What evidence do auditors commonly ask for on 8.3.5 Initial and reset passwords unique and changed?

Procedure for issuing initial and reset passwords; Directory setting forcing change at next logon for new and reset accounts; Sample of provisioning records showing generated, unique initial values; Observation of a reset performed by security staff.

What is the most common gap auditors find on 8.3.5?

New starters all receive the same seasonal default password

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

`8.3.5` Initial and reset passwords unique and changed

Where passwords or passphrases serve as authentication factors under Requirement 8.3.1, they must be set and reset for each user so that they are: given a unique value when first issued and whenever reset; and forced to be changed immediately after first use. Customized approach objective: nobody unauthorized can make use of a starting or reset password or passphrase issued to a user.

Source: PCI DSS v4.0.1, 8.3.5. 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.

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

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

none for this control

periodic reviewEvidence produced at each review

Sample of provisioning records showing generated, unique initial values · Identity provider / directory
Observation of a reset performed by security staff · Identity provider / directory

governing documentDocuments that govern the control

Procedure for issuing initial and reset passwords · Policy repository / GRC workspace
Directory setting forcing change at next logon for new and reset accounts · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

New starters all receive the same seasonal default password
Change-at-next-logon flag not set for accounts created by script
Reset passwords communicated in a predictable format

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

8.3.4 Lockout after 10 attempts for 30 minutes · 8.3.6 Password minimum length 12 and complexity