EvidenceSheet
PCI DSS v4.0.1 · Req 8: Identify and Authenticate Users

8.2.5 Terminated 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.

Source: PCI DSS v4.0.1, 8.2.5. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open PCI DSS v4.0.1 in the compliance library.

Version 4.0.1 is the active version; 4.0 has been retired. Appendix A1 applies only to multi-tenant service providers, A2 only to card-present POS POI terminals that still use SSL or early TLS, and A3 only when a payment brand or acquirer requires it. Which requirements apply to you follows your validation type.

4
artefacts
3
held by a system
0
at each review
easy
to go live
Identity provider / directory
where the evidence lives
teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

  • HR termination list for the period reconciled against active account lists · Identity provider / directory
  • Deprovisioning tickets with timestamps relative to termination dates · Identity provider / directory
  • Token or smart card return and deactivation log · Identity provider / directory

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

  • Remote access (VPN, SaaS, cloud) account listings checked for leavers · Policy repository / GRC workspace

First move

Automate the pull from your Identity provider / directory. Scheduled export of users, roles and MFA state from the directory; access-review completion pulled from the IdP, not a spreadsheet.

Common gaps auditors find

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

8.2.4 User ID lifecycle changes authorized · 8.2.6 Inactive accounts removed within 90 days