes and are provided suitable guidance on procedures for devices placed into service, initialized, deployed, used, and decommissioned,
33-1.b Verify that written records exist for the tests and inspections performed on PIN-processing devices before they are placed into service, as well as devices being decommissioned.