03.01.07: Least Privilege – Privileged Functions

To meet the 03.01.07: least privilege – privileged functions requirement, you must restrict each privileged function (admin actions like changing access, security settings, or system configurations) so only authorized roles can perform it, only on approved systems, and only when needed. Operationalize it by defining privileged functions, mapping them to roles, enforcing them with technical controls, and proving it with logs and reviews. ¹

Key takeaways:

• Inventory privileged functions, then bind each function to specific roles, systems, and approval paths.
• Enforce least privilege with role-based access control (RBAC), privileged access management (PAM), and change control.
• Keep assessor-ready evidence: role mappings, access approvals, privileged activity logs, and periodic access reviews.

03.01.07 sits in the access control family of NIST SP 800-171 Rev. 3 and targets a predictable failure mode: too many people can do admin-level actions, across too many systems, with too little oversight. “Privileged” here is broader than “domain admin.” It includes any function that can change security posture, override controls, expose Controlled Unclassified Information (CUI), or materially alter system behavior.

A Compliance Officer or GRC lead can operationalize 03.01.07 by treating it as a privileged function governance requirement: define what counts as privileged in your environment, identify where those functions exist, and implement hard controls so privileged actions require the right role, the right system boundary, and the right workflow. Then, retain evidence that the controls are implemented and operating, not just documented.

Your fastest path to compliance is to produce an assessor-friendly chain: privileged function catalog → role/entitlement model → technical enforcement → monitoring → review cadence → remediation tracking. This page gives you that chain in executable steps and lists exactly what artifacts you should be able to hand over during an assessment. ¹

Regulatory text

Requirement: “NIST SP 800-171 Rev. 3 requirement 03.01.07 (Least Privilege – Privileged Functions).” ¹

Operator meaning: You must ensure privileged functions are limited by least privilege. In practice, that means:

• You explicitly define which actions are “privileged functions” in your systems handling CUI.
• Only approved roles (not general users, not shared accounts) can perform those actions.
• Privileged access is constrained (scope, duration, and system boundary) and is auditable.
• You can prove it with current configuration evidence, access records, and privileged activity logs. ¹

Plain-English interpretation (what 03.01.07 expects)

If an action can change security posture or materially affect confidentiality/integrity/availability of CUI systems, treat it as a privileged function and lock it down. Examples commonly include:

• Creating/modifying/deleting user accounts and role memberships
• Changing authentication policies, MFA settings, password policy, conditional access
• Modifying firewall rules, routing, VPN access, security group rules
• Changing logging/auditing configuration, deleting logs, disabling EDR/AV agents
• Installing software/agents, modifying system configurations, patching and update approvals
• Database admin actions (schema changes, export permissions, backup/restore access)
• Cloud IAM policy changes, key management actions, storage bucket policy changes

Assessors typically look for two things: (1) your definition and mapping is complete enough to be credible, and (2) controls prevent “quiet admin” pathways (standing admin rights, shared admin accounts, unlogged actions). ¹

Who it applies to (entity and operational context)

Applies to:

• Any nonfederal organization handling CUI under federal contract requirements where NIST SP 800-171 Rev. 3 is the governing baseline, including defense contractors and other federal contractors. ¹

Operational scope (where auditors will dig):

• Identity providers (Entra ID/Azure AD, Okta, AD DS)
• Endpoint management (Intune, SCCM, JAMF)
• Server and virtualization stacks (Windows/Linux, VMware/Hyper-V)
• Cloud control planes (AWS, Azure, GCP IAM and policy layers)
• Network/security tooling (firewalls, SIEM, EDR, email security)
• CUI repositories (SharePoint, file servers, PLM systems, ticketing systems containing CUI)
• Third-party admin paths (MSPs, SaaS admins, remote support tools)

If third parties administer your environment, 03.01.07 still lands on you. You must contractually and technically constrain what they can do, and you must be able to produce logs and approvals for their privileged actions.

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

Use this as an implementation runbook.

Step 1: Define “privileged function” for your environment

1. Write a short privileged function definition for CUI systems (one paragraph).
2. Create a privileged function list by platform (IAM, endpoints, servers, cloud, network, apps).
3. Tag each function with: system(s) in scope, risk impact, and control owner.

Output: “Privileged Functions Catalog” (spreadsheet or GRC record) tied to in-scope systems in your SSP. ¹

Step 2: Map privileged functions to roles (not people)

1. For each privileged function, define the minimum role that can perform it.
2. Document separation-of-duties constraints where needed (example: requester cannot be approver for access grants).
3. Prohibit privileged access via standard user accounts; require separate admin roles or controlled elevation.

Decision check: If you cannot explain why a role needs a function, remove it or move it to “just-in-time” elevation.

Output: Role-to-function matrix (RBAC model) that shows least-privilege intent and scope.

Step 3: Implement technical enforcement (prevent drift)

Pick enforcement patterns that match your stack:

• RBAC + groups: Privileged functions only via admin groups; groups are controlled by approvals.
• Privileged Access Management (PAM): Broker admin sessions; vault credentials; record sessions where feasible.
• Just-in-time (JIT) elevation: Time-bound privileged role activation with approval and MFA.
• Policy-as-code / guardrails (cloud): Restrict who can attach policies, create keys, or change logging.
• Hard blocks: Disable shared admin accounts; block legacy auth; require MFA for privileged roles.

Minimum technical bar: privileged roles exist, are scoped, and changes are logged. Your implementation must be more than a policy statement. ¹

Step 4: Put privileged functions behind change control (where applicable)

For privileged changes that affect configuration or security posture:

1. Require tickets/changes for firewall rules, IAM policy changes, logging changes, endpoint security changes.
2. Define standard change categories (standard/normal/emergency) with approvals.
3. Require evidence of testing/validation for high-impact changes.

Output: Change records that connect the privileged action to a business need, an approver, and an implementation record.

Step 5: Monitor privileged activity and prove it happened as intended

1. Centralize privileged activity logs (identity logs, admin audit logs, OS logs, cloud audit logs).
2. Alert on high-risk events (new admin creation, policy changes, logging disabled, key creation).
3. Review privileged activity on a defined cadence; document findings and remediation.

Output: Privileged activity review reports, alert rules, and sample log exports showing real events.

Step 6: Review access and close gaps through POA&M governance

1. Perform periodic access reviews for privileged roles and systems in scope.
2. Remove stale access quickly; record revocations.
3. Track gaps in a POA&M with target dates, risk ratings, and closure validation. ¹

Practical tip: Daydream (or your GRC system) is most useful here when it ties 03.01.07 to specific systems, owners, and recurring evidence pulls, then keeps the POA&M honest with closure criteria and re-test records. ¹

Required evidence and artifacts to retain (assessor-ready)

Keep evidence tied to CUI scope and dated.

Evidence item	What it proves	Good enough for assessment
Privileged Functions Catalog	You defined privileged functions and scope	Mapped by system; owned; current
RBAC / role-to-function matrix	Least privilege design	Roles mapped to functions; rationale where non-obvious
Access request/approval records	Only authorized users gain privileged access	Tickets/workflow approvals with approver identity
Privileged role membership export	Current state of privileged access	Snapshot from IAM directory/cloud IAM
PAM/JIT configuration screenshots or exports	Technical enforcement	Policies show time-bound access and approvals
Audit log samples (identity, cloud, OS)	Privileged actions are logged	Demonstrates admin changes are captured
Privileged activity review records	Ongoing oversight	Findings + actions taken
Access review results and removals	Least privilege is maintained	Evidence of revocation and follow-up
POA&M items for gaps	Governance and remediation	Target dates and closure validation 1

Common exam/audit questions and hangups

Expect these lines of questioning:

1. “Define privileged functions for this environment.” If you can’t list them by system, you’ll look policy-only.
2. “Show me who can change IAM policies / disable logging.” Assessors test the highest-impact functions first.
3. “Are there shared admin accounts?” Shared admin credentials are a frequent hangup because attribution and least privilege break down.
4. “How do you grant and revoke privileged access?” They want workflow evidence, not verbal process.
5. “Prove privileged actions are monitored.” Bring logs that show admin activity events, plus your review notes.
6. “How do you control third-party admin access?” Show contract terms, scoped accounts, JIT/PAM controls, and logs for third-party sessions.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Treating “privileged” as only a few IT admins. Fix: catalog privileged functions across cloud, SaaS, CI/CD, and security tools.
• Mistake: Standing admin access for convenience. Fix: use JIT elevation with approvals for sensitive roles; keep standing access limited and justified.
• Mistake: Relying on policy without technical enforcement. Fix: demonstrate RBAC group controls, conditional access, PAM, and audit logging configurations. ¹
• Mistake: Logging exists but isn’t reviewed. Fix: record periodic reviews and outcomes; create tickets for anomalies.
• Mistake: Third parties have broad admin. Fix: scope access per system, require named accounts, time-bound access, and session/audit logs.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite specific actions or outcomes.

Operationally, weak control of privileged functions is a common root cause of severe incidents: privilege misuse can disable monitoring, create backdoors, exfiltrate CUI, or alter records. For CUI environments, that translates into contract risk, assessment failure risk, and incident response complexity because you cannot reliably attribute actions without strong privileged access controls and logging. ¹

A practical execution plan (30/60/90)

Use these phases as an operator checklist. Adjust to your environment size and assessment timeline.

First 30 days (stabilize and define)

• Confirm CUI system scope in the SSP and name control owners for identity, endpoints, servers, cloud, network. ¹
• Build the Privileged Functions Catalog for in-scope systems.
• Export current privileged group/role membership and identify obvious over-provisioning.
• Set a temporary gate: no new privileged grants without an approved ticket and named approver.

By 60 days (implement enforcement and evidence loops)

• Implement or tighten RBAC groups for privileged functions across major platforms.
• Turn on or verify audit logging for privileged actions (identity + cloud + key systems).
• Establish privileged access request workflow (request, approval, time bounds, revocation).
• Run your first privileged access review and document removals and exceptions.

By 90 days (operate like an assessed program)

• Add JIT elevation and/or PAM controls for the highest-risk privileged functions.
• Implement alerting for high-risk privileged events and document response steps.
• Link 03.01.07 to SSP narratives, system components, and recurring evidence collection. ¹
• Track remaining gaps in POA&M with closure criteria and re-test evidence before marking complete. ¹

Frequently Asked Questions

What counts as a “privileged function” under 03.01.07 in a cloud-heavy environment?

Any action that can change access control, disable security controls, alter logging, or materially affect CUI system security qualifies. Start with IAM policy changes, key management, logging configuration, and administrative access to CUI storage/services. ¹

Do I need a PAM tool to meet the 03.01.07: least privilege – privileged functions requirement?

NIST SP 800-171 Rev. 3 doesn’t mandate a specific product, but you must show technical restriction and accountability for privileged functions. If you can’t achieve time-bound access, strong approvals, and reliable logging with native controls, PAM/JIT often becomes the practical path. ¹

How do I prove least privilege for privileged functions to an assessor?

Bring a role-to-function matrix, current privileged role membership exports, access request/approval records, and privileged activity logs that show real admin events. Pair that with periodic access review evidence and documented removals. ¹

Can a third party (MSP or SaaS admin) hold privileged access in my CUI environment?

Yes, but you must scope and control it: named accounts, least-privilege roles, time-bound access where feasible, and auditable logs. Keep contract language and operational evidence aligned to your SSP scope. ¹

What’s the fastest way to find “hidden admins”?

Start with identity provider privileged role reports, cloud IAM admin policies, local admin group membership on endpoints/servers, and application admin consoles for CUI repositories. Reconcile findings against your approved RBAC model and open POA&M items for anything you can’t justify. ¹

How should Daydream fit into operationalizing 03.01.07?

Use Daydream to map 03.01.07 to SSP control statements, system components, and accountable owners, then set recurring evidence tasks (access reviews, log reviews, approvals) and track gaps to closure in POA&M with validation artifacts. ¹

Footnotes

1. NIST SP 800-171 Rev. 3