03.01.06: Least Privilege – Privileged Accounts

The 03.01.06: least privilege – privileged accounts requirement means you must strictly control administrative (privileged) accounts so only explicitly authorized personnel can use them, only for approved tasks, and only on approved systems. Operationalize it by inventorying privileged accounts, enforcing separate admin identities, restricting and monitoring privileged actions, and proving all of this with repeatable review evidence. ¹

Key takeaways:

• You need a complete, system-scoped inventory of privileged accounts and what “privileged” means in your environment.
• Enforce separation (admin vs standard), approvals, and technical restrictions for privileged access paths, not just a policy.
• Retain recurring evidence: access approvals, account lists, logs, and periodic access reviews tied to your SSP/POA&M. ¹

Privileged accounts are the fastest way to lose control of a Controlled Unclassified Information (CUI) environment: they can change configurations, disable security controls, access broad data sets, and create new access paths. Requirement 03.01.06 focuses on the “admin layer” of your systems and asks a simple question that assessors repeatedly test in practice: do you restrict who can act as an administrator, and can you prove it with evidence over time? ¹

For a Compliance Officer, CCO, or GRC lead, the work is not to debate least privilege as a principle. The work is to define privileged access in a way your IT and security teams can implement consistently, then connect it to named systems, owners, access workflows, and monitoring. This page gives you a requirement-level playbook you can hand to operators: what to configure, what to review, what to log, and what to show an assessor.

Your goal is defensible control operation. That means the SSP describes how privileged access is controlled in the CUI boundary, the controls are actually implemented on the systems that matter, and any gaps are tracked and closed through a POA&M with validation. ¹

Regulatory text

Excerpt / reference: “NIST SP 800-171 Rev. 3 requirement 03.01.06 (Least Privilege – Privileged Accounts).” ¹

Operator interpretation: You must ensure privileged accounts (administrators, root, domain admins, cloud admins, database admins, security admins, and any account with equivalent power) are limited to approved personnel and constrained to approved activities within the CUI system boundary. You also need to implement controls that prevent privileged access from becoming the default way people work, and you need evidence that the restrictions operate continuously. ¹

Plain-English interpretation (what this really requires)

• Define “privileged” precisely. Privileged is not a job title; it is a capability on a specific system (for example, ability to change access controls, modify security settings, manage identities, or read sensitive stores).
• Minimize privileged identities and sessions. Fewer privileged accounts, fewer privileged logins, and fewer systems where privilege exists.
• Make privileged use provable. If you cannot list privileged accounts by system and show who approved them, you have not operationalized the requirement. ¹

Who it applies to

Entities

• Defense contractors, federal contractors, and any nonfederal organization handling CUI in nonfederal systems where NIST SP 800-171 Rev. 3 is applicable. ¹

Operational context

• Systems in the defined CUI boundary: endpoints, servers, identity providers, network devices, hypervisors, cloud control planes, CI/CD, databases, security tooling, and managed services consoles.
• Third parties with administrative access into your environment (MSPs, cloud administrators, incident response retainers). Treat third-party privileged access the same as internal privileged access: explicit authorization, constraints, and monitoring.

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

1) Establish your privileged access scope and definitions

1. List in-scope systems for the CUI boundary (from your SSP system inventory).
2. Define privileged account types per platform (examples to include):
   • OS admin/root, local admin
   • Directory roles (domain admin, account operators)
   • Cloud IAM roles with admin rights
   • SaaS roles (global admin, security admin)
   • Database owner/admin roles
   • Network device enable/admin modes
3. Define privileged actions that matter to assessors: create/modify accounts, change ACLs, disable logs/EDR, modify firewall rules, change encryption keys, alter audit settings.

Deliverable: a “Privileged Access Definition & Scope” standard referenced in the SSP. ¹

2) Build (and keep current) a privileged accounts inventory

1. For each in-scope system, export a list of privileged accounts/roles.
2. Normalize the list into a register with fields:
   • System / platform
   • Account name / role name
   • Human owner (if shared/service, name the accountable owner)
   • Privilege type (local admin, global admin, etc.)
   • Justification (why needed)
   • Approval record (ticket/change/control ID)
   • Access path (direct login, via PAM, via jump host, via SSO role)
3. Identify and flag:
   • Shared admin accounts
   • Dormant accounts
   • Accounts without an owner
   • Third-party admin accounts
   • Service accounts with interactive login enabled

Deliverable: “Privileged Account Register” with update cadence and owner. ¹

3) Enforce separation of duties at the identity level

Implement these operator rules:

• Separate accounts: administrators have a standard user identity for email/browsing and a separate admin identity for privileged tasks.
• No standing privilege by default: users should not be local admins on endpoints unless justified and approved.
• Role-based assignment: grant roles to groups, not to individuals, where your platform supports it, and tie group membership to approval workflow.

Evidence expectation: assessors want to see identity patterns and technical settings that make daily work non-privileged. ¹

4) Put technical guardrails on privileged access paths

Your goal is to reduce “anywhere admin” risk and make privileged access harder to abuse.

Minimum guardrails to implement and document:

• Centralize authentication (directory/SSO) for admin consoles where possible.
• Restrict privileged access by network path (jump host/bastion, management VLAN, conditional access).
• Require strong authentication for privileged sessions aligned to your access control implementation approach.
• Control elevation (temporary elevation or controlled admin tools) rather than permanent local admin.

If you use a Privileged Access Management (PAM) tool, document:

• onboarding process for systems
• checkout/approval workflow
• session recording/logging configuration
• break-glass process and how it is reviewed

Deliverable: a “Privileged Access Architecture” diagram and control narrative in the SSP mapping 03.01.06 to systems and owners. ¹

5) Monitor and review privileged activity as an operational control

1. Log privileged authentication events and role changes.
2. Log privileged actions where platforms support it (admin console audit logs, command logging, config changes).
3. Define review triggers:
   • New privileged account created
   • Privileged group membership changes
   • Break-glass account used
   • Privilege granted outside normal workflow
4. Perform recurring access reviews of privileged accounts and privileged group memberships, and document outcomes:
   • confirmed needed
   • removed
   • adjusted scope
   • escalated as an incident if anomalous

Deliverable: “Privileged Access Review” procedure and completed review records. ¹

6) Tie the control to SSP/POA&M so it is assessable

• SSP: map 03.01.06 to the exact systems, roles, and tools that enforce privileged restriction; name control owners. ¹
• POA&M: track gaps (for example, legacy shared admin accounts, missing audit logs) with target dates and closure validation steps. ¹

If you run Daydream for GRC execution, this is where it earns its keep: one requirement mapped to system components, owners, recurring evidence tasks, and POA&M remediation so you can show continuous operation instead of a one-time policy artifact. ¹

Required evidence and artifacts to retain

Keep evidence that proves design and ongoing operation:

Core documents

• SSP control statement for 03.01.06, with in-scope system list and responsible owners. ¹
• Privileged Access Policy / Standard defining privileged accounts, approvals, and restrictions.
• Privileged Account Register (current export + normalized register).
• Privileged access request/approval workflow (tickets, IAM approvals, change records).
• Break-glass procedure and post-use review template.
• POA&M items for gaps, with closure validation notes. ¹

Operational proof

• Privileged group membership change logs or audit trails.
• Admin console audit logs (cloud/SaaS), OS logs, and network device config change logs, as applicable.
• Completed privileged access reviews with evidence of removal/adjustment actions.

Common exam/audit questions and hangups

Expect these questions, and prepare screenshots/exports:

• “Show me all privileged accounts for the CUI boundary systems, and who approved each.”
• “Do administrators have separate accounts for admin work?”
• “How do you prevent or detect shared admin use?”
• “How do you control third-party administrator access?”
• “Show your last privileged access review and the removals you executed.”
• “Where is this described in the SSP, and what POA&M items remain open?” ¹

Hangup to preempt: teams often show a policy and an org chart, but cannot produce a complete privileged account list by system.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Treating “admin” as a job title	Privilege exists per system and role; assessors test system reality	Define privileged roles per platform and export actual memberships
Shared admin accounts with no accountability	Breaks attribution and weakens monitoring	Assign accountable owner, restrict use, migrate to named admin identities where possible
Standing local admin on endpoints	Expands attack surface and lateral movement paths	Remove by default; use controlled elevation and approved exceptions
Third-party admin access not governed	Third party becomes an unmanaged privileged path	Put third parties through the same approval, logging, and review process
SSP says “least privilege” without system mapping	Reads as generic and non-testable	Map 03.01.06 to named systems, tools, and owners; attach evidence tasks

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should plan around assessment and contract risk rather than case-law examples. The practical risk remains clear: privileged misuse enables broad unauthorized changes and access within the CUI boundary, and weak evidence (missing inventories, missing reviews, vague SSP language) creates assessment failure risk. ¹

Practical execution plan (30/60/90-day)

Use phases rather than fixed day counts if your environment is complex; the outcomes below are what matter.

First 30 days (baseline and visibility)

• Name the control owner for privileged access in the CUI boundary.
• Publish “Privileged Access Definition & Scope.”
• Export privileged account/group/role lists for top systems (identity provider, endpoint management, cloud/SaaS admin).
• Stand up the Privileged Account Register and reconcile owners and justifications.
• Update SSP language to map 03.01.06 to systems and owners; open POA&M items for any gaps you discover. ¹

By 60 days (technical restrictions and workflow)

• Implement separate admin accounts for administrators (or document exceptions with compensating controls).
• Require approvals for privileged group membership changes via ticketing/IAM workflow.
• Restrict privileged access paths (jump host/conditional access) for the highest-risk admin consoles.
• Turn on and retain admin audit logs for key platforms; document log sources and retention approach.

By 90 days (recurrence and proof)

• Run your first formal privileged access review cycle; capture evidence and remediation actions.
• Test break-glass process and complete post-use review documentation (even if only as a tabletop).
• Validate POA&M closures with screenshots/exports showing changes are real.
• Schedule recurring evidence collection in Daydream (or your GRC system): register refresh, access review completion, and log spot checks tied to 03.01.06. ¹

Frequently Asked Questions

What counts as a “privileged account” for 03.01.06?

Any account or role that can administer systems, change security settings, manage identities, or bypass normal access controls in the CUI boundary. Define it per platform and prove it with exports of role/group membership. ¹

Do we need separate admin accounts for every administrator?

Separation is the cleanest way to show least privilege in day-to-day work and reduces exposure from email/web activity. If you can’t do it everywhere, document exceptions, restrict access paths, and increase monitoring for those identities. ¹

Are shared “Administrator” accounts automatically noncompliant?

The requirement pushes you toward explicit authorization and accountability. If a shared account remains (legacy devices, emergency access), treat it as break-glass: restrict where it can be used, log all use, and conduct post-use reviews with documented approvals. ¹

How should we handle third-party privileged access (MSP or cloud consultant)?

Put third-party admins into your privileged account register, require the same approvals, restrict access paths, and include them in periodic reviews. Contract terms help, but assessors will still look for technical controls and logs. ¹

What evidence is most persuasive to an assessor?

A current privileged account register tied to system exports, tickets showing approval for privileged role assignment, and completed access review records showing removals. SSP mapping and POA&M closure validation make the package assessable. ¹

Can Daydream help without becoming another documentation project?

Yes if you use it to bind 03.01.06 to owners, systems, recurring evidence tasks, and POA&M workflows so evidence collection happens on a schedule and stays audit-ready. The value is continuity of proof, not prettier policies. ¹

Footnotes

1. NIST SP 800-171 Rev. 3