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The only PCI DSS requirement I couldn’t quickly align to NIST and others has been the 90 day expiration. My go-to has been to convince the insurance underwriters first of the primacy of SANS, NIST, Microsoft and so on. Then put them in a locked cage match with the PCI DSS auditors and accept the result when they walk out. PCI DSS auditors can’t accept liability shifting onto them, and cybersecurity insurance underwriters are getting more savvy on current standards and can often twist auditor arms enough to carve out exceptions and still obtain the audit certification.

It’s still messy at this time, but if it is important enough to you, then sometimes it can be obtained. Most of my clients aren’t that doctrinaire over the expiration part though and are still comfortable making everyone change every 90 days, and with some enterprises they don’t care because they have FIDO2/U2F or similar authN infrastructures and corresponding authZ improvements on their roadmaps within the next 3-5 years anyways that do away with most passwords in their environments.




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