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PCI DSS 4.0.1: Compliance for Non-Human Identities

Alon Berger March 3, 2025

The proliferation of NHIs, such as service accounts, APIs, and OAuth Apps, has significantly reshaped the attack surface, with machine identities now outnumbering human users 45:1. This rapid expansion has left enterprises exposed, as seen in recent high-profile breaches at the U.S. Treasury, Snowflake, and Okta, where compromised machine identities played a pivotal role. In fact, according to a recent CSA report about the State of NHI Security, 1 in 5 organizations experienced a security incident related to NHIs.

Recognizing this widening security gap, the PCI DSS framework has quickly evolved, with version 4.0.1 introducing new and specific requirements addressing NHI management, access controls, and lifecycle governance. The message is clear – securing NHIs is no longer optional; it’s a critical, compliance-driven necessity.

PCI DSS Overview and NHI Relevance

Nowadays, the established Payment Card Industry Data Security Standard (PCI DSS) is tightly linked with non-human identity management. The previous 4.0 version of the framework explicitly addressed the unique security challenges posed by NHIs.

The framework now mandates robust access control measures, secure credential management, continuous monitoring, and effective lifecycle management for NHIs.
It emphasizes the application of the least privilege principle and the implementation of unique credentials for each non-human identity.

What’s New in PCI DSS 4.0.1

PCI DSS v4.0.1 marks a strategic evolution in payment security standards, refining the foundation established in version 4.0 with targeted enhancements that address the complexities of today’s threat landscape.

Key advancements include:

Mandatory multifactor authentication for all administrative access.
Enhanced phishing and malware protections.
A fundamental shift toward continuous compliance monitoring rather than point-in-time assessments.
Improved compatibility with global regulations like GDPR and CCPA.
Simplified reporting templates to reduce administrative overhead.
More precise scoping guidance to help organizations effectively define their cardholder data environments.

Together, these refinements transform PCI DSS from a periodic compliance exercise into a dynamic security framework that supports proactive risk management in an increasingly complex digital ecosystem.

Manage PCI DSS 4.0.1 Requirements with Astrix

Navigating PCI DSS compliance involves understanding complex requirements for Non-Human Identities (NHIs) that access cardholder data environments.

The mapping below details specific PCI DSS 4.0.1 requirements affecting NHI and explains how Astrix Security’s platform helps organizations achieve and maintain compliance through comprehensive NHI discovery, lifecycle management, and continuous monitoring.

You can use the referenced PCI DSS sections to locate the exact requirement language in the official documentation.

8.6 Use of application and system accounts and associated authentication factors (mandatory after March 31, 2025)
- 8.6.1 Interactive login management
  - Requirements: Limit interactive use to exceptional circumstances, require management approval, ensure accountability to individuals
  - Astrix solution:
    - Discovers NHIs that can be used for interactive login
    - Enables assignment of owners for accountability
    - Monitors NHI usage to detect unauthorized interactive access
- 8.6.2 Prevention of hardcoded credentials
  - Requirements: Passwords for interactive accounts must not be hardcoded in scripts, configuration files, or source code
  - Astrix solution:
    - Scans for exposed secrets across environments
    - Provides remediation capabilities for exposed secrets
- 8.6.3 Password protection and management
  - Requirements: Periodic password changes based on risk analysis, sufficient complexity
  - Astrix solution:
    - Comprehensive inventory of application/system accounts
    - Enables tracking of password/secret policies and rotation
7.2 Appropriate access definition and assignment
- 7.2.5 Least privilege principle
  - Requirements: System accounts must use the least privileges necessary, limited to required systems
  - Astrix solution:
    - Provides complete NHI inventory and access mapping
    - Monitors usage patterns to identify excessive privileges
- 7.2.5.1 Periodic access reviews
  - Requirements: Regular reviews of application/system account access at risk-appropriate intervals
  - Astrix solution:
    - Establishes ownership for all NHIs
    - Automates access reviews and approvals
    - Provides comprehensive access visibility
8.2 User identification lifecycle management
- 8.2.1 Unique ID assignment
  - Requirements: All users must have unique IDs for system access
  - Astrix solution:
    - Maps NHI access through Access Graph visualization
    - Enables monitoring of NHI usage to ensure proper attribution
    - Assigns business owners to maintain accountability
- 8.2.6 Inactive account removal
  - Requirements: Inactive accounts must be removed/disabled within 90 days
  - Astrix solution:
    - Links NHIs to responsible owners to prevent orphaned accounts
    - Monitors NHI activity to identify inactive accounts