PCI DSS requires QSA to retain audit results and work papers for three years.

Retention isn’t glamorous, but it’s the quiet backbone of security compliance. When you’re knee-deep in controls, diagrams, and vulnerability reports, the time you spend organizing your paperwork now saves you headaches later. So, here’s the bottom line you’ll want to keep in mind: a QSA must secure and maintain audit results and work papers for a minimum of three years.

Three years: the why behind the number

If you’re wondering where that three-year horizon comes from, you’re not alone. The rule isn’t just a random date stamped on a file cabinet. It’s about staying accountable over time. PCI DSS compliance isn’t a one-and-done checkbox; threats evolve, configurations change, and your defenses can be reassessed years down the road. Banks, card brands, and merchants may pull retrospective reviews to confirm that protections remained in place, or to understand how remediation steps played out in real life. A three-year retention window gives everyone a reliable reference point for that kind of retrospective analysis. It’s long enough to spot trends, yet practical enough to manage without turning your storage into a black hole.

What counts as audit results and work papers

To keep things clear, think of three big buckets of material you’d want to keep:

• Assessment results and formal reports

• Final assessment reports, gap analysis summaries, executive dashboards, and any validation letters.

• Evidence collected during the assessment

• Network diagrams, scope boundaries, data flow maps, screenshots from testing tools, vulnerability scan results, penetration test reports, remediation evidence, and change tickets showing how issues were fixed.

• Supporting documentation that proves how you implemented controls

• Policy documents, procedures, access control lists, change management records, incident logs, exception records, and evidence of training or awareness efforts.

In practice, this means you should preserve not only the polished deliverables but also the raw inputs that fed them. If a bank asks, “How did you validate that PCI DSS Requirement 6 was properly implemented in 2021?” you’d want to point to the combination of test results, remediation tickets, and the updated policy that shows the final state.

How to maintain these records for three years

Think of three layers: secure storage, organized access, and reliable retrieval. Here’s a practical blueprint you can adapt.

• Secure storage

• Digital files: keep them in a secure repository with strong access controls, encryption at rest, and tamper-evident logging. Cloud storage like trusted enterprise buckets or a secured document management system works well, as long as you enforce encryption, authentication, and permission granularity.

• Physical copies (if any): store in locked cabinets with limited access. If you can avoid paper, that often reduces risk, but if paper is unavoidable, keep it in a controlled environment with clear off-site backups.

• Organization and cataloging

• Use a consistent folder structure and naming convention so you can find everything quickly. For example, you might organize by engagement year, then by control domain, then by document type.

• Maintain a master index or a metadata sheet that lists what’s in each file, when it was created, who approved it, and the retention deadline. This saves minutes during an audit and hours of digging later.

• Version control and change tracking

• If you update a policy or a test result, keep the history. Versioning helps demonstrate how conclusions evolved as findings were addressed.

• Access controls and audit trails

• Limit who can view, modify, or delete records. Enable detailed logs that capture who accessed which files and when. Retain these logs alongside the documents so you have a complete picture.

• Backups and disaster recovery

• Regular backups are a must. Schedule periodic backups and test restoration to avoid the “you can’t access it when you need it” trap.

• Consider geographic redundancy to protect against local incidents. Just as you’d safeguard customer data, you should safeguard your audit records too.

• Retention policy and destruction

• Establish a formal three-year retention policy. Define when records reach the end of their life and how they’ll be securely destroyed (shredded for paper, wiped and purged for digital).

• Document the destruction process so you can prove compliance if questioned later.

A few practical tips you’ll appreciate

• Start with a simple, written policy

• A concise retention policy is your north star. It should spell out what gets kept, where it’s stored, who can access it, and when it’s disposed of. Keep it readable; nobody benefits from a policy that reads like a legal brief.

• Use a shared, well-governed repository

• Whether you choose a dedicated document management system or a secure shared drive, the key is governance. Clear permissions, standard templates, and an easy way to tag and search documents prevent chaos.

• Create a triage checklist

• When you finish an assessment, run through a quick checklist: Is all critical evidence captured? Are there remediation records? Is the policy updated to reflect new controls? Is everything placed in the correct folder with the right metadata?

• Designate custodians

• Assign responsibility for retention adherence. A named person or role keeps the process human and accountable, which makes audits smoother.

• Plan for periodic reviews

• Three years isn’t a “set it and forget it” timeline. Schedule quarterly or biannual reviews of stored materials to ensure nothing went astray and that the retention dates are accurate.

• Separate retention and disposal duties

• Have a separate process for securely disposing of materials that have reached the end of their three-year window. A predictable cadence reduces risk of accidental retention or premature destruction.

Common pitfalls to dodge

• Failing to capture the chain of evidence

• If you don’t document how a finding was tested and remediated, the paper trail can look thin. Always attach the rationale and the steps taken to fix an issue.

• Overloading with irrelevant files

• Not every artifact needs to live forever. Focus on what supports the assessment scope, control validation, and remediation outcomes.

• Inadequate access control

• If too many people can access the archive, you lose control. Tighten permissions and review access regularly.

• Poorly labeled materials

• Vague filenames are the enemy of retrieval. Clear, descriptive names with dates and control references save time and headaches.

• Unclear destruction plans

• If you don’t have a documented destruction plan, you risk keeping outdated data longer than necessary or, worse, keeping sensitive material in an unsecured place.

A broader lens: retention as part of a security-first mindset

Retention isn’t just about surviving an audit. It’s a signal that your organization treats data with respect and intentionality. When you can pull up a complete, well-documented trail from several years back, you demonstrate continuity and commitment to security. It’s like leaving a trail of breadcrumbs for anyone who wants to understand how your defenses evolved over time.

And yes, this mindset applies beyond PCI DSS. For security teams, audit trails feed into continuous improvement. You can spot patterns—maybe a particular vulnerability got remediated quickly in one year but lingered in another. You can compare how different controls performed across changes in technology, personnel, or processes. That historical perspective helps you fine-tune not just the controls themselves but the culture around security.

A small, comforting truth

Three years isn’t punitive. It’s pragmatic. It gives you a window big enough to reflect on how well your protection layers work in practice, without forcing you to hoard every single digital crumb forever. It also mirrors how many regulatory bodies, insurers, and brand programs operate—reliable, repeatable, and reviewable. The result is a stronger, more transparent security posture overall.

If you’re one of the folks who handles audits, the three-year rule can feel like a dull note in a loud symphony. But once you’ve built a clean, well-tagged archive, the music becomes much easier to read. You move from scrambling to respond to an inquiry to presenting a confident, coherent story about how your organization protects cardholder data. And that confidence matters—because trust is the currency of secure commerce.

Bottom line

• The required retention period for audit results and work papers is three years.

• Build a secure, well-organized archive with clear guidelines for access, versioning, and destruction.

• Focus on the essentials: what proves compliance, how findings were tested, and how remediations were implemented.

• Treat retention as part of a broader commitment to ongoing security improvement, not just a checkbox to tick.

If you’re currently shaping how your team handles these records, start with a simple retention policy and a single, trusted repository. You’ll save time, reduce risk, and keep your security story intact for the years that matter. And that, ultimately, is what strong PCI DSS governance looks like in practice.