Orphaned Account Checker

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

FindingClause
1. A leaver's own account is still enabledPCI DSS 8.2.5 (every account type)
4. Dormant for more than the thresholdPCI DSS 8.2.6 (user accounts only)
6. Password or key not changed within the period, or neverPCI 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 loginPCI 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 scriptPCI DSS 8.6.2 (application and system accounts only)
9. Shared or generic login used by peoplePCI DSS 8.2.2 (every account type)
PCI DSS 8.2.1 (every account type)
10. Not reviewed within the intervalPCI DSS 7.2.4 (user accounts only)
PCI DSS 7.2.5.1 (application and system accounts only)
12. Created with no approval recordedPCI DSS 8.2.4 (every account type)
13. Vendor default or built-in account enabledPCI DSS 2.2.2 (every account type)

PCI DSS: every clause cited

14 of the 280 held

The 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 managed

Vendor 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.

What an auditor asks to see: Inventory of vendor default accounts per system type with disposition (used and re-passworded, or removed/disabled); Configuration files or directory exports showing unused default accounts disabled or deleted; Evidence that retained default accounts use passwords meeting Requirement 8.3.6; Observation record of failed log-on attempts using known default credentials; SNMP configuration showing default community strings changed
Where account lists usually fall short: Default credentials remain on POS terminals, network appliances or out-of-band management interfaces; SaaS or cloud subscription admin accounts retain vendor-provided initial passwords; Default accounts disabled but the default password left unchanged, allowing re-enablement
Source: PCI DSS v4.0
PCI DSS 7.2.4User accounts and privileges reviewed every six months

All 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.

What an auditor asks to see: Semi-annual user access review records for each in-scope system, with review dates; Evidence that inappropriate access found was removed or corrected, such as closed tickets; Management sign-off acknowledging access remains appropriate; Inventory of third-party, vendor and cloud-service accounts included in the review scope
Where account lists usually fall short: Reviews cover employees but omit vendor accounts and cloud console users; Reviewers rubber-stamp lists without evidence of removals being actioned; Interval between reviews exceeds six months for some systems; No management acknowledgement is recorded at the end of the review
Source: PCI DSS v4.0
PCI DSS 7.2.5Application and system accounts least privilege

Every 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.

What an auditor asks to see: Inventory of application and system (service) accounts with owner, purpose and systems used; Privilege and group membership export for each service account; Service account baseline or standard (no privileged group membership, host and time restrictions); Procedure for requesting and approving new application or system accounts
Where account lists usually fall short: Service accounts are members of domain admins for convenience; Service account can log on to any host rather than only the servers that need it; No owner or documented purpose exists for many legacy service accounts
Source: PCI DSS v4.0
PCI DSS 7.2.5.1Application and system account access reviewed periodically

All 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.

What an auditor asks to see: Targeted risk analysis defining the service account review frequency, prepared per 12.3.1; Completed service account review records at the defined frequency; Remediation tickets for excessive or unneeded service account privileges; Management acknowledgement recorded for each review cycle
Where account lists usually fall short: Review frequency is stated in policy without any supporting targeted risk analysis; Service accounts are excluded from the user access review and never reviewed; Accounts for decommissioned applications remain active after review
Source: PCI DSS v4.0
PCI DSS 8.2.1Unique ID assigned to every user

Each 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.

What an auditor asks to see: User account listings from in-scope systems showing one ID per person; Account naming standard and provisioning procedure requiring unique IDs; Audit log samples showing actions tied to named individual IDs; HR-to-directory reconciliation confirming each account maps to one person
Where account lists usually fall short: Several operators share one login on a management console; Contractors reuse IDs of staff who have left; Logs show generic accounts that cannot be traced to a person
Source: PCI DSS v4.0
PCI DSS 8.2.2Shared and generic IDs only by exception

Group, 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.

What an auditor asks to see: Register of shared, group and generic accounts with business justification and management approval; Password vault checkout logs tying each use of a shared account to a named individual; Break-glass procedure and records of each emergency use with duration; Account configuration showing shared IDs disabled or locked outside approved use
Where account lists usually fall short: Root or built-in administrator password known by the whole team and used routinely; No record of who used a shared account at a given time; Shared account kept permanently enabled rather than for the duration of the exception; Justification documented but no explicit management approval
Source: PCI DSS v4.0
PCI DSS 8.2.4User ID lifecycle changes authorized

Any 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.

What an auditor asks to see: Joiner, mover and leaver tickets with approvals for a sample of accounts; Directory audit logs of account creation, change and deletion events; Comparison of granted privileges against privileges stated on each approval; Alerts or reports for accounts created outside the provisioning workflow
Where account lists usually fall short: Accounts created directly by administrators without a ticket; Temporary workers provisioned with more privileges than approved; Changes to authentication factors are not captured in any approval record
Source: PCI DSS v4.0
PCI DSS 8.2.5Terminated users' access revoked immediately

Access 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.

What an auditor asks to see: HR termination list for the period reconciled against active account lists; Deprovisioning tickets with timestamps relative to termination dates; Remote access (VPN, SaaS, cloud) account listings checked for leavers; Token or smart card return and deactivation log
Where account lists usually fall short: Leavers disabled in the directory but still active in SaaS or VPN systems; Days elapse between termination and account revocation due to manual handoffs; Hardware tokens of departed staff never recovered or deactivated
Source: PCI DSS v4.0
PCI DSS 8.2.6Inactive accounts removed within 90 days

A 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.

What an auditor asks to see: Last logon report for in-scope systems showing no enabled account idle beyond 90 days; Automated script or IAM policy that disables dormant accounts, with run logs; Procedure for handling accounts during extended leave; Exception list with justification for any account retained
Where account lists usually fall short: Dormant account job covers the directory but not local application accounts; Last logon attribute not replicated, making inactivity reports unreliable; Accounts of staff on long leave remain enabled
Source: PCI DSS v4.0
PCI DSS 8.2.7Third-party remote access accounts controlled

Where 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.

What an auditor asks to see: List of third-party remote access accounts with enable and disable dates; Access request records tying each enablement to a support need; Monitoring alerts or log reviews of vendor session activity; Vendor contracts or schedules defining access windows
Where account lists usually fall short: Vendor VPN accounts left permanently enabled; No review of what vendors do during their sessions; Unusual vendor activity not followed up
Source: PCI DSS v4.0
PCI DSS 8.3.9Single-factor passwords changed every 90 days or dynamic analysis

If 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.

What an auditor asks to see: Inventory of in-scope systems using password-only authentication; Maximum password age setting of 90 days or less on those systems; Or configuration and decision logs of the dynamic, risk-based access engine; Documentation of which option applies to each system
Where account lists usually fall short: Password expiry disabled on systems that still rely on passwords alone; Claimed dynamic analysis is only a static conditional access rule; Service provider staff accounts wrongly treated as customer accounts and excluded
Source: PCI DSS v4.0
PCI DSS 8.6.1Interactive use of system accounts controlled

Where 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.

What an auditor asks to see: List of application and system accounts with interactive logon capability flagged; Configuration denying interactive logon for service accounts (for example logon rights policies); Approval and justification records for each interactive use; Vault or PAM session logs tying interactive use to a named individual
Where account lists usually fall short: Engineers routinely log in as the application service account to troubleshoot; Interactive logon allowed for all service accounts by default; No record identifying who used a service account interactively
Source: PCI DSS v4.0
PCI DSS 8.6.2No hard-coded passwords for interactive system accounts

Passwords 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.

What an auditor asks to see: Secure coding standard prohibiting embedded credentials; Secret scanning results for code repositories and configuration files; Secrets vault integration configuration used by applications and scripts; Sample review of deployment scripts and property files
Where account lists usually fall short: Database service account password stored in a properties file in the repository; Scheduled scripts on servers contain plaintext credentials; Secret scanning run only on new commits, not historical code
Source: PCI DSS v4.0
PCI DSS 8.6.3System account passwords protected against misuse

Passwords 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.

What an auditor asks to see: Targeted risk analysis per 12.3.1 setting change frequency and complexity for service account passwords; Vault rotation logs or change records demonstrating rotation at the defined frequency; Records of rotation after suspected or confirmed compromise; Configuration showing complexity settings for service account credentials
Where account lists usually fall short: Service account passwords unchanged for years because rotation could break applications; Risk analysis sets a long rotation period without raising complexity; No process to rotate credentials when an administrator with knowledge leaves
Source: PCI DSS v4.0