What evidence do auditors commonly ask for on AC.8 Passwordless Authentication?

List of accounts using passwordless authentication and the method in use; Authenticator registration and revocation records; Policy statement covering accepted passwordless methods.

What is the most common gap auditors find on AC.8?

passwordless treated as out of scope so no control is evidenced

UK Cyber Essentials · User Access Control

`AC.8` Passwordless Authentication

Where identity is established without a password, use a recognised passwordless method such as a FIDO2 authenticator or passkey, biometric, hardware security key or token, push notification or one-time code, and manage it as the authentication control for the account.

Source: UK Cyber Essentials, AC.8. 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 UK Cyber Essentials in the compliance library.

The version of the requirements is not stamped here; check the question set your certification body uses.

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

List of accounts using passwordless authentication and the method in use · Identity provider / directory
Authenticator registration and revocation records · Identity provider / directory

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

Policy statement covering accepted passwordless methods · 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

passwordless treated as out of scope so no control is evidenced
no revocation process when a security key or device is lost
method claimed as MFA when no user authentication is performed

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

AC.7 MFA for Administrative Accounts · FW.1 Boundary Firewalls Deployed