03.01.01: Account Management

To meet the 03.01.01: account management requirement in NIST SP 800-171 Rev. 3, you must establish a controlled account lifecycle for all system accounts that can access CUI systems: request, approval, provisioning, change, periodic review, suspension, and termination, with traceable evidence. Operationalize it by centralizing identity sources, enforcing approvals, and retaining auditable logs and review records. ¹

Key takeaways:

• Define account types, owners, and lifecycle events, then map them to each in-scope system in your SSP. ¹
• Enforce approvals and timely deprovisioning through IAM/ITSM workflows, not email threads. ¹
• Keep recurring evidence: access requests, approvals, provisioning logs, review results, and POA&M items for gaps. ¹

03.01.01 is where assessors quickly learn whether your access control program is real or mostly paperwork. “Account management” sounds basic, but in a CUI environment it becomes a discipline: you must know which accounts exist, why they exist, who approved them, what they can access, and when they must be removed. If any of those answers depend on tribal knowledge, a shared mailbox, or a last-minute spreadsheet, you will struggle to defend the control.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat 03.01.01 as an account lifecycle control with explicit system boundaries. Start by enumerating all in-scope systems that store, process, or transmit CUI and the identity stores and directories that grant access to them. Then lock down how accounts are created and changed (approval and ticketing), how they are reviewed (recurring attestations), and how they are removed (termination triggers and automation). Document the implementation in your System Security Plan (SSP), track gaps in your POA&M, and keep evidence that shows the process runs as designed. ¹

Regulatory text

Excerpt/summary: “NIST SP 800-171 Rev. 3 requirement 03.01.01 (Account Management).” ¹

Operator interpretation of what the text requires: You need a managed process for accounts that can access the system environment where CUI is handled. That process must cover account creation, enabling, modification, disabling, and removal, and it must be implemented consistently across in-scope technologies with evidence you can show an assessor. Document how it works in your SSP and manage any gaps through POA&M governance. ¹

Plain-English interpretation (what “good” looks like)

If a person (or service) can log into an in-scope system, then:

1. the account exists for a defined business reason,
2. the right approver authorized it,
3. access matches the user’s role and current need, and
4. the account disappears quickly when that need ends.

Assessors typically test this control by sampling accounts and walking backward to the proof (request, approval, provisioning record) and forward to the ongoing governance (review results, termination records, and change history). Your goal is to make that walkthrough boring.

Who it applies to

Entity scope: Any organization operating nonfederal systems handling Controlled Unclassified Information (CUI), including federal contractors and defense contractors implementing NIST SP 800-171 Rev. 3 requirements. ¹

Operational scope (where it shows up):

• Identity providers (IdP), directories, and SSO platforms
• Endpoints and servers (local accounts, admin accounts)
• Cloud tenants and SaaS apps used for CUI
• DevOps platforms and code repositories in the CUI boundary
• Databases and storage systems hosting CUI
• Privileged access pathways (break glass, emergency admin)

Account scope (common categories you must include):

• Workforce user accounts (employees, temps)
• Third-party user accounts (MSSPs, consultants, partner support)
• Privileged/admin accounts (domain admins, cloud admins)
• Service accounts (applications, scheduled jobs, API clients)
• Shared accounts (avoid; if unavoidable, tightly control and document)

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

1) Set your boundary and inventory account-capable systems

• List the systems in your CUI boundary and the authoritative sources of identity for each (IdP, AD, local accounts, application-native users).
• Identify where accounts can be created outside your normal workflow (local admin creation, SaaS app admins, emergency access methods).
• Record this mapping in your SSP as the foundation for testable control statements. ¹

Practical output: A system-to-identity-store matrix that lets you say, “All accounts originate here; exceptions are documented here.”

2) Define account types, ownership, and approval rules

Create a short standard that answers:

• What account types exist (standard, privileged, service, third-party)?
• Who can approve each type (manager, system owner, data owner, security)?
• What triggers creation (hire, contract start, project onboarding)?
• What triggers changes (role change, new project, privileged elevation)?
• What triggers removal (termination, contract end, inactivity, project exit)?

This becomes the “rules of the road” you enforce through workflow and tooling.

3) Put creation/modification behind controlled workflows

• Require a ticket (ITSM) or access request workflow for new accounts and access changes.
• Require explicit approval steps appropriate to the access level.
• Enforce provisioning through IAM where possible (groups/roles), not direct per-user entitlements.

Common assessor test: “Show me how an account was created.” Your workflow should produce a single record that shows requester, approver, date, scope, and what was provisioned.

4) Control privileged accounts separately

• Require separate privileged identities (no day-to-day admin from standard accounts).
• Restrict who can grant admin roles, and record approvals.
• Document emergency access (“break glass”) with strict logging and after-the-fact review.

Even if 03.01.01 doesn’t spell out privileged nuances in the excerpt you have, assessors will still expect privileged accounts to be under tighter governance because they are the fastest path to CUI exposure. Align your SSP narrative to your actual privileged access design. ¹

5) Manage service accounts deliberately

Service accounts fail audits because nobody “owns” them.

• Assign an accountable owner (system owner) and a purpose statement.
• Store them in an inventory with where used, permissions, and rotation/disablement process.
• Prohibit interactive login unless there is a documented exception.

6) Run recurring account reviews with action tracking

Set a review cadence that matches your risk and system complexity (your choice; make it consistent and defensible). Each review should:

• Compare active accounts to current workforce/third-party rosters.
• Identify orphaned, dormant, duplicated, or excessive-privilege accounts.
• Produce a remediation list with owners and completion evidence.

Track findings in your POA&M until closure, and validate closure before you mark items complete. ¹

7) Deprovision fast, and prove it

Tie disablement to authoritative events:

• HR termination feeds
• Contractor offboarding dates
• Third-party access end dates tied to statements of work
• Project-based removal triggers

Evidence expectation: A termination record (HR/contract) plus an access removal record (IAM/ITSM logs) that shows the account was disabled/removed across in-scope systems.

8) Build your SSP + POA&M story so it survives sampling

This requirement often “fails on narrative.” Do three things:

• Map 03.01.01 to SSP control statements that name systems, tools, and owners. ¹
• Define measurable implementation criteria (what logs, what workflow steps, what review outputs). ¹
• Track gaps in POA&M with target dates, risk ratings, and closure validation. ¹

If you use Daydream to manage control-to-evidence mapping, set 03.01.01 up with an evidence checklist per system and automate recurring evidence requests from identity, IT, and system owners. Daydream is most valuable here when it reduces “audit scramble” by keeping account review outputs and provisioning approvals attached to the control in real time.

Required evidence and artifacts to retain (assessor-ready)

Use this as a retention checklist (adapt to your environment):

Evidence / artifact	What it proves	Typical owner
Account management policy/standard	Lifecycle rules, approval model	GRC / Security
SSP section for 03.01.01	How the requirement is implemented in-scope	GRC
System-to-identity-store matrix	Coverage across systems	IAM / IT
Access request tickets (new/change)	Authorization and traceability	IT / App owners
Provisioning logs (IdP/IAM/Directory)	What changed and when	IAM
Privileged access approvals and role assignment logs	Admin governance	Security / IAM
Service account inventory with owners	Accountability for non-human access	App owners
Periodic access review outputs and sign-offs	Ongoing governance	System owners
Offboarding/termination records + deprovision evidence	Timely disablement	HR + IT
POA&M entries + closure validation	Managed remediation	GRC 1

Common exam/audit questions and hangups

1. “How do you know this is all the accounts?”
   Hangup: local accounts, SaaS-native users, and emergency accounts missing from inventory.

2. “Show me approvals for these sampled accounts.”
   Hangup: approvals exist only in email/Slack; no durable record tied to the change.

3. “How do you remove access for third parties?”
   Hangup: contractor accounts linger because nobody owns the offboarding trigger.

4. “Who reviews access, and what happens to findings?”
   Hangup: reviews are informal; no evidence of remediation, no POA&M linkage. ¹

Frequent implementation mistakes (and how to avoid them)

• Mistake: Treating the IAM tool as the control. Tools help, but the requirement is governance plus proof. Fix it with explicit workflows and named owners in the SSP. ¹
• Mistake: Ignoring service accounts. Create an inventory, assign owners, and set change controls.
• Mistake: Periodic reviews that don’t drive action. Require tickets for removals/changes and attach closure evidence to the review record.
• Mistake: “One process” that doesn’t cover SaaS and cloud roles. Your SSP must reflect reality system-by-system.
• Mistake: No POA&M discipline. If you have gaps, document them, set target dates, and validate closure. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. Practically, weak account management increases the likelihood of unauthorized access to CUI through orphaned accounts, excessive privileges, and uncontrolled third-party access paths. Your risk posture improves when you can prove who has access, why, and how quickly that access is removed when conditions change. ¹

Practical 30/60/90-day execution plan

First 30 days (stabilize and define)

• Confirm your CUI boundary systems and identity sources; build the system-to-identity-store matrix. ¹
• Publish a short account management standard: account types, approvers, and lifecycle triggers.
• Implement or tighten the access request workflow in ITSM/IAM for new and changed access.
• Draft SSP language for 03.01.01 that names tools, systems, and control owners. ¹

Days 31–60 (operationalize and evidence)

• Stand up privileged account governance (separate identities, approvals, logging).
• Create a service account inventory with ownership and purpose statements.
• Run your first formal account review for one high-risk system, document findings, open remediation tickets, and record results for evidence.
• Start a POA&M register for 03.01.01 gaps and define closure validation steps. ¹

Days 61–90 (scale and prove repeatability)

• Expand formal account reviews across all in-scope systems; standardize reviewer sign-off.
• Test offboarding end-to-end for employee and third-party scenarios; retain proof.
• Validate the SSP matches reality; update control narratives and system mappings.
• If you use Daydream, configure recurring evidence collection (review outputs, approval samples, deprovision samples) so the control stays “evergreen” between assessments.

Frequently Asked Questions

Does 03.01.01 apply to SaaS apps like ticketing, file sharing, or code repos if they touch CUI?

Yes. If the SaaS app is in your CUI boundary, the accounts that grant access to it fall under account management expectations, and your SSP should describe how those accounts are created, reviewed, and removed. ¹

Do service accounts count as “accounts” for this requirement?

They should. Treat non-human identities as first-class accounts with owners, documented purpose, controlled creation, and removal procedures, and keep evidence that permissions stay appropriate. ¹

What’s the minimum evidence an assessor will expect for a sampled user account?

Expect to show the request, the approval, the provisioning event (or admin action log), and the user’s current entitlement. If you also have periodic review sign-off that includes the user, keep it with the control evidence set. ¹

How do we handle third-party access where the third party manages its own identities?

Document the model in your SSP and define the control point you own (for example, federated access approval, role assignment, and removal). You still need a reliable offboarding trigger and proof that access is revoked when the engagement ends. ¹

Our approvals happen in email. Is that acceptable?

Email can work as evidence if it is complete, retrievable, and tied to the actual provisioning change, but it is fragile during sampling. Move approvals into an ITSM or access request workflow so the record is consistent and auditable.

What if we discover orphaned accounts during the first review?

Treat them as control findings, remediate through tracked tickets, and record closure evidence. If the issue is systemic, document it as a POA&M item with clear owners and closure validation. ¹

Footnotes

1. NIST SP 800-171 Rev. 3