What evidence do auditors commonly ask for on 8.3.9 Single-factor passwords changed every 90 days or dynamic analysis?

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.

What is the most common gap auditors find on 8.3.9?

Password expiry disabled on systems that still rely on passwords alone

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

`8.3.9` Single-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.

Source: PCI DSS v4.0.1, 8.3.9. 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

Maximum password age setting of 90 days or less on those systems · Identity provider / directory
Or configuration and decision logs of the dynamic, risk-based access engine · Identity provider / directory

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

Inventory of in-scope systems using password-only authentication · Policy repository / GRC workspace
Documentation of which option applies to each system · 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

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

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

8.3.8 Authentication policies communicated to users · 8.3.10 Service provider customer password guidance