Adam Lisowski
Senior Consultant, Risk Advisory Services
Logging is one of the most critical yet frequently overlooked components of PCI DSS compliance. While not as attention-grabbing as network segmentation or encryption, logging failures can lead directly to audit findings—or worse, undetected breaches. PCI DSS 4.0 continues to place heavy emphasis on logging and monitoring, particularly under Requirement 10.
Whether you're undergoing a PCI audit or tightening internal security practices, ensuring your PCI logging strategy is both useful and compliant is a must. Below, we outline PCI compliance logging requirements and how to avoid the most common missteps.
1. Understand PCI DSS Logging Requirements
PCI DSS Requirement 10 focuses on logging and monitoring access to systems and cardholder data. Organizations must capture, store, review, and protect logs that provide visibility into system activity. The goal is simple: in the event of suspicious or unauthorized activity, your logs should clearly answer the five W’s—who, what, when, where, and why.
Logs must not only exist but also maintain integrity, be retained appropriately, and be reviewed regularly to detect anomalies. Real-time visibility and structured analysis are no longer optional under PCI DSS 4.0.
2. Implement Key PCI Logging Capabilities
PCI-compliant logging systems must satisfy several core requirements. These capabilities fall into four categories:
Key Events to Capture:
- User access (including administrative activity)
- Access to audit logging mechanisms
- Failed login attempts
- Changes to user credentials or authentication mechanisms
- Creation or deletion of system-level objects
- Startup, stopping, or pausing of logging services
Log Entry Components:
- User ID
- Event type
- Date and time
- Success/failure outcome
- Event origination (e.g., IP address or system)
- Impacted system or resource
Retention and Access Control:
- Logs must be stored for at least 12 months
- The last 3 months of logs must be readily accessible
- Only authorized personnel may access logs
- Logs must be protected by file integrity monitoring and/or change detection tools
Log Review Process:
- Daily review of logs related to critical systems and cardholder data
- Use of automated review mechanisms where feasible
- Periodic reviews of logs from less critical systems
- Documented procedures for investigating anomalies
3. Avoid These Common PCI Logging Mistakes
Many organizations fall short not because of a lack of intent—but because of poorly designed or inconsistently managed logging systems. Below are common issues that often lead to compliance gaps:
- Logs are generated but never reviewed
- Systems lack a centralized log management solution
- Sensitive data is logged inadvertently
- Logs are spread across multiple environments without visibility
- Events are not properly tagged or correlated to PCI-relevant systems
- Logging configurations are incomplete or never tested
These challenges can result in audit failures or missed detection of security incidents. Consistent configuration, centralized log management, and automated review tools can significantly reduce these risks.
Final Thoughts on PCI-Compliant Logging
Logs are your system’s memory—crucial for both compliance and incident response. Under PCI DSS 4.0, there is little margin for error. Your PCI DSS logging infrastructure must be accurate, accessible, secure, and actively reviewed.
If you’re unsure whether your current logging practices meet PCI standards, now is the time to assess and remediate. I’ve helped organizations across industries address audit gaps and build sustainable, compliant logging frameworks.
Contact Us for PCI Compliance Support
For a review of your logging strategy or to prepare for an upcoming PCI audit, reach out to Adam Lisowski with Freed Maxick Risk Advisory Services at adam.lisowski@freedmaxick.com or call 716.362.6203. Let’s work together to strengthen your compliance posture and protect sensitive data.