PCI DSS 4.0.1 in Microsoft 365, requirement by requirement

25 requirements can be evidenced from a Microsoft 365 tenant, by 86 checks. Each one is listed below with its checks, and so is what sits outside Microsoft 365.

Every framework mapped to Microsoft 365 · Mappings checked against the published standards in October 2026

What PCI DSS 4.0.1 is

The Payment Card Industry Data Security Standard, version 4.0.1 (version 4.0 was retired at the end of 2024). Applies to Microsoft 365 where it is connected to, or in scope of, the cardholder data environment.

Who asks for it: Organisations that store, process or transmit card data.

What Microsoft 365 can show

25 requirements evidenced by 86 checks. A check maps to a requirement only where its result is genuine evidence for it, so a requirement is listed only when a tenant setting can show it.

Outside Microsoft 365

Network segmentation, card data storage, physical security and testing (requirements 1, 3, 9 and 11) sit outside Microsoft 365.

Readiness is not certification or an audit opinion: it covers only what Microsoft 365 can evidence, and the report says so.

Every requirement and the checks behind it

The mappings were last checked against the published standards in October 2026. Each check links to what it looks at and how to fix it.

PCI DSS 4.0.1: each of the 25 requirements and the checks that evidence it
RequirementChecks that evidence it
2.2.1 Configuration standards are developed, implemented and maintained
2.2.2 Vendor default accounts are managed
2.2.4 Only necessary services, protocols and functions are enabled
3.2.1 Account data storage is kept to a minimum through retention and disposal
5.2.1 An anti-malware solution is deployed on all system components
5.3.1 The anti-malware solution is kept current
5.4.1 Personnel are protected against phishing attacks
12 more checks for 5.4.1
6.3.3 Known vulnerabilities are patched
7.2.1 An access control model is defined
7.2.2 Access is assigned by job function with least privilege
4 more checks for 7.2.2
7.2.4 User accounts and access privileges are reviewed every six months
7.2.5 Application and system accounts are managed with least privilege
8.2.5 Access for terminated users is immediately revoked
8.2.6 Inactive user accounts are removed or disabled within 90 days
8.3.1 All user access is authenticated
8.4.1 MFA for all non-console administrative access into the CDE
8.4.2 MFA for all access into the CDE
8.4.3 MFA for all remote network access
8.6.3 Passwords for application and system accounts are protected
10.2.1 Audit logs are enabled and active
10.4.1 Audit logs are reviewed at least daily
10.5.1 Audit log history is retained for at least 12 months
12.3.4 Hardware and software technologies are reviewed every 12 months
12.5.1 An inventory of in-scope system components is maintained
12.10.1 An incident response plan exists and is ready to be activated

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