EvidenceSheet

8.4.3 MFA for remote access that could reach CDE

MFA must be implemented for all remote access that originates outside the entity's network and could access or affect the CDE. Applicability: covers all user accounts able to access the network remotely where that access leads, or could lead, into the CDE, including staff, both users and administrators, and third parties such as vendors, suppliers, service providers and customers. Remote access to a network segment properly isolated from the CDE does not need MFA, though MFA is recommended for every remote connection into the entity's networks. It covers every kind of system component (cloud and hosted systems, on-premises applications, workstations, servers, endpoints and network security devices) and both direct and web-based access. The guidance defines MFA as presenting at least two of the three factor types from 8.3.1. Customized approach objective: a single authentication factor is never enough to gain remote access into the entity's network.

Source: PCI DSS v4.0.1, 8.4.3. 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
1
held by a system
2
at each review
moderate
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

  • VPN, VDI and remote access gateway MFA configuration · Identity provider / directory

periodic reviewEvidence produced at each review

  • Segmentation evidence for any remote access path claimed to be isolated from the CDE · Identity provider / directory
  • Observation records of employee and third-party remote connections · Identity provider / directory

governing documentDocuments that govern the control

  • Inventory of remote access methods, including vendor tools, with MFA status · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (Identity provider / directory); keep the periodic reviews but log each one as a dated record with a named reviewer.

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

8.4.2 MFA for all non-console CDE access · 8.5.1 MFA system resistant to replay and bypass