Where hashing is used to make PAN unreadable (the first method listed in Requirement 3.5.1), the hashes must be keyed cryptographic hashes over the entire PAN, supported by key-management processes and procedures that meet Requirements 3.6 and 3.7. Applicability: all applicability notes for 3.5.1 also apply; key-management processes (3.6 and 3.7) are not needed for components that produce a single keyed PAN hash to compare against another system if those components hold only one hash value at a time (no hashes stored on them) AND no other account data sits on the same system. Guidance cites transit turnstiles that hash PAN for a backend as an example, while noting the backend itself, seeing many hashes, must meet 3.6 and 3.7. Once effective, this requirement replaces the one-way hash bullet in 3.5.1. Objective under the customized approach: cleartext PAN cannot be worked out from PAN hashes. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.
This control maps to 14 controls across 8 other frameworks. If you already hold one of them, the evidence you collected for it is the starting point here rather than new work.
Every mapping shown was judged rather than inferred from wording similarity, and the ones that failed review are published too. See the coverage reports and what was rejected.
PCI DSS 4.0 3.5.1.1 is one control. If you already hold one of the frameworks below, a reviewed crosswalk already says how much of PCI DSS 4.0 your existing evidence covers. Hold ISO 27001:2022 and 139 of 280 PCI DSS 4.0 controls already carry evidence.
Each report names every control your existing framework evidences, every one it does not, the reasoning behind each claim, and the claims that were argued against and rejected. 415 were rejected on the ISO 27001:2022 pair alone.
The graph holds this control, the 14 it maps to, and the evidence behind each claim, over MCP and REST.