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PCI DSS 9.1.3: Physical Security Controls for CDE Areas

Protecting your cardholder data environment (CDE) starts with physical security. Control 9.1.3 requires you to implement access restrictions to all areas housing CDE system components. Without proper physical barriers and monitoring, your organization faces breach risk regardless of technical safeguards.

What this means

This control mandates that your organization deploy physical security measures to prevent unauthorized individuals from accessing systems that process, store, or transmit cardholder data. This includes server rooms, network closets, workstations used for payment processing, and any facility containing CDE components. Physical security serves as the first line of defense, complementing your technical controls by ensuring only authorized personnel can physically interact with critical systems.

How to comply

  1. 1.Identify and document all areas containing CDE system components, including server rooms, network closets, payment terminals, and administrative workstations
  2. 2.Install physical barriers such as locked doors, gates, or enclosures around CDE areas
  3. 3.Implement access controls using key cards, biometric systems, or PIN codes to restrict entry to authorized personnel only
  4. 4.Maintain an access log or visitor register documenting who enters CDE areas and when
  5. 5.Install surveillance cameras covering all CDE areas with recorded footage retained per your data retention policy
  6. 6.Establish clear policies defining which personnel require CDE access and enforce the principle of least privilege
  7. 7.Conduct regular security audits to verify physical controls remain effective and address any gaps
  8. 8.Implement escort procedures for vendors, contractors, and visitors requiring temporary CDE access

Evidence auditors look for

  • Photographs or floor plans showing locked doors, card readers, or biometric systems on CDE areas
  • Access control system logs demonstrating restricted entry permissions
  • Physical access policies and procedures documentation
  • Surveillance system configuration details and sample footage retention records
  • Visitor log entries showing escort requirements and access dates/times
  • Security audit reports confirming physical control effectiveness
  • Key or badge assignment records tied to specific individuals
  • Maintenance records for locks, cameras, and access control devices

Frequently asked questions

When will FAQs be available?

The FAQ for this control is currently being prepared.

GRCWatch automates physical security control documentation by centralizing access logs, visitor records, and audit findings in a single compliance dashboard, eliminating manual tracking and evidence gathering for PCI DSS 9.1.3 audits.

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Related controls

PCI DSS 9.1.1 — Use video surveillance and physical access controlsPCI DSS 9.1.2 — Control physical access with entry pointsPCI DSS 9.2.1 — Restrict physical access to system componentsPCI DSS 8.1.1 — Limit user access based on job responsibilities