PR.AA-01: Identities and credentials for authorized users, services, and hardware are managed by the organization

PR.AA-01 requires you to centrally manage identities and credentials for every authorized human user, non-human service, and hardware asset so access can be granted, reviewed, rotated, and revoked in a controlled, provable way. To operationalize it fast, define authoritative identity sources, standardize credential types, enforce lifecycle workflows, and retain audit-grade evidence of provisioning, changes, and deprovisioning. ¹

Key takeaways:

• Cover humans, services, and devices; most programs fail by ignoring non-human identities and hardware credentials.
• Make identity lifecycle actions (create/change/disable) ticketed, approved, and logged with periodic review.
• Evidence matters as much as tooling: inventories, access records, rotation logs, and exception handling must be retained. ¹

PR.AA-01: identities and credentials for authorized users, services, and hardware are managed by the organization requirement is an operational control requirement: you must be able to name who/what has access, prove they are authorized, and show that the credentials they use are issued, protected, rotated, and revoked under your rules. The scope is broader than employee accounts. It includes service accounts, API keys, OAuth clients, workload identities, certificates, SSH keys, local accounts on servers, and device identities such as TPM-backed keys, MDM-issued certificates, and network access credentials.

Auditors and incident responders look for two things: (1) completeness (did you include all identity types across SaaS, cloud, endpoints, and network gear) and (2) control of lifecycle (can you rapidly disable access everywhere, and can you prove it happened). This is why PR.AA-01 is not “implement SSO and move on.” SSO helps for workforce access; it rarely solves machine identities or embedded credentials in hardware and scripts.

The fastest path to defensible implementation is to pick an authoritative identity plane (IdP/IAM + CMDB/asset inventory), standardize credential issuance, and run lifecycle workflows through tickets/automation with reliable logs and periodic reviews. ¹

Regulatory text

Excerpt: “Identities and credentials for authorized users, services, and hardware are managed by the organization.” ¹

What the operator must do:
You must implement a managed system of record and operating process for (a) identities (the unique representations of users, services, and devices) and (b) credentials (passwords, keys, tokens, certificates) so that only authorized entities authenticate, credentials are issued and changed under control, and access can be promptly revoked. This includes defining ownership, approvals, and evidence collection so the program is auditable and repeatable. ²

Plain-English interpretation

If something can log in or authenticate to your systems, you need to:

1. know it exists,
2. know who owns it,
3. know what it can access,
4. control how its credentials are created, stored, rotated, and revoked, and
5. prove all of the above with records. ¹

PR.AA-01 is satisfied when identity and credential handling is not ad hoc. “We think the team creates accounts in Okta” is not enough. “Here is the inventory, here are the workflows, here is the access review evidence, here are the revocation records” is what examiners accept.

Who it applies to

Entity scope: Any organization running a cybersecurity program that manages access to information systems, including regulated and non-regulated entities adopting NIST CSF 2.0. ¹

Operational scope (what to include):

• Workforce identities: employees, contractors, interns, temporary staff, break-glass admins.
• Third-party identities: external support engineers, implementation partners, outsourced IT, managed service providers.
• Non-human identities: service accounts, CI/CD runners, RPA bots, integration users, API clients, OAuth apps.
• Hardware/device identities: endpoints, mobile devices, servers, network gear, IoT/OT where applicable, and the credentials used for device management and network admission (e.g., MDM certs, 802.1X creds, SSH keys). ¹

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

Step 1: Assign control ownership and define scope boundaries

• Name a control owner (typically IAM lead or Security Engineering) and a compliance owner (GRC) responsible for evidence.
• Define what systems are in scope: IdP, cloud IAM, key vaults, PAM, MDM, certificate services, HRIS, ITSM, and asset inventory.
• Write scope rules for edge cases: shared workstations, offline devices, OT, emergency accounts. ¹

Step 2: Establish authoritative sources of truth

Create a simple “system of record” map:

• Humans: HRIS (employment status) + IdP (authentication) + directory (group membership).
• Services: cloud IAM and secrets manager/key vault; repo/CI system for pipeline identities.
• Hardware: MDM/endpoint management + asset inventory/CMDB; network identity store if you use certificates.
  Document where each identity type is created and who can approve it. ¹

Step 3: Build an identity inventory that is complete enough to govern

Minimum inventory fields that reduce audit friction:

• Identity name/unique ID
• Type (human/service/device)
• Owner (person/team) and business purpose
• Systems/roles/groups attached
• Credential type(s) used (password, key, certificate, token)
• Status (active/suspended/disabled)
• Created/last changed/last used timestamps (where available)

Practical approach: export from IdP, cloud IAM, MDM, and key management systems into a governed register (GRC tool, spreadsheet with change control, or CMDB). Tie each row to an accountable owner. ¹

Step 4: Standardize credential issuance and storage rules

Set policy-level rules you can enforce:

• No shared accounts except documented break-glass accounts with compensating controls.
• Secrets live in approved stores (password manager, secrets manager, HSM/KMS-backed vault) rather than code repos and wikis.
• Certificates/keys are issued and tracked with an owner and renewal/rotation expectations.
• Hardware credentials (local admin, device certs) are managed through MDM/PAM where feasible.

If you can’t enforce a rule everywhere, document exceptions with risk acceptance and an expiration date. ¹

Step 5: Implement lifecycle workflows (joiner/mover/leaver + device/service lifecycle)

Operationalize with ITSM tickets or automated workflows:

• Provisioning: request, approval, creation, assignment to least-privilege groups/roles.
• Changes: role change triggers access adjustment; service identity permission changes require change management.
• Deprovisioning: disable IdP account, revoke tokens/keys, remove from groups, disable cloud access keys, rotate shared secrets affected by departure, reclaim devices.
• Periodic review: owners attest that access remains appropriate, and service/device accounts are still needed.

For non-human identities, require an “owner-of-record” and a “rotation event” whenever the owning application changes hands. ¹

Step 6: Add technical guardrails that make the process stick

You can meet PR.AA-01 with process, but guardrails reduce human error:

• Centralize workforce authentication in the IdP where possible.
• Restrict creation of cloud IAM users/keys and require federation or approved workflows.
• Use PAM for privileged credentials and break-glass access.
• Monitor for unmanaged credentials (keys in repos, long-lived tokens, dormant accounts) and route findings into remediation tickets.

Guardrails are also your strongest evidence during audits because they show preventive control, not just detective cleanup. ¹

Step 7: Set up recurring evidence collection

Convert PR.AA-01 into a control with a calendar:

• Monthly/quarterly exports of identity inventories (humans, services, devices).
• Access review completion records with approver identity and outcomes.
• Deprovisioning samples showing timeliness and completeness of revocation actions.
• Secrets/key/certificate rotation logs or renewal records.
• Exception register with approvals and expiration tracking.

If you use Daydream to run your control library and evidence collection, map PR.AA-01 to the policy, procedure, control owner, and recurring evidence tasks so audits don’t turn into screenshot hunts. ¹

Required evidence and artifacts to retain

Keep artifacts in a form you can re-produce and explain:

Governance

• IAM/Access Control Policy covering humans, services, and devices (includes ownership, approvals, exceptions)
• Documented RACI for IAM operations and approvals
• Procedure/runbooks for joiner/mover/leaver and service/device identity lifecycle ¹

System-of-record outputs

• IdP user export (active/disabled; group memberships)
• Cloud IAM identities export (roles, access keys status)
• MDM/device inventory export (enrollment status; device identity/cert status where applicable)
• Secrets manager inventory (names/owners/last rotation metadata where available) ¹

Control operation evidence

• Samples of provisioning/changes/deprovisioning tickets with approvals
• Access review attestations and remediation tickets
• Break-glass account log and approvals
• Exception register and risk acceptances with expiration dates ¹

Common exam/audit questions and hangups

Auditors tend to probe gaps between “policy says” and “system shows.”

Audit question	What they’re really testing	What to show
“How do you know this is the full population of identities?”	Completeness across systems	Inventory method + exports from IdP/cloud/MDM + reconciliation notes
“Who owns service accounts and API keys?”	Accountability for non-human access	Owner-of-record field, ticket trail, rotation/disable proof
“How do you revoke access for a terminated user?”	End-to-end offboarding	HR trigger + IdP disable + downstream revocations + sample cases
“How do you manage hardware credentials?”	Device identity and admin credential control	MDM enrollment rules, local admin management approach, cert issuance/renewals
“How do you review access?”	Ongoing governance	Review schedule, evidence, and remediation outcomes

Frequent implementation mistakes and how to avoid them

1. SSO-only mindset. SSO covers workforce apps, not service accounts, cloud access keys, SSH keys, or embedded API tokens. Fix: build a non-human identity register and require owners. ¹

2. No lifecycle for service identities. Teams create a key “temporarily” and it lives for years. Fix: require expiration/rotation expectations and block new secrets outside approved stores. ¹

3. Hardware ignored until an incident. Devices often retain stale certificates, local admin passwords, or default credentials. Fix: enforce MDM enrollment, manage local admin, and track device identity state in inventory. ¹

4. Orphaned accounts after org changes. Mergers, contractor churn, and app owners leaving create access debt. Fix: periodic recertification and an “unknown owner” queue that forces assignment or disablement. ¹

5. Evidence scattered. Controls may exist, but proof is missing. Fix: define an evidence list and collect it on a cadence; centralize in a GRC repository with consistent naming. Daydream can run this as recurring evidence tasks tied to PR.AA-01. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for PR.AA-01. From a risk standpoint, weak identity and credential management consistently amplifies breach impact: compromised credentials enable lateral movement, persistence via service accounts, and unauthorized access through unmanaged device or machine identities. PR.AA-01 reduces this exposure by making identities enumerable, owned, and revocable, with credential hygiene that holds up under incident response. ¹

A practical 30/60/90-day execution plan

Use this as a sequencing guide; adjust to your environment and change-control constraints.

First 30 days (Immediate stabilization)

• Assign control owner, approvers, and evidence owner.
• Publish scope statement covering humans, services, and hardware identities.
• Produce baseline exports: IdP users/groups, cloud IAM identities, MDM device list, and a first-pass service account list.
• Stand up an exception register and require owners for every exception. ¹

By 60 days (Operational workflows)

• Implement joiner/mover/leaver workflow with ticketing evidence.
• Define and enforce service identity creation rules (owner-of-record, purpose, approved secret storage).
• Begin first access recertification for privileged groups and high-risk services.
• Add guardrails: restrict who can mint long-lived keys/tokens; require approved secret stores for new secrets. ¹

By 90 days (Audit-ready operation)

• Expand recertification to broader user groups and key applications.
• Add hardware credential management proof points (MDM enrollment compliance, local admin approach, device identity tracking).
• Demonstrate deprovisioning completeness with a sample set of departures (show disablement and downstream revocation).
• Automate recurring evidence pulls and store them centrally; map PR.AA-01 to policy/procedure/control owner and recurring evidence in Daydream for steady-state readiness. ¹

Frequently Asked Questions

Does PR.AA-01 require MFA?

PR.AA-01 focuses on managing identities and credentials end-to-end, not a single authentication factor. MFA often becomes part of the credential control strategy, but your obligation here is broader: inventory, ownership, lifecycle, and revocation for humans, services, and devices. ¹

How do we handle service accounts that can’t use SSO?

Treat them as non-human identities with an owner-of-record, documented purpose, and controlled credential storage and rotation. If the platform forces long-lived secrets, document compensating controls and track an exception with an expiration date. ¹

What counts as “hardware credentials” in practice?

Anything a device uses to authenticate or be administered, including device certificates, local admin credentials, SSH keys for device management, and network admission credentials. Manage these through MDM/PAM/certificate services where possible, and track device identity status in inventory. ¹

We have hundreds of SaaS apps; where should we start?

Start with the IdP as the workforce identity plane, then prioritize privileged access and systems that store sensitive data. For the long tail, enforce “new app must integrate with IdP” and run phased access reviews based on risk. ¹

What evidence do auditors accept if we automate provisioning?

Provide workflow definitions (who approves what), system logs showing account creation/changes, and a sample set of tickets or automated audit logs tied to specific identities. Automation helps, but you still need traceability from request to access grant. ¹

How do we prove completeness of our identity inventory?

Show the source exports (IdP, cloud IAM, MDM, secrets manager) and a reconciliation method that explains overlaps and exclusions. Auditors accept reasonable methods when you can explain them consistently and show follow-up on exceptions and unknown owners. ¹

Footnotes

1. NIST CSWP 29

2. NIST CSF 1.1 to 2.0 Core Transition Changes; Source: NIST CSWP 29