CMMC Level 2 Practice 3.1.15: Authorize remote execution of privileged commands and remote access to security-relevant

CMMC Level 2 Practice 3.1.15 requires you to explicitly authorize (approve and control) any remote use of privileged commands and any remote access to security-relevant functions or data on systems in your CUI environment. Operationalize it by defining what counts as “privileged” and “security-relevant,” restricting remote paths to approved admin methods, and retaining evidence that access was approved, controlled, and logged. ¹

Key takeaways:

• Put remote privileged administration behind approved channels only (for example, managed bastion/jump host, VPN with MFA, controlled admin tools), and block everything else.
• Treat “security-relevant” broadly: security configuration, identity systems, logging, monitoring, and protective controls need authorization gates for remote access.
• Assessors will ask for proof of authorization and technical enforcement, not just a policy statement. ²

CMMC Level 2 aligns to NIST SP 800-171 Rev. 2 for protecting CUI, and Practice 3.1.15 is a control that prevents “back door admin” from creeping into daily operations. If admins can run privileged commands remotely with ad-hoc tools, shared accounts, or unapproved remote access methods, you lose control over who made security-impacting changes and whether those actions were appropriate.

This requirement is straightforward to state and easy to fail in practice because remote administration is everywhere: cloud consoles, hypervisor management, endpoint management tools, SSH/RDP, help desk remote-control tools, MSP access, and emergency break-glass workflows. Your job as a Compliance Officer, CCO, or GRC lead is to translate “authorize” into an operational system: clear definitions, pre-approved remote admin pathways, enforced technical restrictions, and durable evidence that authorization happened.

This page focuses on quick operationalization: scoping, decision points, concrete implementation steps, and assessor-ready evidence. It stays anchored to CMMC program context and NIST SP 800-171 Rev. 2. ^{3 1 2}

Regulatory text

Requirement (as provided): “CMMC Level 2 practice mapped to NIST SP 800-171 Rev. 2 requirement 3.1.15 (Authorize remote execution of privileged commands and remote access to security-relevant).” ¹

What the operator must do: You must ensure remote activities that can change system security posture, or that touch security control planes, only occur through explicitly approved mechanisms and approved users. “Authorize” needs two layers:

1. Administrative authorization (who is allowed, for what systems, under what conditions), and
2. Technical enforcement (only approved remote paths work; everything else is blocked or controlled).

CMMC program expectations flow from the CMMC rule and program guidance; assessments will test whether the practice is implemented and evidenced in the environment that stores, processes, or transmits CUI. ^{3 2}

Plain-English interpretation (what 3.1.15 really means)

Remote privileged access is risky because it bypasses physical controls and often avoids strong oversight. This practice expects you to:

• Identify privileged commands/roles (domain admin actions, root/sudo, local admin, security admin roles, cloud tenant admin roles).
• Identify security-relevant resources (identity systems, security tooling, logging systems, EDR consoles, firewall/router configuration, SIEM, vulnerability management, audit logs, time sync, and configurations that affect authentication/authorization).
• Require explicit approval and control for remote use of those capabilities.
• Prove it with logs and configuration evidence.

A practical test: if a remote session can disable logging, add an admin user, change firewall rules, or alter EDR policy, it is in-scope for this control.

Who it applies to (entity and operational context)

Entities: Defense contractors and subcontractors handling CUI where CMMC Level 2 is required in contracting scope. ^{3 2}

Operational context (typical in-scope areas):

• Admin access into the CUI enclave (or any network segment/tenant handling CUI)
• Remote IT administration by employees and third parties (MSPs, IR firms, consultants)
• Cloud administrative portals and APIs for CUI workloads
• Endpoint management and remote support tools used on CUI endpoints
• Identity providers and directory services that govern access to CUI systems

Scoping note: If your identity system governs access to the CUI environment, treat it as “security-relevant” even if it sits outside the narrowest enclave boundary, because its remote administration can directly impact CUI confidentiality and system integrity.

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

Step 1: Define “privileged” and “security-relevant” for your environment

Create a short control definition that names:

• Privileged roles (Windows: Domain Admins, local Administrators; Linux: root/sudoers; cloud: tenant/global admin and equivalent)
• Security-relevant systems (IdP, directory, EDR, SIEM/logging, firewall/router management, vulnerability scanners, patch management, backup admin consoles)
• Security-relevant actions (account creation, privilege assignment, logging configuration, security policy changes, network policy changes)

This definition becomes the backbone for policy, technical scoping, and evidence collection. ¹

Step 2: Enumerate all remote administration paths (including the “shadow IT” ones)

Inventory where privileged actions can be performed remotely:

• RDP/SSH to servers and admin workstations
• Hypervisor management (vCenter/Hyper-V)
• Network device management (web UI, SSH, controller)
• Cloud consoles and privileged APIs
• Endpoint management consoles
• Help desk remote-control tools
• Third-party remote access tools and browser-based admin panels

Deliverable: a list of remote admin entry points and which ones are approved vs. prohibited.

Step 3: Establish an authorization mechanism (human approval + technical allow-list)

Pick an authorization model you can actually run:

• Role-based authorization: only members of an “Approved Remote Privileged Admins” group can perform remote privileged actions.
• System-based authorization: only from hardened admin workstations or through a bastion host can privileged sessions reach in-scope targets.
• Tool-based authorization: only designated remote admin tools are allowed (for example, SSH from bastion, RDP via gateway, managed remote management platform with MFA).

Write it down in a standard: who approves access (system owner, IT/security), how requests are made, and how exceptions work. ¹

Step 4: Enforce approved remote privileged access paths

Assessors look for technical controls that make the policy real. Common patterns:

• Require a VPN or private access path with MFA for remote administration into the CUI environment.
• Route admin access through a controlled bastion/jump host with strong authentication and logging.
• Restrict inbound management protocols (SSH/RDP/WinRM) to only the bastion or admin subnet.
• Block consumer remote-control tools on CUI endpoints unless explicitly approved and governed.
• For cloud: require MFA for privileged roles, restrict admin portal access by conditional access rules, and limit API key usage to controlled automation accounts.

The “authorization” element is stronger when unapproved remote admin simply cannot connect. ¹

Step 5: Gate privileged commands when remote (session controls)

For systems where remote login is allowed, add guardrails:

• Separate admin accounts from standard user accounts.
• Require privileged elevation (sudo/UAC) and log elevation events.
• Disable direct remote root login where feasible; require named accounts and elevation.
• Use just-enough administration where feasible for high-risk control planes.

Step 6: Capture and retain evidence continuously (make it recurring)

Don’t treat 3.1.15 as a one-time setup. Build a recurring evidence pack:

• Monthly (or another defined cadence) proof that only approved admin paths exist
• Access review results for privileged remote admin groups
• Samples of remote privileged session logs
• Change tickets for any new remote admin tool or new third-party access

Daydream-style execution (as a workflow, not a product pitch): map 3.1.15 to a documented control, assign an owner, define evidence objects, and schedule recurring collection so you always have assessor-ready artifacts without a scramble. ²

Required evidence and artifacts to retain

Keep evidence that shows authorization, enforcement, and operation:

Governance artifacts

• Remote Access / Remote Administration standard (includes definitions of privileged and security-relevant)
• Privileged Access Management (PAM) or admin access procedure (even if lightweight)
• Third-party access procedure for remote privileged administration (request/approval, termination)

Technical artifacts (screenshots/exports/config snippets)

• Firewall/security group rules restricting SSH/RDP/admin ports to bastion/admin subnet
• VPN/MFA configuration for remote admin
• Conditional access policies for privileged cloud roles (if applicable)
• System configuration that disables or restricts direct remote privileged login (where applicable)

Operational records

• Access requests and approvals (tickets) for adding users to privileged remote admin groups
• Access reviews for privileged groups (with reviewer sign-off)
• Logs: bastion/jump host session logs, VPN auth logs, privileged elevation logs, remote admin tool audit logs
• Exception approvals with compensating controls and expiration

Common exam/audit questions and hangups

Assessors and internal auditors commonly press on:

• “Define ‘security-relevant’ in your environment and show me the list of systems.”
• “Show me how remote privileged access is authorized. Who approved these admins?”
• “Demonstrate that unapproved remote tools cannot be used to administer CUI systems.”
• “Show logs for remote privileged sessions and how you review them.”
• “How do you control third-party remote administration, and how do you turn it off?”

Hangup to anticipate: teams document VPN + MFA but forget that cloud admin portals, EDR consoles, and identity administration are also remote access to security-relevant systems.

Frequent implementation mistakes (and how to avoid them)

1. Policy-only compliance. Fix: pair every written rule with a technical deny-by-default control (network restrictions, conditional access, tool allow-list). ¹
2. No clear definition of “security-relevant.” Fix: publish a scoped list and tie it to your system inventory/SSP.
3. Shared admin accounts for remote access. Fix: require named accounts and log privileged elevation.
4. Third-party remote access left unmanaged. Fix: require tickets, time-bound access, and immediate termination on offboarding.
5. Evidence collected once, then stale. Fix: set a recurring evidence capture cadence and store exports/screenshots with dates and owners. ²

Enforcement context and risk implications

No public enforcement cases were provided in the available source catalog for this requirement. The operational risk is still concrete: unauthorized remote privileged access is a common pathway to disable controls, create persistence, and exfiltrate CUI. CMMC assessments will evaluate implementation against NIST SP 800-171 Rev. 2 practice intent and the CMMC program requirements. ^{1 3}

Practical 30/60/90-day execution plan

First 30 days (stabilize and scope)

• Write your 3.1.15 control statement: definitions, in-scope systems, approved remote admin paths, prohibited tools. ¹
• Inventory remote admin entry points and privileged roles for the CUI environment.
• Identify any “wild” remote tools and decide: approve with controls or remove.

Next 60 days (enforce and instrument)

• Implement technical restrictions: management plane access limited to bastion/admin subnet; VPN + MFA for remote admin; conditional access for cloud admin roles. ¹
• Implement an authorization workflow for privileged remote access requests (ticket + approver + expiry for exceptions).
• Turn on and centralize logs for remote admin sessions and privileged elevation events.

By 90 days (evidence-ready operations)

• Run the first access review for privileged remote admin groups; record results and remediation.
• Produce an evidence pack: configurations, logs, sample approvals, and exception register.
• Add recurring evidence capture and ownership tracking (a lightweight GRC workflow is enough; Daydream can formalize mappings and recurring collection for assessment readiness). ²

Frequently Asked Questions

Does 3.1.15 require a dedicated PAM tool?

No specific tool is mandated in the provided text; the requirement is to authorize and control remote privileged execution and access. You can meet intent with role-based controls, strong authentication, restricted admin paths, and durable logs. ¹

What counts as “security-relevant” remote access?

Treat systems and consoles that manage identity, logging, monitoring, network security, endpoint protection, and security configuration as security-relevant. If remote access can change security posture or hide activity, scope it in. ¹

Are cloud admin consoles in scope for this requirement?

If your cloud environment stores, processes, or transmits CUI, privileged access to the cloud tenant and its security controls is remote access to security-relevant functions. Control it with approved roles, MFA, conditional access, and logging. ¹

How do we handle third-party/MSP remote administration?

Put third-party privileged remote access behind the same approved pathways, require explicit approval, and keep termination/offboarding tight. Retain tickets, approvals, and session logs that show who accessed what and when. ¹

What evidence is most persuasive to an assessor?

A combination of (1) written standard defining privileged and security-relevant, (2) technical enforcement proof (network/conditional access restrictions), and (3) operational records (approvals, access reviews, session logs). ²

We need emergency “break-glass” admin access. Does 3.1.15 allow it?

Yes, if you pre-authorize the mechanism, document conditions for use, tightly control credentials, and keep strong logs and after-action review records. Treat break-glass as an exception process with clear ownership. ¹

Footnotes

1. NIST SP 800-171 Rev. 2

2. DoD CMMC Program Guidance

3. 32 CFR Part 170