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

8.3.10.1 Service provider customer passwords 90 days or dynamic

Service providers only (an additional requirement). If customer user access relies on a password or passphrase alone (that is, 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 and access decisions are made automatically in real time from it. Applicability: applies only when the assessed entity is a service provider; excludes consumers who log in to view their own payment card details. Until it took effect on 31 March 2025, service providers could satisfy either one of the two requirements (8.3.10 or this one). Objective under the customized approach: passwords and passphrases held by a service provider's customers cannot remain in use indefinitely. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.

Source: PCI DSS v4.0.1, 8.3.10.1. 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
2
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

  • Customer portal password expiry configuration of 90 days or less · Identity provider / directory
  • Or configuration and logs of dynamic risk-based access for customer accounts · Identity provider / directory

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

  • List of customer-facing systems relying on password-only authentication · Policy repository / GRC workspace
  • Design document stating which option is applied per portal · Document repository

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

8.3.10 Service provider customer password guidance · 8.3.11 Tokens, smart cards and certificates individually assigned