Comment by bux93
2 days ago
Yikes, whoever wrote that should be ashamed of themselves. On the bright side, it doesn't specify how long the predefined interval should be, and says entities are to 'ensure the strength of authentication is appropriate to the classification of the asset to be accessed' - so, in order to ensure the appropriate strenght the interval should be 100 years is totally defensible IMHO. The whole paragraph doesn't take MFA in account anyway, and FIDO2 does provide for key rotation (even if it's not widely implemented, maybe something to consider if you're covered by NIS2 - or manually rotate keys once every year).
11.3. (a) mandates multi-factor auth for priviledged and sysadmin accounts, and 11.7. requires multi-factor auth depending on criticality determinations. All in addition to whatever is in 11.6.
But the thought about the non-specified intervals in 11.6. is great, nowhere in there are any numbers to be found. So basically one can do the sensible thing, set some huge numbers that are no problem in practice and everything is fine.
I mentioned MFA because 11.6 says to change "authentication credentials", but with MFA that could mean both factors or either. So key rotation without changing the "what you know" factor would arguably also satisfy the requirement; the term 'credentials' is not defined, and especially not defined in relation to MFA.