PCI DSS 6.2.3.1: Independent Code Review Requirements
Code review is a critical security control that catches vulnerabilities before they reach production. PCI DSS 6.2.3.1 requires that manual code reviews be performed by individuals other than the code's original author—a fundamental principle of separation of duties that protects your payment systems from insider threats and human error.
What this means
This control mandates that when your development team performs manual code reviews, at least one person who did not write the code must review and approve all changes. This peer-review process creates accountability, reduces the risk of malicious or careless code reaching production, and ensures technical expertise is applied to security-sensitive decisions. The reviewer must be independent enough to provide objective assessment without conflicts of interest.
How to comply
- 1.Establish a formal code review policy requiring all code changes to be reviewed by an independent developer
- 2.Document the code review process, including roles, responsibilities, and escalation procedures
- 3.Implement version control systems that enforce peer review requirements before code merging
- 4.Assign code reviewers who have no involvement in the original code development
- 5.Maintain audit trails showing who reviewed each change and when approval occurred
- 6.Train developers on secure code review practices and what to look for (SQL injection, authentication flaws, etc.)
- 7.Verify code review completion before promoting changes to production environments
Evidence auditors look for
- Git commit history showing reviewed and approved pull requests from independent reviewers
- Code review documentation or comments from peer reviewers on all code changes
- Version control access logs demonstrating merge-to-main restrictions requiring approval
- Development policy document specifying independent review requirements
- Automated workflow logs from CI/CD tools (GitHub, GitLab, Bitbucket) showing review gates
- Meeting notes or tickets documenting peer review sign-offs on security-critical code
Frequently asked questions
When will FAQs be available?
The FAQ for this control is currently being prepared.
GRCWatch automatically tracks code review workflows from your Git repositories, documenting reviewer independence and maintaining audit-ready evidence for PCI DSS 6.2.3.1 without manual log collection.
See how GRCWatch handles this control automatically
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