Payment card data remains one of the most targeted types of information in the world. Every time your systems store, process, or transmit cardholder data, you fall under the Payment Card Industry Data Security Standard (PCI DSS). Even if you have moved a lot of your payment services to third parties, your organization almost always retains some responsibility for protecting this data and for controlling who can access it.
In this article, I will briefly explain the role of PCI DSS and then focus on Requirement 8: identifying users and authenticating access to system components. You will see how it connects to identity and access management, which controls are essential, and how to implement them in a way that is realistic for your teams and technology stack.
Understanding PCI DSS and its link to identity and access management
PCI DSS is a global security standard created by the major card brands. It requires a baseline level of security for any organization that stores, processes, or transmits cardholder data. It covers network security, system configuration, vulnerability management, logging, and physical safeguards, but a large part of it depends on knowing who is doing what in your environment.
Requirement 8 in PCI DSS version 4.0 is where identity and access management become very concrete. It expects you to identify each user, authenticate them strongly, control their access, and keep records of their activity. If you already have an identity and access management (IAM) program, Requirement 8 should not be a separate effort. Instead, it should be a lens for tightening and documenting the controls you already rely on.
Core purpose of Requirement 8: Identify users and authenticate access correctly
Requirement 8 is titled “Identify users and authenticate access to system components.” In simple terms, it demands that you can clearly answer three questions for any system in the cardholder data environment: who accessed it, how they authenticated, and what kind of access they had.
To achieve that, Requirement 8 focuses on a few core expectations. Each user must have a unique identity. Authentication methods must be robust and resistant to common attacks. Privileged access must be limited and carefully monitored. Non-human accounts must not become blind spots. All these elements work together to create accountability and traceability when something goes wrong.
Unique user identification: No more anonymous or shared accounts
Unique user identification is the foundation of Requirement 8. If several people log in using the same generic account, you may be able to see what happened, but you cannot prove who did it. This makes incident response, forensic investigations, and even internal accountability very difficult.
In practice, you should assign each person a personal account through your identity provider. Administrators should use named admin accounts rather than relying on “admin” or “root” logins.
Suppose legacy systems require a shared technical account. In that case, you can place a privileged access management (PAM) solution in front of them so that individuals authenticate with their own identity. At the same time, PAM brokers the shared account and logs the session. This approach lets you satisfy operational constraints without compromising traceability.
Strong authentication and multi-factor authentication: Beyond passwords
Requirement 8 expects authentication to stand up to basic and common attacks. This means passwords alone are not enough, especially for sensitive or remote access. The standard pushes you toward strong authentication built around robust passwords and multi-factor authentication (MFA).
You should define clear password rules for length, complexity, and lockout behavior after repeated failures. However, the most important shift is consistent MFA use. Access into the cardholder data environment, remote connectivity such as VPN, and administrative access to key systems should all require MFA. Where possible, rely on secure factors such as authenticator apps or hardware keys, which are more resistant to phishing and SIM swapping than SMS codes.
From an operational point of view, a central MFA and single sign-on (SSO) platform simplifies enforcement. Instead of configuring MFA on each system separately, you protect key entry points such as VPN gateways, SSO portals, and PAM systems. This makes the user experience more consistent and your compliance evidence easier to maintain.
Privileged access: Managing the most powerful accounts carefully
Administrative accounts carry the most risk because they can change configurations, disable controls, or access large amounts of data. Requirement 8 expects you to treat these accounts very differently from standard users.
A good pattern is to give administrators two accounts: one for everyday business tasks and a separate one for administrative work. The administrative account should have stronger authentication requirements, including MFA and stricter password rules. Access to systems in the cardholder data environment should be limited to those with a valid business need, granted through a documented approval process.
Privileged Access Management tools can help you centralize access to admin interfaces, rotate privileged passwords, enable just-in-time access, and log or record sessions. Even if you start small, focusing on the most critical systems first, this already significantly reduces the risk of misuse or compromise of powerful accounts.
Service and application accounts: Handling non-human identities
Service accounts and application accounts are often underestimated, but they fall under Requirement 8 as well. These accounts are used by services, scripts, and applications, not people, but they can still be abused if poorly controlled.
You should treat each service account as an asset. Assign it a clear owner, document where it is used, and restrict its permissions to the minimum required level. Default vendor passwords should always be changed before deployment. Passwords or keys should be rotated regularly and especially when staff who had access to them leave the organization. Where possible, use secure methods like key-based authentication or certificates.
A simple inventory of service and application accounts, including their owners, systems, and last rotation date, can make a big difference. It helps you prepare for assessments, simplifies troubleshooting, and reduces the risk that an old, forgotten account becomes an attack path.
Lifecycle management: Getting joiners, movers, and leavers under control
Requirement 8 does not stop at login events. It also expects you to control how accounts are created, modified, and removed. This is often captured in the “joiner–mover–leaver” process.
When people join, their accounts should be created through a standard, approved process that links to their role. Role-based access control (RBAC) helps here by assigning pre-defined access profiles instead of building permissions from scratch each time. When roles change, access should be adjusted accordingly, not simply added on top. When people leave, their accounts in systems that are part of or connected to the cardholder data environment must be disabled or removed promptly, ideally on or before their last day.
Periodic access reviews by managers and data owners help you keep access aligned with current needs. Even a quarterly review of critical systems can catch stale or excessive permissions before they cause problems.
Monitoring, logging, and reviewing: Proving who did what
Even the best authentication and access policies do not guarantee perfect security. Requirement 8 works together with logging and monitoring requirements to ensure you can reconstruct what happened after an event.
From an authentication perspective, you should:
- Log all successful and failed authentication attempts to systems in scope.
- Log administrative actions and changes to access control configurations.
- Correlate logs with unique user IDs so you can tie each action to an individual.
- Regularly review logs for anomalies, either through manual review, automated alerts, or a Security Information and Event Management (SIEM) platform.
These logs are crucial not only for incident response but also for demonstrating compliance during assessments. Traceability is at the heart of Requirement 8: if you cannot show who did what, you are missing the spirit of the requirement, even if the technology looks good on paper.
PRO TIP
Integrate authentication logs from your identity provider, VPN, PAM, and critical applications into a single SIEM or logging platform. Focus on alerts for suspicious login patterns, such as logins from unusual locations, excessive failures, or impossible travel scenarios.
Requirement 8 summary: Turning guidance into a control checklist
To make Requirement 8 more operational, it helps to translate it into concrete control areas you can track.
| Control area | Practical focus | Example actions |
|---|---|---|
| Unique user identification | Ensure every person has an individual identity | Personal accounts, no shared passwords, PAM for legacy shared accounts |
| Strong authentication | Make credentials resilient against attacks | Password standards, account lockouts, secure storage |
| Multi-factor authentication | Prevent single-factor compromise from granting access | MFA for remote and admin access, centralized MFA platform |
| Privileged access management | Control and monitor administrative power | Named admin accounts, PAM, session logging |
| Service and application accounts | Avoid blind spots in non-human identities | Inventory, ownership, password rotation, avoidance of defaults |
| Lifecycle management | Keep access aligned with role changes and departures | Joiner–mover–leaver process, RBAC, timely deprovisioning |
| Logging and monitoring | Provide traceability and detect misuse | Central log collection, SIEM alerts, periodic review |
Use this table as a working checklist. For each control area, identify what you already do today, what is missing, and what needs better documentation for PCI DSS purposes.
From compliance burden to IAM opportunity: Where you go from here
PCI DSS Requirement 8 can feel like a checklist focused on passwords and MFA, but its real value is broader. It pushes you toward a disciplined identity and access management model, where each user and account is known, authenticated strongly, and monitored. That model does not just help you pass assessments; it directly reduces the risk of credential theft, insider misuse, and unauthorized changes to critical systems.
If you map Requirement 8 to your existing IAM tools, privileged access processes, and HR-driven lifecycle events, you can turn it into a structured improvement plan instead of a one-off compliance project. The natural next step is to build on this foundation with more advanced capabilities, such as risk-based authentication and automated access governance.
The question is not whether PCI DSS forces you to change; it is whether you use Requirement 8 as an opportunity to mature your identity and access management in a way that protects both your customers and your business for the long term.
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