PCI DSS: what it asks of an account list
PCI DSS v4.0 applies where card data is in scope. It sets its own periods: inactive user accounts removed or disabled within 90 days (8.2.6), user accounts and privileges reviewed at least every six months (7.2.4), a password used alone changed at least every 90 days (8.3.9); for application and system accounts the review frequency (7.2.5.1) and the password change frequency (8.6.3) are set by your own targeted risk analysis. User-account periods never read on a system account here, and system-account lines never read on a person.
When to tick it: tick it only when card data is in scope for the systems in the list.
Findings that cite it
| Finding | Clause |
|---|---|
| 1. A leaver's own account is still enabled | PCI DSS 8.2.5 (every account type) |
| 4. Dormant for more than the threshold | PCI DSS 8.2.6 (user accounts only) |
| 6. Password or key not changed within the period, or never | PCI DSS 8.3.9 (user accounts whose MFA does not read yes) PCI DSS 8.6.3 (application and system accounts only) |
| 7. Service or system account that allows interactive login | PCI DSS 8.6.1 (application and system accounts only) PCI DSS 7.2.5 (application and system accounts only) |
| 8. Credential stored in code, a config file or a script | PCI DSS 8.6.2 (application and system accounts only) |
| 9. Shared or generic login used by people | PCI DSS 8.2.2 (every account type) PCI DSS 8.2.1 (every account type) |
| 10. Not reviewed within the interval | PCI DSS 7.2.4 (user accounts only) PCI DSS 7.2.5.1 (application and system accounts only) |
| 12. Created with no approval recorded | PCI DSS 8.2.4 (every account type) |
| 13. Vendor default or built-in account enabled | PCI DSS 2.2.2 (every account type) |
PCI DSS: every clause cited
14 of the 280 heldThe requirement text is our statement of each clause, read against the copy we hold and cited to it; it is not the instrument verbatim.
PCI DSS 2.2.2Vendor default accounts managedVendor default accounts must be handled as follows: (a) where a vendor default account will be used, its default password is changed in line with Requirement 8.3.6; and (b) where it will stay unused, the account is disabled or deleted. Applicability: every vendor default account and password is covered, for example those of operating systems, security software, application and system accounts, POS terminals, payment applications and SNMP defaults; it also applies to components not installed in the entity's environment, such as CDE software and applications consumed through a cloud subscription. Objective under the customized approach: default passwords cannot be used to access system components.
PCI DSS 7.2.4User accounts and privileges reviewed every six monthsAll user accounts and their related access privileges, including third-party and vendor accounts, must be reviewed at least every six months. The review must confirm that accounts and access remain appropriate for each person's job function, any inappropriate access must be dealt with, and management must acknowledge that the remaining access is appropriate. The guidance notes the review is also a chance to catch terminated users and third parties whose access was missed. Applicability: covers every user account and related privilege, including accounts of personnel, of vendors and of other third parties and accounts used to reach third-party cloud services; application and system accounts are handled instead by Requirement 7.2.5 (and its sub-requirement) and by 8.6.1 to 8.6.3. Objective under the customized approach: management periodically verifies that account privilege assignments are correct and remediates nonconformities. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.
PCI DSS 7.2.5Application and system accounts least privilegeEvery application and system account and its related access privileges must be assigned and managed so that: privileges are the least needed for the system or application to operate; and access is limited to those systems, processes or applications that have a specific need for the account. The guidance explains that a compromised service account gives an attacker whatever the account can reach, and suggests entities may consider a baseline that keeps such accounts out of privileged groups such as domain or local administrators or root, restricts the machines and hours they can be used, and removes VPN or remote access. Objective under the customized approach: the rights given to system and application accounts are confined to what that application or system needs to operate. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.
PCI DSS 7.2.5.1Application and system account access reviewed periodicallyAll access held by application and system accounts, together with their related privileges, must be reviewed periodically, at a frequency set by the entity's own targeted risk analysis carried out as Requirement 12.3.1 specifies. Each review must confirm that the account's access is still appropriate for the function it performs, address any inappropriate access, and record management's acknowledgement that the access remains appropriate. Objective under the customized approach: management periodically verifies that privilege assignments for application and system accounts are correct and remediates nonconformities. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.
PCI DSS 8.2.1Unique ID assigned to every userEach user must be given a unique ID before being permitted to reach any system component or cardholder data. The guidance explains that unique identification keeps actions traceable to one person, supports individual accountability and an effective audit trail, and helps resolve and contain misuse. Applicability: not intended for point-of-sale terminal user accounts that are limited to a single card number per transaction. Customized approach objective: every action by every user can be attributed to an individual.
PCI DSS 8.2.2Shared and generic IDs only by exceptionGroup, shared or generic IDs, and any other shared authentication credentials, may be used only where needed as an exception, and must be managed so that: use of the ID is blocked unless an exceptional circumstance calls for it; use lasts only as long as the exceptional circumstance requires; a business justification is documented; management explicitly approves the use; the identity of the individual is verified before the account is made available; and every action taken is attributable to one individual user. The guidance suggests password vaults or controls like sudo, and gives a break-glass emergency account as an example of an exception. Applicability: not intended for point-of-sale terminal user accounts that are limited to a single card number per transaction. Objective under the customized approach: all actions carried out with group, shared or generic IDs can be attributed to an individual person.
PCI DSS 8.2.4User ID lifecycle changes authorizedAny addition, deletion or modification of a user ID, an authentication factor or another identifier object must be: authorized with appropriate approval; and carried out with only the privileges stated on the documented approval. The guidance stresses detecting IDs created or changed outside the normal process, since attackers often escalate an existing account or create new IDs. Applicability: covers every user account, whether held by employees, contractors, consultants, temporary staff or third-party vendors. Objective under the customized approach: no lifecycle event affecting a user ID or authentication factor can occur without appropriate authorization.
PCI DSS 8.2.5Terminated users' access revoked immediatelyAccess for users who have been terminated must be revoked immediately. The testing procedures check both local and remote access lists for terminated IDs and confirm that any physical authentication factor, for example a token or smart card, has been deactivated or handed back. The guidance explains that a former employee or third party who keeps a working account, or an attacker who takes over an abandoned one, could reach cardholder data. Objective under the customized approach: accounts belonging to terminated users cannot be used.
PCI DSS 8.2.6Inactive accounts removed within 90 daysA user account must be disabled or removed once it has gone unused for 90 days. The guidance explains that unused accounts are attractive targets because changes to them, such as a new password, tend to go unnoticed, and advises that where an extended absence such as a leave of absence is expected, the account be disabled when the absence begins rather than after 90 days. Objective under the customized approach: inactive user accounts cannot be used.
PCI DSS 8.2.7Third-party remote access accounts controlledWhere a third party reaches, supports or maintains system components remotely, the accounts it uses must be: switched on only for as long as needed and switched off when idle; and monitored for unexpected activity. The guidance advises that where round-the-clock access is genuinely needed it be recorded, justified, watched and linked to particular service needs, and suggests start and stop dates aligned with the service contract. Objective under the customized approach: remote access by third parties is unusable unless specifically authorized, and management oversees its use.
PCI DSS 8.3.9Single-factor passwords changed every 90 days or dynamic analysisIf user access relies on a password or passphrase alone (any single-factor implementation), one of these must hold: the password or passphrase is replaced no less often than every 90 days; or account security posture is assessed dynamically, with access to resources decided automatically and in real time from that assessment. The guidance notes that dynamic analysis may weigh data points such as device integrity, location, access times and resources requested. Applicability: does not apply to in-scope components where MFA is used; not intended for point-of-sale terminal user accounts that are limited to a single card number per transaction. Customer accounts of service providers are excluded, while accounts used by service provider staff are included. Objective under the customized approach: an undetected compromised password or passphrase cannot be used indefinitely.
PCI DSS 8.6.1Interactive use of system accounts controlledWhere a system or application account is capable of interactive login, it must be managed so that: interactive use is prevented unless an exceptional circumstance requires it; interactive use lasts no longer than the exceptional circumstance requires; the business justification is documented; management explicitly approves interactive use; the individual's identity is verified before the account is made available; and each action performed is attributable to one individual user. The guidance advises that, where possible, such accounts be configured to disallow interactive login and limited to specific machines and devices. Objective under the customized approach: whenever system or application accounts are used interactively, each action is authorized and traceable to one person. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.
PCI DSS 8.6.2No hard-coded passwords for interactive system accountsPasswords or passphrases belonging to any application or system account capable of interactive login must never be hard coded in scripts, in configuration or property files, or in bespoke or custom source code. The guidance suggests password vaults and other system-managed controls can help. Applicability: stored passwords must be encrypted in line with Requirement 8.3.2. Objective under the customized approach: unauthorized personnel are unable to use the passwords and passphrases of application and system accounts. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.
PCI DSS 8.6.3System account passwords protected against misusePasswords or passphrases used by system and application accounts must be protected against misuse so that: they are changed periodically, at the frequency set by the entity's own targeted risk analysis performed per Requirement 12.3.1, and upon suspected or confirmed compromise; and they are built with enough complexity for how often the entity changes them. The guidance lists risk factors to weigh (how securely they are stored, such as in a vault; staff turnover; how many people can reach the factor; whether interactive login is possible; and whether dynamic posture analysis is used) and advises that complexity be stricter where changes are infrequent. Objective under the customized approach: passwords of application and system accounts cannot stay usable indefinitely and are built so that guessing and brute-force attacks fail. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.