Periodic media inventories must be conducted annually under PCI DSS.

If you’ve ever wrestled with PCI DSS compliance, you’ve probably learned that security isn’t a one-and-done deal. It’s a rhythm—a steady routine that keeps sensitive cardholder data out of the wrong hands. One line in that rhythm often trips people up: periodic media inventories. The rule is simple, but the impact is real. At least annually, organizations should take stock of the media that could hold cardholder data. Yes, annually. Let me unpack why that matters, what it looks like in practice, and how a team can make it feel less like a headache and more like a safeguard.

What exactly is “media” here, and why does it need to be inventoried?

Media, in PCI DSS terms, means any physical or electronic storage that could contain cardholder data. That includes old hard drives you’ve tucked away in a closet, USB drives that still have a temp file from a project, external backups, tapes in a vault, and even printed materials that somehow made their way into the office. You might think, “We don’t have that much stuff.” Then a quick scan of the warehouse, the offsite storage, and the backups in the cloud can reveal there’s more than you’d expect. The point is quick: if it can hold data, it needs to be accounted for.

Why annually? Why not monthly or quarterly?

Here’s the thing: more frequent inventories are perfectly valid—and many teams choose to do them for added assurance. But PCI DSS sets a minimum: once a year. Why? Because an annual cycle is a practical balance. It’s long enough to be manageable, short enough to catch drift, and just frequent enough to flag old or forgotten media before it becomes a risk. If you did monthly inventories, you’d be chasing tiny changes and spending a lot of effort for incremental safety. If you did them quarterly or semi-annually, you’d create a dense cadence that’s hard to maintain across multiple offices, remote sites, and third-party storage vendors. The annual cadence, when paired with ongoing asset management, tends to work well for most organizations.

How a yearly media inventory typically plays out

Think of the year as a rolling map, not a single sprint. A well-structured annual media inventory usually includes these touchpoints:

• Define the scope

• Confirm which media types count: physical storage devices, backups, physical copies of printed data, and any cloud or offsite repositories that could contain cardholder data.

• Identify locations: on-site data rooms, offices, service providers, offsite vaults, and long-term archives.

• Create a current inventory baseline

• Use a centralized list that names each item, its type, serial/business ID, location, owner, and any encryption or access controls.

• Tag physical media with durable identifiers so it’s easy to spot during a physical check.

• Conduct the physical verification

• Go room-to-room, cabinet-to-cabinet, and vault-to-vault. Verify that every item on the list exists where you say it is.

• Verify the status: is it in use, archived, or retired? Are there backups that have outlived their retention policy?

• Reconcile with other systems

• Compare the media inventory against your asset management tools, backups catalogs, and any vendor-provided inventories.

• Look for gaps: media that’s not listed anywhere, or items that show up in one system but not another.

• Assess disposal and retirement

• Check how old media is, whether it’s scheduled for retirement, and if disposal methods meet PCI DSS requirements (for instance, secure erasure or physical destruction when appropriate).

• Ensure that any media previously containing cardholder data has been properly sanitized before disposal or reuse.

• Document, remediate, and improve

• Record findings, issues, and owners. Assign clear corrective actions with deadlines.

• Review the process to see where it can be smoother next year—new locations, better tagging, or more automated reconciliation.

A practical, person-friendly way to run it

You don’t need a giant playbook to get this done. A practical approach might look like this:

• Start with a one-page map: “What counts as media in our environment?” Then keep it updated as your environment grows.

• Use labels. A simple, durable tag on every physical item makes tracking easier and slows the “it’ll turn up later” problem.

• Lean on tools you already trust. Asset management systems like ServiceNow, Lansweeper, or Spiceworks can help keep a live record. Even a well-maintained spreadsheet can do the job if you’re careful about version control and access.

• Assign a media steward. A named owner keeps the accountability clear and reduces the fog of “someone else is handling it.”

• Build a small checklist for the physical walk-through. It should cover location, status, and whether the item is still in scope.

Avoiding common pitfalls (so the year doesn’t feel like a slog)

• Don’t forget offsite or third-party media. Backups or archive tapes kept at a vendor location slip into the inventory just as readily as those in your server room.

• Don’t rely on memory. If it isn’t documented, it’s a risk. Treat the inventory as a living record that’s updated when media moves, retires, or is added.

• Don’t ignore backups. A backup tape sitting in a safe room may be out of date with your live data. Make sure retention policies are aligned with the inventory.

• Don’t treat “retired” as “forgotten.” Retired media isn’t automatically safe to hold onto forever. Confirm disposal or proper re-purposing, with proof of sanitization if required.

• Don’t rush the sign-off. Take time to review discrepancies and close gaps. A rushed job creates gaps that only show up later.

What a QSA—or anyone auditing security controls—looks for

From a governance perspective, QSAs are listening for two things: that the process exists, and that it actually works. They want to see:

• Documentation of the annual inventory policy, including scope and responsibilities.

• Evidence of the physical verification, with notes on what was found and what wasn’t.

• A reconciliation trail linking the inventory to asset logs, backups catalogs, and offsite storage records.

• Evidence of secure handling for media that contains or previously contained cardholder data, including storage, access controls, encryption, and disposal methods.

• A corrective action plan for any gaps found during the inventory, plus a timeline for fixes.

Real-world flavor: why this matters beyond the checklist

Imagine you’re managing a multi-location retail operation with a few remote warehouses. Throughout the year, devices move, backups are refreshed, and old drives drift into a back room. If you don’t have an annual inventory, you could miss a stray USB drive or a retired tape that still holds sensitive data. A yearly check helps you catch that drift, close the gaps, and keep the whole system honest.

The human side of the equation

Compliance work isn’t just about ticking boxes. It’s a team sport. The people who handle media day to day—IT staff, custodians, office managers, and the security lead—need to feel ownership. A simple, clear policy, a regularly reviewed process, and transparent reporting make the annual cycle less painful and more practical. And when teams see the benefit—less risk, fewer surprises during audits, smoother incident response—it becomes easier to stay engaged.

A few quick, practical resources and ideas

• Start with a one-page policy that defines “media” and sets the annual cadence. Keep it lightweight but precise.

• Use a tagging system for physical media. Durable labels, a simple color code, and a master list help everyone know where things belong.

• Leverage an asset management tool if you have one; if not, a well-maintained spreadsheet still works (just protect it with access controls and version history).

• Schedule a yearly inventory window and assign a backstop owner for emergencies. Treat it as a fixed calendar item, not a “when there’s time” task.

• Review your disposal policies, especially for media that has contained sensitive data. Ensure processes match regulatory expectations and internal security standards.

A closing thought

If you’re steering a PCI DSS program, this annual media inventory is a small habit with big payoffs. It’s not about fear of a flag on a form; it’s about practical risk reduction. When media is accounted for, tagged, and checked, you gain a clearer view of your data landscape. You stop wondering whether a stray drive is sitting in a drawer somewhere, and you start knowing—confidently—that you’ve done what’s needed to protect sensitive information.

So, take a breath, map your media, set the yearly check, and keep the conversation alive with the people who touch it every day. The result isn’t just a compliant label on a page—it’s a safer environment for customers, a calmer operation for staff, and a stronger shield for your organization’s reputation. And that, in the end, feels just right.