TL;DR: PCI DSS compliance centers on the same recurring control themes behind payment-card risk: firewall hardening, default credential removal, access restriction, encryption, monitoring, and access reviews, with practical emphasis on least privilege and continuous oversight, according to Zluri. The deeper issue is that PCI compliance still fails when identity governance treats system and application accounts as an afterthought, not a governed access surface.
Editorial analysis by NHI Mgmt Group, based on content published by Zluri: “Top 12 PCI DSS Compliance Checklist in 2026”.
Key questions
Q: What breaks when shared or interactive non-human identities are used in PCI DSS environments?
A: Shared or interactive NHI use breaks traceability and weakens accountability.
Q: Why do default credentials and standing privilege create PCI DSS risk?
A: Default credentials create risk because they are known, durable, and often left in place after deployment.
Q: How should teams prioritise PCI DSS controls when access governance is weak?
A: Start with the identities that can directly touch cardholder data.
Practitioner guidance
- Inventory every non-human account in PCI scope Map service accounts, application accounts, shared admin logins, SNMP strings, and other credentials that can reach cardholder-data systems.
- Remove default and vendor-supplied credentials Replace every default password, username, and administrative account on in-scope systems before those assets join the production environment.
- Certify NHI access on a fixed cadence Review non-human entitlements against current business function, not initial provisioning records.
Bottom line: PCI DSS control language is broad enough to cover payment-system access, but many programmes still under-govern the non-human identities that actually reach those systems.
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NHI access is the missing control plane in many PCI DSS programmes. The checklist emphasises perimeter hardening, encryption, monitoring, and reviews, but those controls do not work if application and system accounts are unmanaged. When machine identities are treated as implementation detail, the organisation has no durable way to prove who owns access, why it exists, or when it should end. The practical conclusion is that PCI governance must include non-human identities as first-class assets.
A question worth separating out:
Q: What is the difference between monitoring cardholder data access and governing who can use it?
A: Monitoring tells you that access happened, while governance determines whether the access should exist at all. PCI teams need both, but they solve different problems. If a non-human account can reach payment systems without a named owner or expiry, monitoring only records the failure after the fact.
👉 Read our full editorial: PCI DSS checklist in 2026 exposes the NHI access gap