8.4.2 MFA is implemented for all non-console access into the CDE
MFA is implemented for all non-console access into the CDE.
5
artefacts
1
held by a system
1
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
system holds itEvidence a system already holds
- Observation of a non-administrative user logging in with evidence multi-factor was required · Identity provider / directory
periodic reviewEvidence produced at each review
- Evidence covering user accounts as well as administrative ones · Identity provider / directory
governing documentDocuments that govern the control
- Network and system configurations showing multi-factor authentication is implemented for all non-console access into the cardholder data environment · Policy repository / GRC workspace
- Complete enumeration of non-console access paths into the environment, including application, remote desktop and API paths · Policy repository / GRC workspace
- Handling of accounts or paths that cannot support multi-factor, with the compensating position documented · Policy repository / GRC workspace
First move
Mostly documents and reviews. Pull the 1 system-held artefact from your Identity provider / directory on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.
Common gaps auditors find
- Multi-factor required for administrators under 8.4.1 while ordinary user access into the environment still relies on a single factor
- Application to application and batch access paths into the environment excluded with no documented position on why
- Access paths enumerated from the network diagram rather than from the live estate, so an undocumented path is never assessed
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 sheet8.4.1 MFA is implemented for all non-console access into the CDE for personnel with administrative access · 8.4.3 MFA is implemented for all remote access originating from outside the entity's network that could access or impact the CDE