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PCI DSS 8.1.1: Documenting Identity and Authentication Policies

Requirement 8.1.1 mandates that all security policies and procedures governing user identity and authentication are formally documented, regularly updated, actively enforced, and understood by every affected employee. This foundation control ensures your organization has clear, communicated guidelines that protect against unauthorized access across all systems.

What this means

This control requires you to create comprehensive written policies covering how users are identified, authenticated, and granted access to systems and data. These policies must be living documents—reviewed and updated as threats evolve and systems change. Every team member responsible for authentication, access control, or user management must know and follow these policies. Without documented and communicated policies, authentication practices become inconsistent and vulnerable to exploitation.

How to comply

  1. 1.Create written identity and authentication policies that define roles, responsibilities, and authentication requirements for all system types
  2. 2.Document specific authentication methods required (passwords, multi-factor authentication, certificates) for different user categories and access levels
  3. 3.Establish a review and update schedule—at minimum annually, and whenever systems, threats, or regulations change
  4. 4.Communicate policies to all affected staff through training, acknowledgment forms, and accessible policy repositories
  5. 5.Assign clear ownership for policy maintenance and ensure procedures are actively enforced through monitoring and audits
  6. 6.Document exceptions and compensating controls where standard authentication cannot be applied

Evidence auditors look for

  • Written identity and authentication policy document with version control and approval dates
  • Employee acknowledgment forms signed by staff confirming they have read and understand the policies
  • Policy distribution records showing communication to all affected departments and roles
  • Meeting minutes or documentation showing policy review cycles and updates over time
  • System configuration screenshots demonstrating enforced authentication requirements aligned with policy
  • Training attendance records and course materials covering identity and authentication procedures
  • Change management logs showing policy revisions tied to system upgrades or threat updates

Frequently asked questions

When will FAQs be available?

The FAQ for this control is currently being prepared.

GRCWatch automates policy version control, tracks employee acknowledgments, schedules mandatory reviews, and generates evidence dashboards—eliminating manual tracking and ensuring your identity and authentication policies stay documented, current, and provably communicated.

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Related controls

PCI DSS 8.1 (Establish strong access control procedures)PCI DSS 8.2 (User identity and access)PCI DSS 8.3 (Restrict access to cardholder data)PCI DSS 12.1 (Information security policy)