PCI PIN Security v3.1

Normative Annex B – Key-Injection Facilities 

Control Objective 4: Key-loading to HSMs and POI PIN-acceptance devices is handled in a secure manner. 

Requirement 13: The mechanisms used to load secret and private keys—such as terminals, external PIN pads, key guns, or similar devices and methods—must be protected to prevent any type of monitoring that could result in the unauthorized disclosure of any component. 
Key-injection facilities must ensure key-loading mechanisms are not subject to disclosure of key components or keys. Some key-injection platforms use personal-computer (PC)-based software applications, whereby clear-text secret and/or private keys and/or their components exist in memory outside the secure boundary of an SCD for loading keys. Such systems have inherent weaknesses that, if exploited, may cause the unauthorized disclosure of components and/or keys. These weaknesses include: 

PIN Security Requirements:
13-9 Key-injection facilities that use PC-based key-loading software platforms or similar devices (e.g., modified PEDs) that allow clear-text secret and/or private keys and/or their components to exist in memory outside the secure boundary of an SCD must minimally implement the following additional controls:
Note: Effective 1 January 2021, entities engaged in key loading on behalf of others shall not be allowed to use PC based key-loading methodologies where clear-text secret and/or private keying material appears in the clear in memory outside the secure boundary of an SCD.
Effective 1 January 2023, entities only performing key loading for devices for which they are the processor shall no longer have this option.
Testing Procedures:
13-9 Interview appropriate personnel and examine documentation to determine the procedures for key loading to POIs, key-loading devices, and HSMs that are part of the key-loading platform. Examine any logs of key loading.