CYB-16 · Cyber security
Password policy — minimum complexity enforced; no password reuse; credential exposure monitoring
Password policy must enforce: minimum 12 characters, complexity requirements, and prohibition of reuse (last 12 passwords). Ideally aligned to NIST SP800-63b (length over complexity). Leaked credential monitoring must be in place to identify staff credentials that have appeared in data breach databases.
Trigger
When this rule fires
Password policy below 8 characters; no complexity requirements enforced; no password history restriction; no breach credential monitoring in place
Applicability gate
Confirm the entity's role before treating this as a duty
This is a readiness rule mapped to JS2 themes. Its presence in the library does not establish that JS2 applies directly to the firm.
- Insurance Broker: Most independent non-life Category I brokers are not directly in JS2's defined scope. A broker may be directly in scope if it separately meets a listed category, and may face contract or oversight requirements from an in-scope institution. Third-party provisions impose duties on the in-scope financial institution. They do not themselves make every supplier or intermediary directly subject to JS2.
- Uma Binder Holder: UMA or binder-holder status is not itself listed in JS2's definition. Direct scope depends on another listed capacity; insurer contracts and oversight may create evidence requirements. JS2 paragraph 3.3 concerns juristic persons structured under an insurer or designated insurance group; it is not a blanket rule for every independent UMA or intermediary.
- Insurer: An insurer as defined in the Insurance Act is directly in scope of JS2 from 1 June 2025. Apply proportionality and distinguish the insurer's own duty from requirements it places on third parties.
Citation
Mapped source
This control maps to the public instruments below. The mapping does not establish entity applicability.
- Section
- Joint Standard 2 of 2024 / NIST SP800-63b
- Legislation
-
- Joint Standard 2 of 2024
Remediation
How to close the gap
Update password policy to minimum 12 characters, complexity enforced, last 12 passwords prohibited. Implement Have I Been Pwned (HIBP) integration or equivalent for breach credential alerts. Consider passphrase guidance for staff.
Evidence required
Evidence to prepare if this control applies
- Active Directory / M365 password policy configuration
- Breach credential monitoring service subscription
- Password policy document