PCI DSS Requirement 10: what it asks for and how to comply without building a security team

Requirement 10 is the part of PCI DSS that most merchants and service providers find hardest to keep up with, because it is not a one-time fix. It asks you to collect security logs from every in-scope system, protect them, review them every day, keep them for a year, and notice when a control stops working. This page explains what version 4.0.1 requires in plain language, which SAQs it shows up in, and how Managed SOC + SIEM from Clone Systems does the ongoing work for you.

What Requirement 10 actually requires

Log everything in scope (10.2)

Audit logs must be on for every system component in the cardholder data environment and must capture specific events: every access to cardholder data, every action by an administrator, every access to the logs themselves, failed login attempts, changes to accounts and credentials, logs being started, stopped or paused, and system-level objects being created or deleted. Each entry has to record who, what, when, where and the outcome.

Protect the logs (10.3)

Only people with a job-related need can read the logs, nobody can alter them, they are backed up promptly to a central log server, and file integrity monitoring or change detection alerts if existing log data is changed.

Review them every day (10.4)

Security events, logs from systems that store, process or transmit cardholder data, logs from critical systems and from systems that perform security functions must be reviewed at least once a day. Since 31 March 2025 that review must use automated mechanisms (10.4.1.1). Anything unusual has to be followed up and resolved, not just noted.

Keep a year of history (10.5)

At least 12 months of audit log history, with at least the most recent three months immediately available for analysis.

Keep the clocks right (10.6)

Every system uses synchronized time from a reliable source so events can be lined up across systems during an investigation.

Notice when a control fails (10.7)

Failures of critical security controls, including firewalls, intrusion detection, anti-malware, access controls, the logging itself and the log review process, must be detected, alerted on and dealt with promptly. As of 31 March 2025 this applies to all entities, not only service providers.

Requirement 11.5 comes along with it

Requirement 10 is about seeing what happened. Requirement 11.5 is about catching intrusions and unauthorized changes as they happen. Assessors look at the two together, and the same platform usually covers both.

Intrusion detection and prevention (11.5.1)

Intrusion detection or prevention techniques must watch all traffic at the perimeter of the cardholder data environment and at critical points inside it, alert on suspected compromises, and be kept current.

Change detection (11.5.2)

A change-detection mechanism such as file integrity monitoring must alert on unauthorized changes to critical system files, configuration files and content files, with comparisons at least weekly.

Which SAQs include Requirement 10

Not every self-assessment questionnaire includes the full requirement. The table is a guide; confirm your SAQ with our PCI SAQ Finder.

Who you areSAQRequirement 10 and 11.5 scope
Merchant with all card data handled by a validated third party, website redirects or iframesSAQ AMinimal; logging requirements largely fall on your provider
E-commerce merchant whose website affects the payment pageSAQ A-EPPartial; logging, log review and retention for the systems that touch the payment page
Merchant with a payment application connected to the internetSAQ CPartial; logging and review for the in-scope payment systems
Merchant that does not fit a shorter SAQ, or any service providerSAQ DFull Requirement 10 and 11.5
Any organization assessed by a QSA for a Report on ComplianceROCFull Requirement 10 and 11.5

How Managed SOC + SIEM covers it

We sell one service, Managed SOC + SIEM. Here is how it maps to the requirement, line by line.

Logging (10.2)

The SIEM collects logs from your in-scope systems, including syslog from network devices, agents on servers and workstations, and API connections to your cloud, identity and security tools, into one place with every event stamped with who, what, when and where.

Protection (10.3)

Logs are stored centrally on your SIEM, hosted in our data centers in Philadelphia, Athens or Limassol, or deployed in your own environment, encrypted in transit and protected from modification.

Daily and automated review (10.4)

Detection rules check your logs continuously, which satisfies the automated review mechanism the standard now requires, and Clone Systems analysts in the United States and the EU work the incident queue 24/7, so exceptions are investigated and resolved rather than filed.

Retention (10.5)

Retention is set to meet the 12 months of history and three months immediately available that PCI DSS requires, and can be set longer if another framework needs it.

Control failure detection (10.7)

A quiet-source rule set for each monitored control raises an alert when it stops reporting, and a log source health report lists anything that has gone silent, so the SOC knows when a control fails.

Intrusion detection (11.5.1)

Inline intrusion prevention is available as a managed service alongside the SOC, with alerts correlated in the same SIEM.

Change detection (11.5.2)

File changes on monitored endpoints flow into the SIEM, so unauthorized changes to critical files are alerted on and investigated.

Evidence for your assessor

Scheduled reports aligned to PCI DSS, delivered as PDF or Excel, give your QSA or your SAQ the review evidence, retention evidence and incident history in one place.

How to decide

  1. You are on SAQ A. You probably do not need this page. Keep your quarterly ASV scans current.
  2. You are on SAQ A-EP or SAQ C and someone reviews logs by hand. Since March 2025 the review has to be automated. Managed SOC + SIEM covers it, and the 50 endpoint minimum is the thing to check first.
  3. You are on SAQ D or going through a ROC. Requirement 10 and 11.5 apply in full. This is the service built for you.
  4. You are a service provider. You also carry the control-failure detection requirement, which the SOC handles as part of normal monitoring.
  5. Your logs cannot leave your environment. Self-host the SIEM with us managing it. The analysts and the AI work the same way.

What it costs, in structure

Managed SOC + SIEM is priced per monitored endpoint with a 50 endpoint minimum, on a one-year term with multi-year available. The SIEM, the analysts and the private AI are included. It is sold directly through a scoping call and demo, not online.

Managed SOC + SIEM

Hand Requirement 10 to a team that does it every day.

Tell us your SAQ, your endpoint count and where your logs need to live, and we will tell you plainly what is covered and what is not.

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FAQ

PCI DSS Requirement 10 questions, answered.

Does PCI DSS require a SIEM?

Not by name. It requires logging, protection, daily automated review, 12-month retention and failure detection. A SIEM with people watching it is the practical way most organizations meet all of those at once.

How long do PCI logs have to be kept?

At least 12 months, with the most recent three months immediately available for analysis (Requirement 10.5.1).

Do we have to review logs every day?

Yes, for security events and for logs from in-scope and critical systems, and since 31 March 2025 the review must use automated mechanisms. Other logs are reviewed on a schedule set by your targeted risk analysis.

Does Requirement 10 apply to my SAQ?

In full for SAQ D and any Report on Compliance; in part for SAQ A-EP and SAQ C; barely at all for SAQ A. Use our SAQ Finder to confirm which one you are on.

Can you cover Requirement 10 if our logs cannot leave our environment?

Yes. The SIEM can be deployed in your environment, with our analysts and AI working in it the same way as in our data centers.

Does this replace our quarterly ASV scans?

No. ASV scans satisfy Requirement 11.3.2. Managed SOC + SIEM covers Requirements 10 and 11.5. Most PCI customers need both, and Clone Systems provides both.