Organizations that handle payment cards often invest heavily in firewalls, antivirus, and encryption. Yet when something suspicious happens, they still struggle to answer basic questions: who did what, when, from where, and using which system. That gap is exactly what Payment Card Industry Data Security Standard (PCI DSS) Requirement 10 is meant to close.
In this article, I will walk you through what Requirement 10 expects, how to interpret it in plain language, and how to implement logging and monitoring in a way that is both compliant and practical for your teams.
Understanding The Purpose Of Requirement 10
PCI DSS sets out baseline security controls for any environment that stores, processes, or transmits cardholder data. Requirement 10 is titled “Log and monitor all access to system components and cardholder data.” In simple terms, it requires you to generate, protect, and review logs so that you can trace important actions in your cardholder data environment.
The real purpose is accountability. If a security incident or data breach occurs, you should be able to reconstruct what happened without guesswork. Requirement 10 makes sure you do not rely on memory or assumptions, but on recorded, trusted evidence.
When you treat Requirement 10 as a way to gain visibility, instead of just an audit checkbox, it naturally supports other regulations as well, including cyber resilience and incident reporting obligations.
Core Elements Of Requirement 10 In Plain Language
To keep Requirement 10 digestible, it helps to group its expectations into a few practical themes rather than memorize subclauses.
| Area | What Requirement 10 Expects | What You Should Implement |
|---|---|---|
| Logging scope | Important systems must create security-relevant logs | Clear list of in-scope systems and enabled audit logging |
| Log content | Logs must answer “who, what, when, where” | User IDs, timestamps, actions, system and source identifiers |
| Log protection | Logs must be tamper-resistant and retained | Restricted access, centralized storage, backups, retention |
| Monitoring and review | Logs must be actively reviewed, not just stored | SIEM or log platform, alerts, documented review process |
| Time synchronization | Times must line up across systems | Common time source (for example, NTP servers) |
| Logging failures | Problems with logging must be detected and handled | Alerts for missing logs, full storage, or disabled logging |
If you design your controls so that each row of this table is clearly covered, you will be much closer to a defensible implementation of Requirement 10.
PRO TIP
Take the “core elements” table and turn each row into a named control with an owner (e.g., “Log Protection – owned by Security”) so you know exactly who is accountable for each part.
Defining What You Log And Why It Matters
A common mistake is turning on “everything” and assuming volume equals coverage. Requirement 10 is more specific. You need to log events that actually matter for security and compliance, especially around systems in the cardholder data environment and systems that can affect their security.
At a minimum, focus on:
- Authentication events, including successful and failed logins and logouts.
- Privileged activity, such as admin actions and changes to permissions or roles.
- Security-relevant changes, including firewall rules, configuration changes, and changes to access control lists.
- Actions that affect cardholder data, such as data exports, data deletion, or changes to encryption settings.
If you can answer “who did what, from where, and when” for these event types, you are already meeting the spirit of Requirement 10. If you cannot, adjust your logging configuration until those questions can be answered consistently.
From a practical point of view, this also makes incident response much faster. When your team investigates an alert, they can move directly to the relevant log entries instead of searching through noise.
Protecting Logs So They Can Be Trusted
Logs are only useful if they are trustworthy. Requirement 10 expects that logs are protected from tampering and inappropriate access. This has two sides: who can see logs, and who can change them.
You should make sure that:
- Only authorized personnel can view logs, and access is granted on a need-to-know basis.
- Administrators who manage systems do not have the unchecked ability to erase or alter the logs that record their own actions.
- Logs are sent to a centralized platform where changes are tightly controlled and monitored.
- Logs are backed up and kept for at least the required retention period, with recent logs quickly accessible.
In practice, this often means forwarding logs from servers, applications, firewalls, identity providers, and databases into a central Security Information and Event Management (SIEM) or log management solution. That platform becomes your “source of truth” for investigations and audit evidence.
PRO TIP
Forward all critical logs to a central SIEM or log platform where admins have read-only access and only a small, separate group can manage configuration and retention.
Turning Logs Into Monitoring And Action
Requirement 10 is not satisfied by simply collecting logs. There must be a monitoring and review process that looks at those logs and responds to what they show.
A practical approach usually has three layers. First, you centralize logs into one platform. Second, you define alert rules for high-risk events, such as multiple failed admin logins, a sudden change in firewall rules for payment systems, or the disabling of security tools. Third, you set clear expectations for daily and periodic review.
You might, for example, require that:
- Security events and alerts from the SIEM are reviewed every business day.
- Critical alerts trigger immediate investigation and potential incident response.
- Regular reports, such as weekly summaries of admin activity or access exceptions, are reviewed and signed off.
The key is to make the process realistic for your team size. A smaller organization might start with a focused set of alerts and a simple daily checklist, while a larger environment may have a fully staffed security operations center. In both cases, you should be able to show that logs are being used to detect and respond to suspicious behavior, not just stored.
Making Time Your Ally: Synchronization Across Systems
Time synchronization is one of the simplest, yet most valuable, parts of Requirement 10. All systems in scope should use a reliable, centralized time source so that their timestamps align.
If your application server says an event happened at 09:01, the database should not claim the related event occurred at 08:55 or 09:10. When clocks are misaligned, investigations turn into guesswork, and it becomes very hard to show a clear sequence of events to assessors or regulators.
By using a small number of internal time servers and pointing all in-scope systems to them, you dramatically improve the quality of your evidence without adding much complexity.
PRO TIP
Configure all in-scope systems to use the same internal NTP servers and add “time sync status” to your standard build and hardening checklist.
Dealing With Logging Failures Before They Become Blind Spots
Requirement 10 also expects you to notice when logging and monitoring stop working as intended. Storage can fill up, a system can stop sending logs, or someone can disable a critical alert rule.
You should treat these failures like any other security incident and define how they are detected and handled. For example, you might:
- Configure the SIEM to alert if no logs are received from a critical system for a defined period.
- Set thresholds for storage usage and alert when log partitions or indices approach their limits.
- Monitor changes to the SIEM configuration itself, especially alert rules and data inputs.
When a failure happens, your procedure should cover investigation, short-term mitigation, and restoration of full logging, together with documenting what occurred. This shows that your control is not just configured but actively managed.
Designing A Simple, Compliant Logging Architecture
The easiest way to think about Requirement 10 is as an architecture question. You want a structure that is simple enough to maintain, yet robust enough to provide good visibility.
A common pattern that works well is:
- Identify all systems in the cardholder data environment, plus systems that directly affect its security.
- Forward relevant logs from these systems into a central SIEM or log management platform.
- Normalize key fields such as timestamp, username, IP address, and system name.
- Define a small, high-value set of alerts aligned to real risks in your environment.
- Establish clear roles, responsibilities, and review routines for these alerts and reports.
When you design it this way, Requirement 10 stops being a long list of clauses and becomes a straightforward architecture with clear responsibilities. It also gives you reusable evidence for other frameworks that expect strong logging and monitoring.
From Logs To Confidence: Using Requirement 10 Strategically
When you treat PCI DSS Requirement 10 as a simple logging checklist, it feels like extra work with little benefit. When you view it as a tool for visibility and control, it becomes a central piece of your security posture.
If you are refining or building your approach, I suggest you start with three steps. First, map which systems really matter for payment processing and security. Second, verify that you can answer “who did what, when, from where, and using which system” for those systems, using logs. Third, formalize your monitoring and review process so that logs are not just stored but actively used.
Handled this way, Requirement 10 does more than satisfy PCI DSS. It gives you a reliable view of what is happening in your environment and a solid foundation for responding to incidents, demonstrating compliance, and building trust with your customers and leadership.
PRO TIP
Pick your top 5–10 critical systems and verify, end-to-end, that you can answer “who did what, when, from where, and using which system” using only logs and documented procedures.
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