EvidenceSheet

8.6.1 Interactive use of system accounts controlled

Where a system or application account is capable of interactive login, it must be managed so that: interactive use is prevented unless an exceptional circumstance requires it; interactive use lasts no longer than the exceptional circumstance requires; the business justification is documented; management explicitly approves interactive use; the individual's identity is verified before the account is made available; and each action performed is attributable to one individual user. The guidance advises that, where possible, such accounts be configured to disallow interactive login and limited to specific machines and devices. Objective under the customized approach: whenever system or application accounts are used interactively, each action is authorized and traceable to one person. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.

Source: PCI DSS v4.0.1, 8.6.1. 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
3
held by a system
1
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

  • List of application and system accounts with interactive logon capability flagged · Identity provider / directory
  • Configuration denying interactive logon for service accounts (for example logon rights policies) · Identity provider / directory
  • Vault or PAM session logs tying interactive use to a named individual · Identity provider / directory

periodic reviewEvidence produced at each review

  • Approval and justification records for each interactive use · 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

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

8.5.1 MFA system resistant to replay and bypass · 8.6.2 No hard-coded passwords for interactive system accounts