PCI vs. FedRAMP: Multi-Factor Authentication Requirements

Given today’s continually evolving threat landscape, strengthening access controls is an essential element and growing priority of any robust security program. As such, it’s no surprise multi-factor authentication (MFA) has become a widely adopted compliance requirement by a significant number of security standards across industries. That said, it can be difficult to understand the intricacies of the MFA regulations for each compliance framework.  

To help tackle this confusion, we’ll compare the multi-factor authentication requirements for two important compliance frameworks: PCI DSS and FedRAMP. By understanding both the similarities and differences in their MFA requirements, you can build a more comprehensive compliance roadmap that meets the needs of your organization. 

Multi-Factor Authentication Explained 

Multi-factor authentication is a security mechanism that requires users to present two or more verification factors to gain access to a resource such as an application, network, or database. Unlike traditional single-factor authentication, which typically relies on just a password, MFA adds additional layers of security by requiring factors such as something you know (a password), something you have (a token or mobile device), or something you are (biometrics). This multi-layered approach makes it exponentially harder for attackers to compromise an account by targeting one single authentication vector. 

With cyber threats continually growing and advancing, MFA has become a mainstay risk reduction and security measure. Given the range of threats it protects against, the use of MFA is widely recognized as an indispensable best practice. So much so that organizations in the payment card industry (PCI) and those subject to FedRAMP guidelines must implement MFA as a primary control.  

While MFA is now considered a regulatory standard for both PCI and FedRAMP compliance, understanding the full scope of these requirements can be challenging. To provide clarity, we’ll delve into the specific mandates of each framework and further explain why organizations must treat MFA not just as an optional add-on, but as a core element of their security infrastructure. 

MFA Requirements for PCI Compliance 

The Payment Card Industry Security Standards Council (PCI SSC) establishes the standards that organizations must adhere to in order to safeguard cardholder data. As such, PCI compliance guidelines outlined in PCI DSS mandate the implementation of MFA for any access to the cardholder data environment. This requirement ensures that multiple forms of verification are presented before users are able to access sensitive systems or data. For example, when employees or third-party service providers attempt remote access to systems, they are authenticated using both something they know and something they have, such as a predetermined password and an ad-hoc code sent to their mobile device. This extra security measure greatly reduces the risk of unauthorized access. 

Beyond remote access, PCI compliance also emphasizes the need for MFA in any scenario where privileged access is involved. By enforcing multi-factor authentication, organizations can ensure that even if one credential is compromised, the additional factors will effectively prevent a damaging security breach. Embracing MFA as a fundamental component of PCI compliance not only meets PCI DSS requirements but also helps strengthen your overall cybersecurity posture. 

MFA Requirements for FedRAMP Compliance 

FedRAMP, which stands for the Federal Risk and Authorization Management Program, sets stringent security standards for cloud service providers working with the United States federal government. FedRAMP compliance mandates the use of MFA to protect access to sensitive government data. The guidelines under FedRAMP require that cloud service providers implement MFA for both user and administrative access, ensuring that multiple layers of identity verification are in place. This is crucial given the sensitive nature of federal data and the potential risks associated with unauthorized access. 

In addition to user access controls, FedRAMP outlines specific technical requirements for MFA implementation. Cloud service providers must demonstrate that their authentication processes integrate seamlessly with their existing security frameworks and are continuously monitored for vulnerabilities. The use of MFA within the FedRAMP framework is not just a regulatory checkbox; it is an essential control that helps mitigate the risk of insider threats and external attacks. For organizations aiming to achieve or maintain FedRAMP compliance, understanding and implementing robust MFA measures is vital for both security and regulatory approval. 

PCI vs. FedRAMP: MFA Similarities 

While PCI and FedRAMP each address distinct frameworks—the payment card industry and federal cloud services, respectively—both recognize the critical importance of multi-factor authentication. At their core, both sets of guidelines require that organizations implement MFA to reduce the risk of unauthorized access. This shared requirement underscores a common understanding: single-factor authentication methods are no longer sufficient to counter modern cyber threats. 

Both PCI and FedRAMP also emphasize the use of multiple verification methods. Whether it’s a combination of passwords, tokens, or biometric factors, each framework promotes a layered approach to authentication. This similarity is particularly evident in remote and privileged access scenarios, where the loss or compromise of a single credential could lead to severe breaches. By aligning MFA practices across both standards, organizations can benefit from a harmonized security posture that not only meets regulatory requirements but also enhances overall defense against cyberattacks. 

PCI vs. FedRAMP: MFA Differences 

Despite their shared focus on MFA, PCI and FedRAMP differ in several key respects that reflect their distinct approaches. PCI compliance tends to have more prescriptive requirements regarding which authentication methods must be used to protect the Cardholder Data Environment. This often means that organizations must implement specific controls that address remote access, network segmentation, and end-user device security in a very defined manner. 

In contrast, FedRAMP’s MFA requirements are tailored to the unique challenges of cloud service environments, addressing the need to secure large-scale, distributed systems. Therefore, FedRAMP’s MFA guidelines are designed with scalability and continuous monitoring in mind.  

FedRAMP explicitly incorporates other federal standards such as NIST and FIPS. This leads to some important divergences between FedRAMP and PCI regarding where MFA applies. For example, under FedRAMP, MFA is mandatory for all user accounts, not just privileged accounts; whereas within PCI, MFA is required for all access to the Cardholder Data Environment, but not necessarily for access to other ancillary systems, or by customer end users. Additionally, FedRAMP mandates that MFA solutions be validated against FIPS 140-2 standards and that they adhere to NIST SP 800-63B. 

Helpful Tips for MFA Implementation 

As you work towards a robust compliance roadmap, the integration of MFA should be one of your top priorities. Here are some helpful tips to get started with implementing MFA: 

1. Assess your current authentication controls

Begin by performing a comprehensive assessment of your existing authentication and authorization controls. Identify any gaps in your current authentication processes relative to the requirements of PCI compliance and FedRAMP compliance, severally. This initial assessment will help you understand where your systems are vulnerable and what steps you need to take to better align with the standards. In particular, ensure that your implementation of MFA is not a one-size-fits-all solution, but rather is tailored to the unique requirements of each regulatory framework your organization falls under. 

2. Adopt a phased approach for MFA implementation

Next, develop a phased approach for implementing enhanced MFA controls. This roadmap should include clear timelines, budget considerations, and responsibilities for different teams within your organization. Work closely with IT, security, and compliance stakeholders to design policies that address both remote access and privileged access requirements. Leverage automated monitoring tools to continuously track MFA effectiveness and integrate regular audits to ensure ongoing compliance. By adopting a structured, proactive approach, you can reduce risk and strengthen your overall security posture while meeting the evolving demands of both the payment card industry (PCI) and federal security standards (FedRAMP). 

3. Stay abreast of compliance framework updates

Finally, it's best practice to remain well-informed about updates in both compliance landscapes. Regulatory bodies periodically update their guidelines in response to emerging threats and new technologies, so it’s crucial to keep your compliance roadmap agile. Engage with industry experts and participate in relevant forums or training sessions to remain current on best practices. By doing so, you’ll not only maintain compliance with standards such as PCI DSS and FedRAMP but also build a resilient security framework that can adapt to the ever-changing cyber threat landscape. This forward-thinking approach will ultimately empower your organization to protect critical data, build customer trust, and stay ahead in a competitive market. 

Next Steps in Building Your Compliance Roadmap 

The comparison between PCI and FedRAMP multi-factor authentication requirements reveals both common principles and distinct challenges. Organizations must carefully consider these nuances as they build or refine their compliance roadmaps. Whether you are focused on safeguarding cardholder data under PCI guidelines or ensuring the security of cloud environments under FedRAMP, robust MFA implementation is a critical step toward enhancing your overall security posture. 

By taking a strategic, informed approach to integrating MFA into your compliance framework, you not only meet regulatory mandates but also build a solid foundation for long-term cyber resilience. Use this guide as a starting point to drive meaningful improvements in your security practices and to ensure that your compliance roadmap remains a living document—one that evolves in step with the latest industry trends and emerging threats. 

If you’re ready to undergo a PCI DSS Validation or FedRAMP Assessment, or you have additional questions about MFA or any other compliance framework requirements, reach out to a Schellman specialist today and we’ll get back to you shortly.  

In the meantime, discover other helpful PCI and FedRAMP compliance insights in these additional resources: 

• Are Passwords Still Secure? A Look at Other Alternatives
  
• How to Go Password-Less Under PCI DSS v4.0 
• PCI DSS for Security Leaders – How to Take a Proactive Approach 
• FedRAMP Moderate Equivalency for Cloud Service Providers Explained 
• Securing the Cloud: Mastering FedRAMP Authorization Boundaries