Identity and access management maturity

The identity and access management maturity requirement means you must strengthen identity governance and access controls as your organization’s cybersecurity capability matures, with clear checkpoints for access decisions and tighter privileged access controls. Operationalize it by defining maturity-based IAM outcomes, implementing governance gates (joiner/mover/leaver and access reviews), and proving consistent operation with audit-ready evidence.

Key takeaways:

• Treat “maturity” as staged control outcomes: basics first, then stronger governance, then tighter privileged access discipline.
• Build governance checkpoints into workflows (HR events, ticketing, change management, third-party onboarding), not side processes.
• Evidence wins exams: keep decision records, review results, privileged access logs, and exception approvals tied to systems and owners.

“IAM maturity” is easy to agree with and surprisingly hard to prove. Auditors and assessors do not accept “we have SSO” as maturity; they look for governance, repeatability, and improvement over time. The C2M2 requirement here is intentionally simple: strengthen identity governance and access controls as capability maturity improves ¹. Your job is to translate that into a staged, testable program that can survive staff turnover, tool changes, and expanding system scope.

For most Compliance Officers, CCOs, and GRC leads, the fastest path is to define what “stronger” means for your environment, then attach those expectations to operational triggers. Examples: access cannot be granted without an owner and justification; privileged access cannot be persistent without a documented exception; access reviews must produce tracked remediation; third-party access must follow the same joiner/mover/leaver discipline as employees.

This page gives you requirement-level implementation guidance: who it applies to, what to do step-by-step, what evidence to retain, common audit hangups, mistakes to avoid, and a practical execution plan you can run without rewriting your entire security program.

Requirement: identity and access management maturity requirement (C2M2)

Regulatory anchor: C2M2 expects your identity governance and access controls to get stronger as your cybersecurity capability matures ¹. Practically, you need a documented, operating IAM governance system that can demonstrate progress: tighter approval, better verification, stronger privileged access controls, and fewer unmanaged exceptions.

Regulatory text

Excerpt (C2M2-06): “Strengthen identity governance and access controls as capability maturity improves.” ¹

What the operator must do:

• Define what “maturity” means in your IAM program (stages, target outcomes, and scope).
• Implement governance checkpoints that prevent unmanaged access (approvals, ownership, reviews, and deprovisioning).
• Increase rigor for higher-risk access (privileged accounts, sensitive systems, remote access, third-party access).
• Show continuous improvement with evidence: reviews completed, issues remediated, exceptions controlled.

Plain-English interpretation

You are expected to run IAM as a governed control system, not an ad hoc IT function. As you mature, the program must become more consistent, more risk-based, and more measurable. “Mature” IAM shows up in how access is requested, approved, provisioned, reviewed, revoked, and monitored, with special handling for privileged access.

A useful way to interpret the requirement: every increase in business reliance on systems, connectivity, and automation should be matched by a corresponding increase in IAM rigor ¹. That “rigor” must be visible in artifacts and logs, not just policy language.

Who it applies to (entity and operational context)

Entities: Critical infrastructure operators and energy sector organizations using the C2M2 model to assess and improve cybersecurity capability ¹.

Operational contexts where this gets examined hard:

• OT/ICS environments where identity is fragmented (local accounts, shared credentials, jump hosts).
• Hybrid enterprises with multiple identity providers, legacy directories, and acquired systems.
• High contractor / third-party usage (field services, managed service providers, OEM support).
• Environments with sensitive operational data, billing systems, outage management, or safety-relevant systems.

Functions involved: Security/IAM, IT operations, HR, OT engineering, application owners, service desk, procurement/third-party management, and GRC.

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

Step 1: Define IAM maturity outcomes and scope

1. Set scope boundaries: which populations (employees, contractors, third parties), which environments (IT, OT, cloud), which critical apps/systems.
2. Define maturity stages you can defend in an assessment. Keep it outcome-based, such as:
   • Stage A: Access is inventoried, owned, and revocable.
   • Stage B: Access is governed through approvals and periodic review.
   • Stage C: Privileged access is controlled with strong verification, logging, and time-bounded elevation.
3. Assign control ownership: one accountable IAM owner, plus application/system owners who approve access.

Deliverable: an “IAM Maturity Standard” (1–3 pages) that states what gets stronger as maturity increases.

Step 2: Implement governance checkpoints (“gates”)

Treat these as non-negotiable workflow steps with named approvers and required fields.

Gate 1 — Access request

• Require: requester identity, business justification, target system/role, duration (if temporary), and data/system classification.
• Route approvals to the system owner and (for elevated access) security.

Gate 2 — Provisioning

• Provision through managed groups/roles where possible.
• Block direct assignment outside the process or require an exception with compensating controls.

Gate 3 — Joiner/Mover/Leaver (JML)

• Joiner: access aligns to role baseline; elevated access requires additional approval.
• Mover: access is re-validated and removed where no longer needed.
• Leaver: disable accounts promptly, revoke tokens/keys, and remove group memberships; address orphaned accounts.

Gate 4 — Periodic access review

• Review access to critical systems and privileged roles on a defined cadence that matches risk. (Cadence is your policy decision; you don’t need a citation for your chosen frequency.)
• Require evidence of review completion and remediation tickets for removals.

Step 3: Tighten privileged access controls as maturity improves

Privileged access is where examiners spend time because it is a common path to high-impact incidents.

Minimum operator expectations you can implement quickly:

• Privileged account inventory (human and non-human).
• Separate admin identities from daily-use identities where feasible.
• Strong authentication for privileged access paths (admin portals, bastions, remote tooling).
• Time-bounded elevation (or documented exceptions if you can’t).
• Session/log capture for key systems, plus retention aligned to your security logging standard.
• Break-glass access with named approvers, strict conditions, and post-event review.

Step 4: Extend the same discipline to third-party access

Third parties often bypass internal norms unless you force consistency.

Operationalize:

• Ensure third-party identities are tied to a sponsor (business owner) and contract/work order context.
• Require the same JML lifecycle and access reviews.
• Restrict to least privilege, restrict connectivity paths, and log activity.

Step 5: Measure, remediate, and show improvement

Maturity implies improvement over time ¹. Build a small set of metrics that drive action without creating reporting theater:

• Count of systems in-scope with named access owners.
• Access reviews completed vs. overdue, and removals executed.
• Number of privileged accounts not covered by your privileged access controls (gap register).
• Exception volume and age, with approvals and compensating controls.

If you run Daydream for third-party risk management and control evidence, map IAM gates to your critical third-party access patterns (support portals, VPN, bastion access, SaaS admin roles). Daydream becomes the system of record for who has access, why they have it, what review confirmed it, and where exceptions are approved.

Required evidence and artifacts to retain

Auditors test IAM maturity by sampling access events and asking you to prove governance operated as designed.

Keep these artifacts, organized by system and time period:

• IAM policy/standard describing maturity expectations and privileged access rules.
• System inventory with access owners (app owner, data owner, technical owner).
• Access request and approval records (ticketing exports, IAM tool workflows).
• Provisioning logs (group/role change history, admin action logs).
• JML records (HR feed evidence, termination disablement records, mover validations).
• Periodic access review packages: reviewer assignment, user/role listing, reviewer sign-off, findings, remediation tickets, closure evidence.
• Privileged access artifacts: privileged account inventory, PAM configuration screenshots/exports, session logs where applicable, break-glass logs, and exception register.
• Exception management: approvals, compensating controls, expiry dates, and re-approval evidence.

Common exam/audit questions and hangups

Expect these questions and prepare your evidence package ahead of time:

1. “Show me how access is approved for System X.”
   Hangup: approvals occur in email/Slack with no retention or linkage to provisioning.

2. “Who owns access for each critical system?”
   Hangup: “IT owns it” with no named business owner.

3. “Prove leavers lose access.”
   Hangup: identity disabled in one directory, but app accounts, API keys, and local OT accounts remain.

4. “How do you control privileged access?”
   Hangup: shared admin accounts, persistent admin rights, or weak logging.

5. “How do you govern third-party access?”
   Hangup: contractors are exempt from reviews, or access is granted via generic accounts.

Frequent implementation mistakes (and how to avoid them)

• Mistake: equating SSO with governance. SSO is plumbing; maturity is governance gates, ownership, reviews, and remediation.
  Fix: require approvals and reviews even if access is federated.

• Mistake: access reviews that don’t remove access. Reviews become checkbox exercises without remediation tracking.
  Fix: every removal decision needs a ticket and closure evidence.

• Mistake: privileged access exceptions that never expire.
  Fix: enforce expirations, re-approval, and compensating controls; track in an exception register.

• Mistake: ignoring non-human identities. Service accounts, API keys, and automation tokens often have broad access.
  Fix: inventory and assign ownership, set rotation and monitoring expectations, and include them in reviews where relevant.

• Mistake: third parties outside IAM controls.
  Fix: sponsor-based access, time-bounded access, and review third-party access alongside employees.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. Practically, weak IAM maturity increases the likelihood and blast radius of unauthorized access, privilege abuse, and gaps in offboarding, especially in critical infrastructure environments where availability and safety matter ¹. From a governance perspective, the most common “failure mode” in assessments is not the absence of tools; it is missing, inconsistent evidence that controls operated across in-scope systems.

Practical 30/60/90-day execution plan

Day 0–30: Stabilize and define “maturity”

• Publish IAM maturity standard: scope, stages, and privileged access rules.
• Build or refresh system inventory with named access owners for critical systems.
• Stand up an exception register for access and privileged access.
• Choose the initial “top systems” list (critical apps, remote access paths, admin consoles).

Day 31–60: Put governance gates into production

• Implement required fields and approvals in your access request workflow.
• Start JML controls: ensure leaver disablement reaches critical apps and remote access.
• Run your first access review for one critical system and one privileged group; track removals to closure.
• Implement privileged account inventory and break-glass procedure with logging and post-use review.

Day 61–90: Expand coverage and prove improvement

• Extend access reviews to additional critical systems and third-party access groups.
• Add privileged access tightening: time-bounded elevation where feasible, stronger authentication for admin access paths, and better logging.
• Produce an “IAM maturity evidence pack” for auditors: policy, owner inventory, review packages, exception register, and privileged access artifacts.
• If you use Daydream, align third-party access reviews and exception evidence to your third-party inventory so you can show consistent governance across external access paths.

Frequently Asked Questions

How do I define “maturity” without a formal scoring model?

Define a small set of staged outcomes you can test: ownership coverage, approval discipline, review completion with remediation, and privileged access controls. Document the stages and map each critical system to a current stage with a target stage.

Do access reviews have to be performed in an IAM tool?

No. Auditors care that reviews are complete, performed by the right owner, and produce removals or justified retention with evidence. A tool helps with consistency and retention, but tickets plus exports can work if controlled.

What counts as “privileged access” for this requirement?

Any identity or credential that can change security settings, create accounts, access sensitive datasets broadly, or administer critical services. Include local admin, domain/cloud admins, SaaS admins, and high-impact OT management consoles.

We have shared accounts in OT/ICS. How do we show maturity progress?

Start by inventorying shared accounts, documenting where they exist, and implementing compensating controls (restricted access paths, logging, and strict approval). Track a roadmap to named accounts where feasible and keep exception approvals current.

How should we handle third-party remote support access?

Require a sponsor, time-bound access, least privilege roles, and logging of sessions where possible. Include third-party accounts in the same access review cycle as employee accounts, and revoke access when the work ends.

What is the minimum “evidence pack” to satisfy an assessor quickly?

Provide your IAM maturity standard, critical system list with access owners, samples of access requests/approvals, one completed access review with remediation proof, privileged account inventory with controls, and the exception register with approvals ¹.

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control lifecycle management

Footnotes

1. DOE C2M2