What evidence do auditors commonly ask for on 8.3.7 No reuse of last four passwords?

Password history setting of four or more on directories and applications; Configuration exports for systems with local authentication; Test record showing a recently used password is rejected; Password standard specifying the history rule.

What is the most common gap auditors find on 8.3.7?

History set to four but minimum password age of zero lets users cycle through quickly

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

`8.3.7` No reuse of last four passwords

Individuals must not be able to submit a new password or passphrase that matches any of the last four they used. The guidance explains that keeping password history stops users cycling back to passwords that may have been guessed, brute-forced or changed due to suspected compromise. Applicability: not intended for point-of-sale terminal user accounts that are limited to a single card number per transaction. Customized approach objective: an old password cannot be used again to reach an account for a minimum of 12 months.

Source: PCI DSS v4.0.1, 8.3.7. 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

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

Password history setting of four or more on directories and applications · Identity provider / directory
Configuration exports for systems with local authentication · Identity provider / directory
Password standard specifying the history rule · Identity provider / directory

periodic reviewEvidence produced at each review

Test record showing a recently used password is rejected · Identity provider / directory

governing documentDocuments that govern the control

none for this control

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

History set to four but minimum password age of zero lets users cycle through quickly
Local application accounts keep no password history
History rule missing on network device local accounts

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

8.3.6 Password minimum length 12 and complexity · 8.3.8 Authentication policies communicated to users