CIS AWS Foundations v1.2 1.1: Avoid the use of the root user

CIS AWS Foundations Benchmark v1.2 control 1.1 focuses on one recurring failure mode in cloud incidents and audit findings: teams operating with the AWS account root user. Root is not a normal identity. It bypasses many of the guardrails you rely on for accountability, access control, and incident response, because it is difficult to scope, difficult to delegate, and (if mishandled) can become a single point of catastrophic compromise.

For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing this requirement is to frame it as an access governance control with three parts: (1) prevention (do not use root for administration; remove root access keys; enforce MFA), (2) detection (alert on any root usage through CloudTrail/Security Hub), and (3) evidence (retain artifacts that prove the control is operating over time, not just configured once). AWS Security Hub maps this requirement to a specific CIS control check, so you can track it as a measurable control and produce consistent audit outputs (AWS Security Hub CIS AWS Foundations mapping table).

This page gives you requirement-level implementation guidance: who owns it, what to configure, what auditors ask for, what breaks in real environments, and what evidence to keep.

Regulatory text

Excerpt (provided): “Implement CIS AWS Foundations Benchmark v1.2 requirement 1.1 as mapped in AWS Security Hub.” (CIS AWS Foundations Benchmark; AWS Security Hub CIS AWS Foundations mapping table)

Operator meaning: Implement the CIS AWS Foundations v1.2 control that requires you to avoid using the AWS account root user, using the AWS Security Hub mapping as the operational reference point for how the requirement is evaluated (AWS Security Hub CIS AWS Foundations mapping table). Practically, you need: root locked down, root use restricted to break-glass, and monitoring plus evidence that root is not being used for normal operations.

Implementation anchor: Track and remediate the mapped Security Hub control for this requirement (IAM.20) so you have a consistent, testable standard across accounts (AWS Security Hub CIS AWS Foundations mapping table).

Plain-English interpretation (what the requirement expects)

You should run AWS using named, least-privileged IAM roles/users (preferably via federation/SSO) and keep the root user as an emergency-only identity. Your program should make root usage rare, obvious, approved, and reviewable.

What “avoid” means in practice:

• Root is not used for provisioning, debugging, daily admin, or routine billing tasks.
• Root has MFA enabled and credentials are protected.
• Root has no access keys and cannot be used programmatically.
• Any root sign-in triggers alerts, investigation, and a recorded reason.

Who it applies to

Entities: Any organization that operates AWS accounts in scope for CIS AWS Foundations Benchmark assessments (CIS AWS Foundations Benchmark).

Operational scope:

• All AWS accounts: production, staging, dev, shared services, security accounts, and any acquired or sandbox accounts that connect to corporate networks or data.
• Teams: Cloud infrastructure, platform engineering, security engineering, identity/access management, and incident response. Compliance owns oversight, but engineering must implement.

Common scoping decisions you must make:

• Whether “lab” accounts are exempt. Most audit approaches still expect baseline root protections everywhere because lab accounts become pivot points.
• Whether third parties (MSPs, consultants) ever have root access. If they do, you need contractual controls and a break-glass workflow that still preserves your evidence.

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

Step 1: Assign ownership and define “break-glass”

1. Name a control owner (cloud security or IAM lead) and a compliance approver.
2. Define “break-glass” conditions (examples: account recovery, support-only actions that require root, rare billing/account actions).
3. Write an exception rule: who can request root, who approves, maximum session duration expectation, and post-use review requirements.

Deliverable: a one-page control card/runbook that an auditor can read and an operator can execute.

Step 2: Lock down the root user

1. Enable MFA on the root user for every AWS account. Store backup codes/seed securely with restricted access.
2. Ensure no root access keys exist. Root access keys create silent, long-lived exposure because they enable API access without interactive login.
3. Harden root credential handling:
   • Keep root email distribution controlled (avoid shared inboxes without strong access controls).
   • Store credentials in an approved secrets manager or offline break-glass vault with dual control.

Step 3: Enforce “no routine root usage” with identity design

1. Move administrators to federated access (SSO/IdP) and role-based permissions.
2. Create dedicated admin roles for common tasks (network admin, security admin, billing admin) and require privileged actions through those roles.
3. Use least privilege and session-based access so activity is attributable to a person, not a shared credential.

Step 4: Implement detection and alerting for root activity

1. Turn on CloudTrail organization-wide and ensure logs are centrally retained (central logging account is a common pattern).
2. Create alerts for root events, such as:
   • Root console login
   • Root credential changes (password/MFA/access keys)
   • High-risk account configuration changes performed by root
3. In Security Hub, monitor the mapped control status and route findings into your ticketing/IR workflow (AWS Security Hub CIS AWS Foundations mapping table).

Step 5: Establish an operating cadence (control health checks)

1. Review Security Hub findings for the mapped control on a recurring schedule.
2. Review CloudTrail root-related events; investigate and document each occurrence.
3. Track remediation to closure when root is used outside break-glass criteria or when a configuration drift is found.

Step 6: Test the break-glass process

1. Run a tabletop: request root, approve it, perform a benign root-only action (or a simulated step if you cannot do it safely), then close out the record.
2. Verify evidence capture: who approved, when used, what was done, and confirmation that root access keys are still absent.

Required evidence and artifacts to retain

Keep these in a GRC repository with clear timestamps and account identifiers:

Configuration evidence

• Screenshot or exported setting record showing root MFA enabled for each AWS account.
• Proof that no root access keys exist (IAM credential report or equivalent evidence from AWS tooling).
• Security Hub evidence: control status and history for the mapped CIS check (AWS Security Hub CIS AWS Foundations mapping table).

Detective control evidence

• CloudTrail configuration evidence showing trails enabled and logging destination/retention configured.
• Alerting configuration (EventBridge/CloudWatch rule definitions, SIEM correlation rule, or ticketing integration) that triggers on root events.
• Sample alert output (sanitized) showing the pipeline works end-to-end.

Operational evidence

• Root usage log: date/time, requester, approver, business justification, actions performed, post-use review notes.
• Monthly/quarterly control check record: reviewer, results, findings, remediation links.

Governance artifacts

• Break-glass policy/runbook.
• Exception register entries (if any) with compensating controls and expiry.

Common exam/audit questions and hangups

“Show me root isn’t used.”
Auditors often ask for CloudTrail event searches for userIdentity.type = Root and supporting alert/ticket evidence for the review period.

“Who can access root and how do you control it?”
They want named individuals, approvals, and proof that credentials are stored securely and not shared loosely.

“Do you have root access keys?”
Expect them to request IAM credential reports or equivalent. If any root keys exist, you will likely face a clear finding because programmatic root access undermines accountability.

“How do you know this works across all accounts?”
This is where Security Hub mapping helps. Show centralized visibility and consistent remediation workflow (AWS Security Hub CIS AWS Foundations mapping table).

Frequent implementation mistakes (and how to avoid them)

1. MFA enabled in some accounts, forgotten in others.
   Fix: maintain an AWS Organizations account inventory and make root MFA a launch/landing-zone gate.

2. Root credentials stored in a shared password manager folder without approvals.
   Fix: require dual control and ticket-based approval; restrict vault access to a tiny break-glass group.

3. “We don’t use root” as a policy statement, with no detection.
   Fix: treat root usage as a security event. Build alerts from CloudTrail and retain evidence of review.

4. No documented exception path, so engineers “just sign in” when blocked.
   Fix: publish a short runbook with an escalation path and expected response times.

5. Security Hub findings ignored because they’re “just benchmark noise.”
   Fix: wire IAM.20 findings into your triage queue and track them like other security issues (AWS Security Hub CIS AWS Foundations mapping table).

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite regulator actions.

Risk implications you can state precisely without over-claiming:

• Root usage reduces attribution and weakens detective controls because actions may not map to an individual identity.
• Root credential compromise can lead to full-account takeover, including disabling logs, changing access, and data exfiltration.
• Audit risk increases when you cannot produce operating evidence (ownership, cadence, and traceable artifacts). This is a documented risk factor for control programs (CIS AWS Foundations Benchmark).

Practical execution plan (30/60/90)

Use phases rather than day-count promises. If you need timeboxes, map them to your change windows and account count.

First 30 days (stabilize and stop the bleeding)

• Inventory all AWS accounts and identify root owner contacts.
• Enable root MFA everywhere; remove any root access keys.
• Turn on centralized CloudTrail if not already enabled.
• Configure basic alerting for root sign-in and root credential changes.
• Create the control card: owner, scope, break-glass definition, and evidence list.

Next 60 days (operationalize and make it auditable)

• Move administrators to federation/SSO and role-based admin access where gaps exist.
• Route Security Hub mapped control findings to ticketing; define SLAs and triage ownership (AWS Security Hub CIS AWS Foundations mapping table).
• Stand up the root usage register and approval workflow.
• Run the first formal control check and save the evidence bundle.

By 90 days (make it resilient)

• Add drift detection: periodic validation of root MFA/no root keys across the org.
• Exercise break-glass in a controlled test and close the loop with documented review.
• Add metrics that matter for GRC: number of root events, time-to-review, and open exceptions (avoid vanity counts; focus on audit questions).
• If you use Daydream, attach the control card, evidence checklist, and recurring tasks to the requirement so your team has a single system of record for operation and evidence.

Frequently Asked Questions

Does CIS 1.1 mean the root user must be disabled or deleted?

No. The AWS root user cannot be deleted. The requirement is to avoid using it for routine operations and restrict it to tightly controlled break-glass scenarios (CIS AWS Foundations Benchmark).

Is enabling MFA on the root user enough to pass this requirement?

MFA is necessary but rarely sufficient by itself. Auditors will still expect proof that root is not used for day-to-day work and that you detect and review any root activity (AWS Security Hub CIS AWS Foundations mapping table).

What evidence is most persuasive to an auditor?

A clean IAM credential report showing no root access keys, proof of root MFA enabled, and CloudTrail searches (or alerts/tickets) demonstrating that root logins are reviewed and explained.

We have an MSP/third party that asks for root access. How do we handle that?

Treat it as an exception with written justification, time-bounded approval, and mandatory post-use review. Prefer delegated admin roles and federation so actions remain attributable to individuals rather than a shared root identity.

How do we monitor root usage across many AWS accounts?

Centralize CloudTrail logs and aggregate Security Hub findings to a security account, then alert on root-related events and the mapped CIS control status (AWS Security Hub CIS AWS Foundations mapping table).

What should we do if we detect an unexpected root login?

Treat it as a security incident until explained. Preserve logs, confirm whether credentials were exposed, rotate root password, verify MFA device integrity, and document the investigation and corrective actions in your ticketing system.