PR.AT-02: Individuals in specialized roles are provided with awareness and training so that they possess the knowledge and skills to perform relevant tasks with cybersecurity risks in mind

To meet the pr.at-02: individuals in specialized roles are provided with awareness and training so that they possess the knowledge and skills to perform relevant tasks with cybersecurity risks in mind requirement, identify specialized roles, define role-based cybersecurity training outcomes, deliver training before privileged or high-impact work begins, and retain proof of completion and competence. Operationalize it by mapping roles to risks, training modules, owners, and recurring evidence collection. 1

Key takeaways:

  • Specialized roles need role-based training tied to the tasks and risks they actually perform, not generic security awareness. 1
  • Audit defensibility depends on mapping: role → tasks → risks → training → competency checks → evidence. 2
  • The most common failure mode is “training happened” without proving coverage, timeliness, or job relevance for privileged and high-risk roles. 1

PR.AT-02 focuses on people, not platforms. Your baseline security awareness program may cover phishing, passwords, and incident reporting, but PR.AT-02 expects more: individuals in specialized roles must be trained so they can perform their specific duties with cybersecurity risks in mind. 1

For a CCO or GRC lead, the fastest path to compliance is to treat PR.AT-02 as a role-based control with measurable coverage and repeatable evidence. That means you define which roles are “specialized,” what “good” looks like for each, and how you will prove the organization did the training and that it was relevant to the person’s tasks. 1

This requirement typically touches IT and Security, but it also reaches engineering, data, privacy, legal, procurement, and any business function that administers access, configures systems, handles sensitive data, or manages third parties. If your organization relies on managed service providers or contractors in these roles, your process must account for them too, because the risk exposure is the same even if the worker is not on payroll. 1

Regulatory text

Excerpt: “Individuals in specialized roles are provided with awareness and training so that they possess the knowledge and skills to perform relevant tasks with cybersecurity risks in mind.” 1

Operator interpretation (what you must do):

  1. Define “specialized roles” in your environment (by job function, access level, or tasks performed). 1
  2. Provide training and awareness tailored to those roles so individuals can perform their tasks securely, with the relevant cyber risks understood. 1
  3. Be able to show evidence that the training occurred, was role-appropriate, and is maintained over time through a repeatable process (not ad hoc). 2

Plain-English interpretation of the requirement

PR.AT-02 means: if someone’s job can materially change your security posture, expose sensitive data, or weaken controls, you must give them training that matches the reality of their job. A developer needs different guidance than Accounts Payable. A cloud engineer needs different guidance than a call center supervisor. 1

You are not being asked to create a graduate program. You are being asked to show that (a) you identified the roles where mistakes become incidents, (b) you trained those people on the risks and safe ways of working, and (c) you can prove it. 1

Who it applies to (entity and operational context)

Applies to: organizations operating a cybersecurity program and using NIST CSF 2.0 as a framework expectation. 1

Common specialized roles to scope (examples you can adapt):

  • Privileged access administrators: identity admins, domain admins, PAM operators.
  • Security operations roles: SOC analysts, incident responders, threat hunters.
  • Engineers with production change authority: SRE, platform engineering, DevOps, release managers.
  • Cloud and network roles: cloud admins, network engineers, firewall/WAF administrators.
  • Data roles: database admins, data engineers, analytics engineers handling regulated data.
  • Application and product roles: developers, QA automation, product security champions.
  • Third-party facing roles: procurement, third-party risk, vendor managers who approve security exceptions.
  • Business roles with high-risk workflows: finance roles handling payment instructions; HR roles handling identity lifecycle inputs.

Operational contexts where PR.AT-02 becomes high priority:

  • You grant privileged access without a defined onboarding-to-training gate.
  • You ship code frequently and rely on peer review without secure coding standards training.
  • You outsource IT/security operations to third parties without verifying role-based training expectations. 1

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

1) Assign ownership and define the control boundary

  • Control owner: usually Security GRC with HR/Learning and functional leaders as contributors.
  • System of record: LMS, HRIS, or an access governance tool; pick one place auditors can follow.
  • Boundary statement: roles included, populations included (employees, contractors, key third parties), and training types included (internal, external certifications, vendor-specific). 1

2) Build a “specialized roles” inventory tied to risk

Create a simple table and keep it current:

Role / group Why it’s specialized Key tasks Primary risks Required training
Cloud admin Broad control-plane authority IAM, networking, logging Misconfig, excessive access Cloud security fundamentals + org standards
Developer Writes and deploys code PRs, dependency updates Injection, secrets leaks Secure coding + secrets handling

Your goal is traceability from role → tasks → risks → training. 1

3) Define training objectives and “what good looks like”

For each specialized role, define:

  • Learning objectives: what the person must know to perform securely (for example: secure configuration baselines, change control requirements, incident escalation).
  • Required frequency triggers: onboarding, role change, major technology change, and refresher cadence (set a cadence your organization can sustain).
  • Competence check: quiz, lab, scenario review, or manager attestation tied to observed work outputs.

Avoid vague objectives like “understands cybersecurity.” Make them task-oriented. 1

4) Select or build training content (keep it role-specific)

Use a blend:

  • Role-based modules (secure coding, cloud hardening, privileged access handling)
  • Organization-specific procedures (how to request firewall changes, how to store secrets, what “break glass” means internally)
  • Scenario drills (tabletops for incident responders; change failure drills for SRE)

Map each module back to the role inventory table to prove coverage. 2

5) Implement gating and workflow hooks

Training without operational hooks turns into “checkbox compliance.” Add gates such as:

  • Pre-access gate: require completion before granting privileged roles or production deploy rights.
  • Role-change gate: when HRIS reflects a job change, auto-enroll required training.
  • Exception workflow: documented approval for temporary access when training is pending, with a time-bound remediation plan.

This is where auditability improves sharply: your process prevents untrained specialized staff from doing high-risk tasks. 1

6) Run recurring evidence collection (make it routine)

Decide how you will capture evidence at set intervals:

  • Pull completion reports by role group.
  • Reconcile HR roster vs LMS completion.
  • Track late completions and exceptions.
  • Report coverage to a security or risk committee.

Daydream can help by mapping PR.AT-02 to your policy, procedures, control owner, and an evidence schedule so you always know what to collect and when. 2

Required evidence and artifacts to retain

Keep evidence that proves design and operation:

Design artifacts

  • Role-based training standard (policy or control statement) referencing specialized roles.
  • Role inventory and mapping table (role → tasks → risks → training modules). 1
  • Training curriculum outlines and learning objectives by role.
  • Exception criteria and approval workflow.

Operational artifacts

  • LMS completion reports by role group and period.
  • New hire / role-change enrollment logs.
  • Rosters showing specialized-role population at the time of reporting.
  • Competency checks: quiz results, lab completion, or manager attestations.
  • Records of enforcement: access gating evidence, tickets, or access reviews showing training prerequisites were met.

Retention period should follow your internal compliance record retention standard, and it must be consistent. 1

Common exam/audit questions and hangups

Auditors tend to press on traceability and completeness:

  • “Show me your list of specialized roles. Who approves changes to it?”
  • “How do you ensure contractors in these roles complete training?”
  • “What training does a cloud admin receive that a normal user does not?”
  • “How do you validate people learned anything beyond clicking through modules?”
  • “Prove training happens before privileged access is granted.”
  • “Show exceptions, approvals, and closure.”

Hangup to anticipate: you will have “training completion” but no documented definition of specialized roles. Fix that first. 1

Frequent implementation mistakes and how to avoid them

  1. Mistake: equating PR.AT-02 with annual general awareness.
    Fix: document role-based curricula and keep general awareness separate. 1

  2. Mistake: incomplete population coverage (contractors, interns, MSP staff).
    Fix: include non-employees in scope when they perform specialized tasks; add training clauses to third-party contracts and onboarding checklists. 1

  3. Mistake: no linkage to tasks and systems.
    Fix: tie roles to access profiles (PAM groups, cloud roles, prod deploy permissions) and make training a prerequisite for assignment. 1

  4. Mistake: “set and forget” curricula that falls out of date after platform changes.
    Fix: trigger curriculum review when you introduce new tooling (cloud migration, new CI/CD, new IAM). Track this as a governance item. 1

Enforcement context and risk implications

No public enforcement cases are provided in the source catalog for PR.AT-02, so treat this as a defensibility and loss-prevention control rather than a case-driven requirement.

Operationally, PR.AT-02 reduces two risks that drive real findings across many regimes: (1) privileged or specialized staff make preventable errors, and (2) the organization cannot prove it ran a mature program because evidence is thin or inconsistent. The second risk is avoidable with disciplined mapping and recurring evidence collection. 2

A practical 30/60/90-day execution plan

First 30 days (establish scope and ownership)

  • Name a control owner and agree on the system of record for training evidence.
  • Define “specialized roles” using access and task-based criteria; draft the initial role inventory. 1
  • Identify the top risk workflows to prioritize (privileged access, production changes, incident response, cloud config).

By 60 days (deliver training and implement gates)

  • Publish role-based training requirements and learning objectives. 1
  • Roll out initial modules for the highest-risk roles first.
  • Implement at least one gating control (for example: training required before privileged access assignment).
  • Stand up an exception workflow with approvals and tracking.

By 90 days (prove operation and make it repeatable)

  • Run a full roster-to-completion reconciliation for specialized roles and track remediation.
  • Add competency checks for at least the most sensitive role groups.
  • Produce a management report that shows coverage, exceptions, and corrective actions.
  • Operationalize recurring evidence collection in your GRC workflow (Daydream can track owners, due dates, and artifacts against PR.AT-02). 2

Frequently Asked Questions

Who counts as an “individual in a specialized role” for PR.AT-02?

Anyone whose job tasks can materially affect security outcomes, such as administering privileged access, deploying to production, configuring cloud/network controls, or handling sensitive datasets. Define this in your role inventory and keep it tied to tasks and access. 1

Do I need separate training for every job title?

No. Group roles by similar risk and tasks (for example: “production deployers,” “privileged admins,” “incident responders”). Auditors care about job relevance and coverage, not extreme granularity. 1

How do we handle third parties (contractors/MSPs) in specialized roles?

Put them in scope if they perform the tasks. Require proof of comparable training, provide your organization-specific procedures, and retain evidence through onboarding and contract artifacts. 1

What evidence is strongest in an audit?

A role-to-training mapping, completion reports reconciled to HR rosters, and proof of gating (access assignments tied to training status). Competency checks or manager attestations strengthen the story. 2

Can certifications (cloud certs, security certs) count as PR.AT-02 training?

They can support competence, but you still need training on your internal standards and procedures because PR.AT-02 is about performing relevant tasks in your environment. Keep certificates as supplemental evidence, not the only control. 1

How often should role-based training refresh?

Set a refresher cadence you can sustain and add trigger-based updates for technology or role changes. Document the cadence and triggers so auditors can evaluate consistency. 1

Footnotes

  1. NIST CSWP 29

  2. NIST CSF 1.1 to 2.0 Core Transition Changes

Frequently Asked Questions

Who counts as an “individual in a specialized role” for PR.AT-02?

Anyone whose job tasks can materially affect security outcomes, such as administering privileged access, deploying to production, configuring cloud/network controls, or handling sensitive datasets. Define this in your role inventory and keep it tied to tasks and access. (Source: NIST CSWP 29)

Do I need separate training for every job title?

No. Group roles by similar risk and tasks (for example: “production deployers,” “privileged admins,” “incident responders”). Auditors care about job relevance and coverage, not extreme granularity. (Source: NIST CSWP 29)

How do we handle third parties (contractors/MSPs) in specialized roles?

Put them in scope if they perform the tasks. Require proof of comparable training, provide your organization-specific procedures, and retain evidence through onboarding and contract artifacts. (Source: NIST CSWP 29)

What evidence is strongest in an audit?

A role-to-training mapping, completion reports reconciled to HR rosters, and proof of gating (access assignments tied to training status). Competency checks or manager attestations strengthen the story. (Source: NIST CSF 1.1 to 2.0 Core Transition Changes)

Can certifications (cloud certs, security certs) count as PR.AT-02 training?

They can support competence, but you still need training on your internal standards and procedures because PR.AT-02 is about performing relevant tasks in your environment. Keep certificates as supplemental evidence, not the only control. (Source: NIST CSWP 29)

How often should role-based training refresh?

Set a refresher cadence you can sustain and add trigger-based updates for technology or role changes. Document the cadence and triggers so auditors can evaluate consistency. (Source: NIST CSWP 29)

Operationalize this requirement

Map requirement text to controls, owners, evidence, and review workflows inside Daydream.

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