CIS AWS Foundations v1.2 1.9: Ensure IAM password policy requires minimum password length of 14 or greater

Set an AWS account IAM password policy that enforces a minimum password length of at least 14 characters, then continuously verify it remains in place across all in-scope accounts. This CIS requirement targets human console passwords (not access keys) and is commonly checked via AWS Security Hub (control IAM.15) and audit evidence from IAM policy outputs.

Key takeaways:

• Enforce minimum password length ≥ 14 in each AWS account’s IAM password policy ¹.
• Scope it to IAM users who can sign in to the AWS console; it does not change access key behavior ².
• Operationalize with automation + recurring evidence (policy output, Security Hub findings, change history) to prove sustained compliance ¹.

Password length requirements look “basic,” but they fail audits for one reason: teams set them once and can’t prove they stayed set. CIS AWS Foundations v1.2 control 1.9 is straightforward: require a minimum length of 14 characters or greater for the AWS IAM account password policy. The operational challenge is consistently enforcing it across accounts (including dev/test), preventing drift, and producing clean evidence on demand for auditors, customers, and internal risk committees.

This page gives you requirement-level implementation guidance for the target keyword: cis aws foundations v1.2 1.9: ensure iam password policy requires minimum password length of 14 or greater requirement. You’ll get a practical runbook, evidence bundle, audit questions to pre-answer, and a phased execution plan you can hand to Cloud Security or Platform teams. Where relevant, this maps to AWS Security Hub’s CIS coverage so you can use findings for monitoring and proof ².

Requirement: minimum password length ≥ 14 (CIS AWS Foundations v1.2 1.9)

Plain-English interpretation

You must configure each in-scope AWS account so that any IAM user password used to sign in to the AWS Management Console must be at least 14 characters long. This is enforced through the IAM account password policy.

What it is not:

• It is not an access key control. IAM access keys and role credentials are governed by different mechanisms.
• It is not a “per-user” setting. AWS enforces it at the account level via the IAM password policy.

Primary references:

• CIS benchmark requirement statement and intent ¹.
• AWS Security Hub mapping for CIS AWS Foundations (IAM.15) used for continuous checks ².

Regulatory text

Excerpt (provided): “Implement CIS AWS Foundations Benchmark v1.2 requirement 1.9 as mapped in AWS Security Hub.” ³

Operator interpretation:

• Implement the CIS requirement by configuring the IAM password policy so MinimumPasswordLength = 14 (or greater) in each in-scope AWS account ¹.
• Use AWS Security Hub’s mapped control (IAM.15) as a monitoring signal where Security Hub is enabled, and treat failures as security findings that require remediation and closure evidence ².

Who it applies to

Entities

• Any organization operating workloads in AWS that claims alignment to, is audited against, or contractually commits to CIS AWS Foundations ¹.

Operational context (where this control matters)

• Accounts that permit human interactive console access for IAM users (for example, break-glass users, legacy IAM users, or partner access patterns).
• Multi-account environments where centralized identity exists but IAM users still exist in some accounts due to exceptions, acquisitions, or transitional states.

Practical scoping note: even if your primary identity is federated (SSO), auditors often still expect the IAM password policy to be set because it is cheap, low-risk, and reduces exposure if an IAM user is ever created.

What you actually need to do (step-by-step)

Step 1: Establish control ownership and decision points

Document who owns the configuration and who approves exceptions:

• Control owner: Cloud Security / Platform Security
• Implementer: AWS administrators (Org/Account owners)
• Approver for exceptions: CISO/CCO delegate (your governance structure)

Define two decision points:

• Are IAM users allowed for console access at all?
• If allowed, how are exceptions handled (break-glass, third-party support access, etc.)?

This is where a lightweight “control card” helps: objective, owner, cadence, triggers, and evidence bundle ¹.

Step 2: Inventory in-scope accounts and current state

Minimum inventory outputs:

• List of AWS accounts in scope for CIS checks (usually all production and shared services, plus any account that can affect them).
• For each account, retrieve the current IAM password policy settings.

Operational approach options:

• Security Hub: Check findings for the mapped CIS control (IAM.15) where enabled ².
• Direct configuration check: Query the account password policy via IAM APIs/CLI in every account.

Step 3: Implement the IAM password policy minimum length setting

In each account:

1. Open IAM settings (or use CLI/API) and set minimum password length to 14 or greater.
2. Confirm policy is applied (read-back the policy and verify the value).
3. If you manage accounts through infrastructure-as-code, encode the setting so it is reproducible and reviewable.

Execution guidance that keeps auditors happy:

• Prefer a standardized method (IaC, scripted org-wide rollout, or an account bootstrap pipeline).
• Avoid one-off console changes without a change record. One-off changes create evidence gaps.

Step 4: Prevent drift (continuous monitoring + change control)

You need two lines of defense:

• Detection: Security Hub findings for IAM.15, plus periodic configuration read-backs ².
• Response: A ticketed workflow that assigns, remediates, and validates closure with timestamps and an approver where required.

A common operating model:

• If a finding appears (or a config check fails), create a remediation ticket.
• Remediate by resetting the password policy to compliant configuration.
• Attach evidence and close the ticket only after validation.

This is where teams often formalize “recurring control health checks” with tracked remediation to closure ¹.

Step 5: Address edge cases explicitly (exceptions and compensating controls)

Document exception scenarios you will allow, such as:

• A regulated third party support user that requires an IAM user (rare, but happens).
• Break-glass IAM users with console access.

If exceptions exist, define:

• Who can approve the exception
• The expiry or review trigger (for example, role end date, contract renewal, or quarterly access review)
• Compensating controls (MFA, strict monitoring, limited permissions)

This requirement is still met if the password policy minimum length remains ≥ 14, even for exception users. Exceptions usually relate to other password complexity controls, not length.

Required evidence and artifacts to retain

Auditors and customer diligence reviewers ask two things: “Is it set?” and “How do you know it stays set?”

Retain an evidence bundle that answers both:

Configuration evidence ¹

• Screenshot or exported output of the IAM account password policy showing minimum length ≥ 14.
• CLI/API output (preferred for repeatability) showing the setting value.
• If you use IaC: the code/config snippet and the associated change approval (PR) that sets the value.

Monitoring and operations evidence

• AWS Security Hub screenshots/exports showing the control status for IAM.15 (where Security Hub is enabled) ².
• Remediation tickets for any exceptions/drift events, including:
  • Detection timestamp
  • Owner assignment
  • Fix implemented
  • Validation evidence
  • Closure approval

Governance artifacts

• A short “control card” or runbook: owner, scope, how it’s checked, and where evidence is stored ¹.
• Evidence retention location and naming convention (so you can produce it quickly).

Common exam/audit questions and hangups

Expect these, and pre-answer them in your runbook and evidence:

1. “Show me the password policy in each AWS account.”
   Hangup: teams show only one account (often the management account) and forget member accounts.

2. “How do you know it didn’t change last month?”
   Hangup: teams have a screenshot from last year. Fix this with recurring checks and dated exports.

3. “Does this apply if you use SSO?”
   Hangup: auditors still want to see the IAM password policy set because IAM users can exist. Keep it set unless you have a formal policy forbidding IAM users and strong preventative controls.

4. “Where is this mapped in your tooling?”
   Hangup: teams can’t connect CIS 1.9 to Security Hub IAM.15. Keep a one-line mapping in the control card ².

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	How to avoid
Setting the policy in only one account	CIS checks are account-scoped; member accounts drift	Roll out org-wide and track account coverage
No recurring validation	You can’t prove sustained operation	Use Security Hub + periodic config exports 2
Relying on screenshots without context	Screenshots lack account ID, date, and repeatability	Prefer CLI/API outputs; store with timestamps and account identifiers
Treating this as “done” after implementation	Audits test operation over time	Tie failures to ticketing and closure evidence 1
Confusing password policy with access key rules	You waste time changing the wrong control	Document scope: console passwords for IAM users only

Enforcement context and risk implications

No public enforcement cases were provided for this specific CIS requirement in the supplied sources. Practically, failures show up in:

• Customer security reviews and procurement questionnaires
• Internal audits (especially where CIS alignment is a contractual commitment)
• External audits where CIS is used as a benchmark for cloud configuration hygiene ¹

Risk-wise, weak password length requirements increase the chance that an IAM user console password can be guessed or cracked if exposed. Even if your primary identity is federated, leaving IAM password policy unset creates unnecessary exposure for break-glass or legacy users.

Practical 30/60/90-day execution plan

Use a plan that produces evidence early and then hardens operations. (Time horizons are planning labels, not elapsed-day promises.)

First 30 days (Immediate stabilization)

• Assign an owner and publish a one-page control card: objective, scope, and check method ¹.
• Inventory accounts and capture baseline password policy state per account.
• Remediate all accounts missing the minimum length setting, and store proof per account.

By 60 days (Operationalize and reduce drift)

• Turn the check into a recurring control health process with tracked remediation items to closure ¹.
• Where Security Hub is deployed, validate IAM.15 reporting and define who triages findings ².
• Standardize evidence storage (folder structure, naming conventions, ticket templates).

By 90 days (Sustain and audit-proof)

• Integrate the setting into account provisioning/bootstrapping so new accounts start compliant.
• Add exception governance: documented exception criteria, approvers, and review triggers.
• Run an internal “audit dry-run”: pull evidence for a sample of accounts and verify it is complete, dated, and attributable.

Tooling note (where Daydream fits naturally)

If your problem is not setting the policy but proving ongoing operation, Daydream can help you package this as a requirement control card, define the minimum evidence bundle, and run recurring control health checks with remediation tracking to validated closure ¹. That closes the gap auditors focus on: ownership, cadence, and traceable evidence.

Frequently Asked Questions

Does CIS 1.9 apply if we exclusively use AWS IAM Identity Center (SSO) and have no IAM users?

Set the IAM password policy anyway unless you have strong preventative controls that block IAM user creation. Auditors often treat the password policy as a baseline configuration because IAM users can be created in an account.

Is this requirement about password complexity (symbols, numbers) or only length?

This requirement is specifically about minimum length: 14 or greater ¹. Other CIS controls address complexity and rotation separately.

Does changing the IAM password policy force users to change their passwords immediately?

It affects password validity rules going forward. Plan communications for any population of IAM users, especially break-glass or third-party access accounts, so you don’t cause an unplanned access outage.

How do we prove compliance to an auditor quickly?

Provide the current IAM account password policy output per in-scope account and show monitoring results from Security Hub IAM.15 where enabled ². Add dated evidence plus remediation tickets for any historical drift.

What about third-party support access that “needs” an IAM user?

Keep the minimum length requirement in place regardless. If the third party insists on weaker passwords, treat that as a security exception and renegotiate; don’t weaken the global policy for one user.

Can we meet the requirement with SCPs (Service Control Policies) alone?

SCPs can prevent certain actions, but they don’t replace the need to configure the IAM password policy itself. Use SCPs as a drift-prevention layer, then keep direct evidence that the password policy is set correctly.

Footnotes

1. CIS AWS Foundations Benchmark

2. AWS Security Hub CIS AWS Foundations mapping table

3. CIS AWS Foundations Benchmark; AWS Security Hub CIS AWS Foundations mapping table