Requirement 8: Identify Users and Authenticate Access to System Components
Overview
Assigning a unique identification (ID) to each person with access ensures that actions taken on critical data and systems are performed by, and can be traced to, known and authorized users and processes. The effectiveness of a password is largely determined by the design and implementation of the authentication system—particularly, how frequently password attempts can be made by an attacker, and the security methods to protect user passwords at the point of entry, during transmission, and while in storage.
Requirements for these authentication mechanisms are provided in the following requirements.
Refer to Appendix G for definitions of PCI DSS terms.
Sections
- 8.1: Processes and mechanisms for identifying users and authenticating access to system components are defined and understood.
- 8.2: User identification and related accounts for users and administrators are strictly managed throughout an account's lifecycle.
- 8.3: Strong authentication for users and administrators is established and managed.
- 8.4: Multi-factor authentication (MFA) is implemented to secure access into the CDE.
- 8.5: Multi-factor authentication (MFA) systems are configured to prevent misuse.
- 8.6: Use of application and system accounts and associated authentication factors is strictly managed.
8. Identify and Authenticate Access to System Components
Ensure secure access to cardholder data environments through robust user identification, strong authentication mechanisms, and continuous monitoring of access patterns.
Control Types
Key Risks
Frequently Asked Questions
What are the critical password requirement changes in PCI DSS 4.0.1?
PCI DSS 4.0.1 mandates: 1) Minimum password length increased to 12 characters (from 7) for new implementations, 2) Service providers must implement MFA or enforce 90-day password rotations, and 3) Phishing-resistant authentication methods required for administrative access. These changes apply to all interactive accounts accessing CDE systems, with legacy systems requiring compensating controls until modernization.
How should MFA be implemented under Requirement 8?
Implement phishing-resistant MFA for: 1) All non-console administrative access, 2) Third-party remote access sessions, and 3) Cloud-based CDE entry points. Use FIDO2 security keys or PIV cards for administrators. For POS systems, implement transaction-specific MFA challenges. PCI DSS 4.0.1 requires quarterly testing of MFA failover mechanisms and cryptographic verification of authentication tokens.
What documentation is required for user access management?
Maintain: 1) Unique ID assignment records with UPN mappings, 2) MFA configuration templates for different access scenarios, 3) Password complexity rules aligned with NIST 800-63B, and 4) Automated account lifecycle workflows. PCI DSS 4.0.1 specifically requires version-controlled access revocation procedures and cryptographic audit trails for privilege changes.
How to manage legacy systems incompatible with modern authentication?
For legacy systems: 1) Implement network segmentation with IPS monitoring, 2) Use credential vaulting solutions like CyberArk, 3) Enforce daily password rotations via service accounts, and 4) Conduct weekly manual access reviews. All exceptions require quarterly risk assessments and compensating control validation through penetration testing.
What are the requirements for third-party access management?
Implement: 1) Just-in-Time access with 4-hour maximum session durations, 2) Session recording for all vendor activities, 3) Separate RBAC profiles with activity monitoring, and 4) Automated deprovisioning post-contract. PCI DSS 4.0.1 mandates quarterly attestations of third-party compliance and cryptographic verification of access approvals.
Common QSA Questions
Demonstrate unique ID implementation across hybrid environments?
Our identity system uses: 1) Azure AD UPNs for cloud resources, 2) On-prem AD SIDs synchronized via Azure Connect, and 3) Service principal IDs for APIs. Evidence includes Entra ID audit logs showing 100% unique authentication events across 15,000+ endpoints, with automated alerts for duplicate ID creation attempts.
Show MFA enforcement for all administrative access points?
We enforce FIDO2 security keys for: 1) SSH access via Azure MFA for Linux, 2) Windows Admin Center logins, and 3) Cloud console access. Logs show 100% MFA coverage across 450 privileged accounts. Emergency break-glass accounts use Thales HSMs with quorum authentication requiring 3 security officers.
Provide evidence of password policy enforcement mechanisms?
Our automated system includes: 1) 14-character minimum via AD Password Policies, 2) Banned password lists with 10M+ entries, 3) 90-day rotations enforced via SailPoint, and 4) Real-time hash analysis preventing reused patterns. Last quarter's audit showed 0 password policy exceptions across 12,000 user accounts.
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