Multi-factor authentication

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Glossary / M / Multi-factor authentication
Glossary · GRC and resilience

Multi-factor authentication

MFAAlso called two-factor authentication (2FA), multifactor authentication

Definition

Multi-factor authentication is a login control that requires two or more independent factors before granting access: something the user knows, such as a password; something they have, such as a phone or token; or something they are, such as a fingerprint. Stealing one factor alone is not enough to get in.

PASSWORDDEVICE OR TOKENBIOMETRIC
Fig. 1 · Multi-factor authentication
NYDFS Part 500, section 500.12 · FTC Safeguards Rule, 314.4(c)(5) · FFIEC authentication guidance
Key rulesNYDFS Part 500, section 500.12 · FTC Safeguards Rule, 314.4(c)(5) · FFIEC authentication guidance · DORA RTS on ICT risk management, Article 21
Applies toBanks, insurers and other entities licensed by NYDFS
RegionsGlobal · EU · US
01

How it works

When a user signs in, the system checks a first factor, usually a password, then asks for a second from a different category. Common second factors are a code from an authenticator app, a push approval on a registered phone, a hardware security key or a biometric check. Phishing-resistant methods, such as hardware keys and passkeys, bind the login to the genuine site so stolen codes cannot be replayed.

Regulators now expect MFA for staff and systems as a baseline control. Financial firms apply it to remote access, privileged accounts, email and cloud services, and any system holding customer data. Weak spots include SMS codes, which can be intercepted through SIM swaps, and push fatigue attacks, where users approve repeated prompts. Firms monitor failed attempts and resets, which attackers target through help desks.

Step 1Inventory accessList systems, users and privileged accounts.
Step 2Choose factorsPrefer phishing-resistant methods for high-risk access.
Step 3Enforce MFAApply it to remote, privileged and data-bearing systems.
Step 4Secure resetsVerify identity strongly before resetting factors.
Step 5MonitorWatch failed attempts, repeated prompts and exceptions.
02

The rules

US · Universal MFA from 1 November 2025NYDFS Part 500, section 500.1223 NYCRR Part 500 (Cybersecurity Requirements for Financial Services Companies), section 500.12, as amended 1 November 2023

Requires MFA for any individual accessing any information system, unless the CISO approves equivalent or more secure controls in writing.

Banks, insurers and other entities licensed by NYDFS
US · 9 June 2023FTC Safeguards Rule, 314.4(c)(5)FTC Standards for Safeguarding Customer Information, 16 CFR 314.4(c)(5)

Requires MFA for any individual accessing any information system, unless the qualified individual approves equivalent or more secure controls in writing.

Non-bank financial institutions under FTC jurisdiction
US · 11 August 2021FFIEC authentication guidanceFFIEC Authentication and Access to Financial Institution Services and Systems

Sets supervisory expectations for risk-based authentication, naming MFA as an effective control for customers, employees and third parties.

US banks and credit unions
EU · Applies from 17 January 2025DORA RTS on ICT risk management, Article 21Commission Delegated Regulation (EU) 2024/1774, Article 21, supplementing Regulation (EU) 2022/2554 (DORA)

Requires strong authentication for remote network access, privileged access, and ICT assets supporting critical or important functions or publicly accessible.

EU financial entities under DORA
03

Common questions

Is MFA the same as two-factor authentication?

Two-factor authentication is MFA with exactly two factors. MFA covers two or more. Both only count when the factors come from different categories, so a password plus a security question is not MFA.

What is the difference between MFA and strong customer authentication?

Strong customer authentication is the EU and UK payments rule requiring two-factor checks for customer payments and account access. MFA is the wider security control, applied to staff, systems and customers.

Are SMS codes good enough for MFA?

They count as a factor under most rules, but regulators and security bodies class them as weaker. Attackers can intercept them through SIM swaps or phishing, so firms prefer app-based, hardware key or passkey methods for sensitive access.