Safeguard 5.1: Establish and Maintain an Inventory of Accounts

For a CCO or GRC lead, the fastest path to implementing the safeguard 5.1: establish and maintain an inventory of accounts requirement is to treat it as a governance-and-evidence problem, not a directory admin task. CIS is asking for a complete view of “who/what can authenticate,” across identity providers, endpoints, servers, SaaS apps, cloud consoles, databases, and automation. That inventory becomes the backbone for access reviews, offboarding, least privilege, incident response, and third-party access control.

Most gaps come from two places: (1) narrow scope (only listing employees in the IdP, ignoring local accounts, break-glass, service principals, API keys tied to “accounts,” and third-party logins), and (2) weak operating rhythm (a spreadsheet exists once, but nobody can show it’s kept current). Auditors and internal assessors will accept different technical implementations, but they consistently look for the same outcomes: completeness, clear ownership, and repeatable maintenance with retained evidence.

This page translates CIS Safeguard 5.1 into steps you can assign, track, and test, with a specific focus on artifacts you can hand to an assessor. Source references: CIS Controls v8 and CIS Controls Navigator v8. ¹

Regulatory text

Framework requirement (excerpt): “CIS Controls v8 safeguard 5.1 implementation expectation (Establish and Maintain an Inventory of Accounts).” ¹

Operator interpretation of the text: You must (a) identify all accounts that can access your enterprise assets and services, (b) maintain an inventory that stays accurate as accounts change, and (c) be able to demonstrate this inventory exists and is operated as a control, not as a one-time exercise. ¹

Plain-English interpretation (what it really means)

You need a living list of every identity that can log in or otherwise authenticate in your environment. That includes:

• Human accounts: employees, contractors, interns, temporary workforce
• Privileged accounts: admin roles, root, domain admins, delegated admins
• Service / non-human accounts: service accounts, service principals, CI/CD identities, automation runbooks, “app registrations”
• Third-party accounts: support portals, MSP access, outsourced devs, external auditors with access
• Local and “hidden” accounts: local admin on endpoints/servers, database accounts, network device accounts
• Break-glass / emergency access accounts: rarely used, high privilege, must be tracked

Your inventory must answer basic questions fast: What is the account? Who owns it? What can it access? Why does it exist? When was it last used? When does it expire?

Who it applies to (entity and operational context)

Safeguard 5.1 applies broadly to enterprises and technology organizations adopting CIS Controls v8. ¹ In practice, it applies wherever your organization:

• Operates an identity provider (IdP) or directory (cloud or on-prem)
• Uses SaaS applications with distinct account stores (CRM, HRIS, ticketing, finance)
• Runs cloud infrastructure with IAM identities and roles
• Allows third-party connectivity or privileged remote support
• Uses automation that authenticates to systems (scripts, pipelines, bots)

If you have a mix of corporate IT and product engineering, scope both. Engineering-owned cloud accounts and service principals are common blind spots.

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

Step 1: Define “account” and scope (write it down)

Create a short standard that defines:

• In-scope account types (human, privileged, service/non-human, third party, local, break-glass)
• In-scope systems (IdP/directory, major SaaS, cloud IAM, endpoint local accounts, key infrastructure platforms)
• Authoritative sources (your “systems of record” for each account class)

Deliverable: “Account Inventory Standard” (one to two pages) approved by the control owner.

Step 2: Assign control ownership and RACI

Name one accountable owner (often IAM lead or Security Operations) and document:

• Who maintains integrations/exports
• Who reviews exceptions
• Who approves creation of privileged/service/third-party accounts
• Who executes deprovisioning

A clean RACI prevents the common failure mode where Security “expects IT to do it” and IT “expects Security to track it.”

Step 3: Build the minimum inventory schema (required fields)

Define required attributes by account type. Example minimum fields:

Field	Human	Privileged	Service / Non-human	Third party
Unique account identifier	Yes	Yes	Yes	Yes
System / platform	Yes	Yes	Yes	Yes
Account owner (named individual)	Yes	Yes	Yes	Yes
Business purpose / justification	Optional	Yes	Yes	Yes
Privilege level / role	Optional	Yes	Yes	Optional
Creation date	Yes	Yes	Yes	Yes
Last login / last used	Yes	Yes	Yes	Yes
Status (active/disabled)	Yes	Yes	Yes	Yes
Expiration / review date	Optional	Optional	Yes	Yes
Access method (SSO, local, API key)	Optional	Optional	Yes	Yes

Rule to enforce: every non-human or third-party account has a named internal owner and a documented purpose.

Step 4: Aggregate data from authoritative sources (reconcile, don’t just export)

Collect data from:

• Your IdP directory for human accounts and group memberships
• Privileged access tooling (if present) or admin group listings
• Cloud IAM (users, roles, service principals)
• Critical SaaS apps with local user stores
• Endpoint/server local admin accounts (where feasible)

Then reconcile:

• De-duplicate identities
• Normalize naming (email vs username vs GUID)
• Mark accounts discovered outside the expected creation process as “exceptions” for triage

Deliverable: an “Account Inventory” dataset with versioning and change history. A spreadsheet can work early on, but it must be controlled and reproducible.

Step 5: Establish lifecycle controls (create, change, disable, delete)

Document and implement lifecycle rules aligned to your operating model:

• Provisioning: ticketed request, manager/system owner approval, least privilege by default
• Changes: role changes require re-approval for privileged access
• Deprovisioning: disable upon termination or contract end; remove third-party access when engagement ends
• Dormancy: define how you identify stale accounts and how you remediate (disable, rotate credentials, confirm need)
• Service accounts: prohibit shared ownership; require rotation/secret management where applicable; require “no interactive login” where possible

You do not need perfect automation to meet the intent, but you must show the control runs repeatedly and drives cleanup.

Step 6: Set a maintenance cadence and prove it ran

Define a recurring operating rhythm that includes:

• Inventory refresh from sources
• Exception review and remediation tracking
• Metrics that indicate drift (e.g., newly discovered local admins, third-party accounts without owners)

Tie the rhythm to an evidence package (see below). CIS expects maintenance, not a one-time snapshot. ¹

Step 7: Test the inventory (sampling that mirrors audit behavior)

Run periodic tests that simulate assessor questions:

• Pick a terminated user and prove the account is disabled everywhere it should be
• Pick a third-party account and show owner, purpose, and offboarding date
• Pick a service principal and show owning team, what it’s for, and whether it’s still used
• Pick a server and compare local accounts to inventory

Document test results and remediation actions. This is how you turn a list into a control.

Required evidence and artifacts to retain

Auditors usually accept different technical implementations if the evidence is consistent. Retain:

1. Account Inventory Standard (scope, definitions, required fields, authoritative sources)
2. Current account inventory export (controlled file or system report) with timestamp
3. Change log / version history showing updates over time
4. Access lifecycle procedures (provisioning, privileged access, third-party onboarding/offboarding, service account management)
5. Review records (meeting notes, tickets, approvals) showing inventory review and exception handling
6. Exception register for accounts that cannot meet standard (with compensating controls and approvals)
7. Remediation proof (tickets closed, accounts disabled, access removed)
8. Control mapping showing Safeguard 5.1 mapped to documented control operation and recurring evidence capture (recommended practice) ¹

Practical note: retain “before/after” screenshots or exports for high-risk removals (privileged and third-party). They reduce back-and-forth during assessments.

Common exam/audit questions and hangups

Expect these questions:

• “Show me your authoritative inventory of all accounts. How do you know it’s complete?”
• “How do you capture local accounts and cloud service principals?”
• “Who owns service accounts, and how do you prevent orphaned accounts?”
• “How do you handle third-party access, and how do you remove it at end of engagement?”
• “What is your last review evidence? What exceptions were found and resolved?”

Hangups that derail audits:

• Inventory exists but lacks owners for non-human and third-party accounts.
• Inventory is limited to the IdP and ignores SaaS and cloud IAM.
• No evidence of recurring operation (only an undated spreadsheet).

Frequent implementation mistakes and how to avoid them

1. Mistake: treating “accounts” as only employees.
   Fix: explicitly include service and third-party identities in scope and schema.

2. Mistake: no single source of truth.
   Fix: pick a control-plane inventory with reconciled feeds; track authoritative sources per platform.

3. Mistake: missing lifecycle linkage.
   Fix: require a ticket/approval reference for privileged, service, and third-party accounts, and store it as an inventory field.

4. Mistake: inventory updates happen, but nobody can prove them.
   Fix: schedule recurring review, archive exports, and retain the exception/remediation trail.

5. Mistake: exceptions become permanent.
   Fix: put expiration dates on exceptions and force re-approval.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this safeguard, so you should treat this as a framework-driven control expectation rather than a specific enforcement-linked mandate.

Risk implications remain practical:

• Orphaned accounts increase the chance of unauthorized access after terminations or vendor offboarding.
• Unowned service accounts create blind spots for incident response and credential rotation.
• Incomplete inventories undermine downstream controls (access reviews, PAM, monitoring) and weaken your ability to answer “who had access” during investigations.

Practical 30/60/90-day execution plan

First 30 days (stabilize scope and ownership)

• Publish the Account Inventory Standard (definitions, scope, sources, required fields).
• Assign control owner and RACI across IAM, IT, Security, and key application owners.
• Build an initial inventory from the IdP plus at least one high-risk platform (cloud IAM or a critical SaaS app).
• Stand up an exception register and start tracking “unknown owner,” “unknown purpose,” and “stale account” items.

Days 31–60 (expand coverage and build the operating rhythm)

• Add remaining critical sources (privileged groups, cloud service principals, key SaaS user stores).
• Implement lifecycle hooks: required approvals for privileged/service/third-party accounts, plus documented offboarding steps.
• Run the first formal review cycle and retain evidence (export, issues list, tickets closed).
• Start sampling tests (terminated user, third party, service account) and document outcomes.

Days 61–90 (make it audit-ready and repeatable)

• Reconcile gaps: local accounts, break-glass identities, and hard-to-inventory systems.
• Define KPIs that indicate drift (new privileged accounts, accounts without owners, stale accounts) and review them regularly.
• Package evidence for assessors: standard, inventories, change logs, review records, remediation proof.
• If scale becomes a blocker, implement tooling or workflow automation to keep the inventory current and evidence-ready.

Where Daydream fits (earned mention)

Most teams fail Safeguard 5.1 during audits because they cannot show repeatable operation and consistent evidence across sources. Daydream can help you map Safeguard 5.1 to a documented control operation and automate recurring evidence capture, so you can produce the inventory snapshots, review records, and remediation trail on demand. ¹

Frequently Asked Questions

Do we have to inventory accounts in every SaaS tool?

Start with systems that provide meaningful access to company data or administrative control, then expand coverage. Document your scope and rationale so assessors see a governed approach, not omission.

Are API keys and tokens “accounts” under Safeguard 5.1?

CIS 5.1 targets accounts, but in practice API keys and tokens are tied to non-human identities. Track the owning identity, where the credential is used, and who owns the business purpose so they don’t become unowned access paths. ¹

How do we handle shared accounts that a team uses?

Treat shared accounts as an exception that requires documented approval, a named accountable owner, and compensating controls like reduced privilege and monitoring. Put an expiration date on the exception and review it routinely.

What’s the minimum an auditor will accept as an “inventory”?

A controlled dataset (tool report or governed spreadsheet) with clear scope, required fields, and evidence of recurring updates and issue remediation. A one-time export without ownership and maintenance evidence usually fails.

Who should own service accounts: Security or Engineering?

Engineering or the system owner should own the business purpose, while Security/IAM sets standards and enforces required fields and reviews. The inventory must always map each service account to a named internal owner.

How do we prove the inventory is maintained over time?

Retain periodic exports or system reports, plus the review notes and tickets that show exceptions were identified and resolved. Evidence of “findings and fixes” is typically what convinces assessors the control operates.

Footnotes

1. CIS Controls v8; CIS Controls Navigator v8