PCI DSS Security Maturity Model·AWS v1.0.0
Foundational Threat Detection 🤝 Shared

r10.2 Centralize and protect logs against tampering

Protect audit logs against unauthorized modification or deletion and retain them per the required period (at least 12 months, with 3 months immediately available).

Quick Wins
Foundational
Efficient
Optimized
Effort: Medium Impact: High Applies to CDE: Yes

AWS services

AWS CloudTrail Amazon S3 AWS KMS Amazon CloudWatch Logs

Requirement 10

Log and Monitor All Access to System Components and Cardholder Data

PCI sub-requirements covered

  • 10.3 Audit logs are protected from destruction and unauthorized modifications
  • 10.5 Audit log history is retained and available for analysis

How to implement on AWS

Enable CloudTrail log file validation. Apply S3 Object Lock (WORM) and restrictive policies on the log bucket, with limited access in a dedicated account. Encrypt logs with KMS. Define S3 Lifecycle for retention >= 12 months (Glacier for archival, with 3 months immediately available).

Practical implementation

How this control is implemented in each reference architecture:

Enable CloudTrail log file validation, apply S3 Object Lock (WORM) and a restrictive bucket policy, encrypt with KMS, and set Lifecycle for >=12 months retention in the account.

Single-account, 3-tier →

Centralize all audit logs in the dedicated log-archive account with Object Lock, KMS, and access restricted even from the rest of the org, giving tamper-resistant, consolidated retention across every CDE account.

Multi-account with a dedicated PCI OU →

PCI validation

Testing methods: examineobserve

Testing procedures

  • Examine configurations and privileges to verify read access to audit logs is limited to those with a job-related need and that logs are protected from modification (10.3.1, 10.3.2).
  • Examine backup configurations to verify logs are promptly backed up to a secure central server difficult to modify, with file integrity/change detection in use (10.3.3, 10.3.4).
  • Examine retention configurations to verify audit log history is retained at least 12 months with the most recent 3 months immediately available (10.5.1.b, 10.5.1.c).

Evidence in AWS

  • CloudTrail log file validation enabled.
  • S3 Object Lock (WORM) and log bucket policy with restricted access.
  • S3 Lifecycle rules evidencing retention >= 12 months and KMS encryption.

Customized approach

Requires a targeted risk analysis (Req 12.3.2).

Customized Approach Objective

  • 10.3 — Stored activity records cannot be accessed by unauthorized personnel and are protected from destruction and unauthorized modification.
  • 10.5 — Historical records of activity are available immediately to support incident response and are retained for at least 12 months.

Learning resources

References

  • AWS Security Maturity Model: Centralized logging
  • PCI DSS v4.0.1 Requirements 10.3, 10.5