PCI DSS 10.2.1.1: Logging Administrative and Root Actions
Administrative and root-level access poses the highest risk to your payment card environment. PCI DSS 10.2.1.1 requires comprehensive audit logging of every action taken by privileged users—no exceptions. Without proof of these activities, you can't detect unauthorized access, demonstrate accountability, or prove compliance during assessment.
What this means
This control mandates that your organization capture and retain detailed audit logs for all actions performed by users with root or administrative privileges. This includes account modifications, system configuration changes, access to cardholder data, and security-relevant events. Logs must be immutable, timestamped, and maintained for investigation and forensic purposes. The goal is to create an unbroken chain of accountability for high-risk activities.
How to comply
- 1.Enable audit logging at the OS and application level for all administrative accounts
- 2.Configure centralized log collection to aggregate logs from all systems in real-time
- 3.Define and document which administrative actions trigger logging (user creation, permission changes, file access, etc.)
- 4.Ensure logs include user identification, timestamp, action performed, and affected resources
- 5.Implement write-once, read-many (WORM) storage or equivalent immutability controls
- 6.Retain logs for at least one year with a minimum of three months readily accessible online
- 7.Review logs regularly for suspicious or unauthorized activity; document review findings
- 8.Restrict access to audit logs themselves—only authorized personnel should read or modify them
Evidence auditors look for
- Screenshots or reports of centralized log management system (e.g., syslog, Splunk, ELK) showing admin action entries
- Configuration documentation for audit logging policies on servers, databases, and applications
- Log retention schedule and storage location details (on-site, cloud, archival systems)
- Sample audit log entries showing user ID, timestamp, action type, and affected resource
- Access control matrix showing who can view, export, or manage audit logs
- Automated alert rules configured for high-risk administrative actions
- Review records or reports documenting periodic audit log analysis and findings
Frequently asked questions
When will FAQs be available?
The FAQ for this control is currently being prepared.
GRCWatch automatically aggregates and maintains immutable audit logs from your infrastructure, generates pre-formatted evidence reports for admin actions, and flags privileged activities that require investigation—eliminating manual log collection and compliance documentation overhead.
See how GRCWatch handles this control automatically
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