03.13.08: for authenticators stored in organizational

To meet the 03.13.08: for authenticators stored in organizational requirement, you must protect any stored authenticators (for example, password hashes, private keys, API tokens, and secrets) with strong cryptography, strict access control, and controlled lifecycle processes so they cannot be recovered or misused if systems or backups are exposed. Build an “authenticator inventory → secure storage standard → evidence” workflow and run it continuously.

Key takeaways:

• Treat stored authenticators as high-impact assets; manage them like cryptographic material, not “just config.”
• Standardize where authenticators may be stored (approved vaults, HSM/KMS-backed services) and prohibit everything else (repos, endpoints, spreadsheets).
• Evidence wins assessments: inventory, storage configs, access logs, rotation records, and exception approvals.

The phrase “authenticators stored in organizational …” is short, but the operational scope is wide. In practice, this requirement is about preventing attacker reuse of your organization’s stored credentials and secrets if a database, server, backup, or code repository is compromised. Assessors will look for two things: (1) you have a clear technical standard for how authenticators are stored and protected, and (2) you can prove it is consistently followed across the systems that handle Controlled Unclassified Information (CUI) and the supporting identity and access stack.

This requirement typically fails for mundane reasons: service account passwords hardcoded in scripts, API keys in CI/CD variables without governance, private keys sitting on shared file shares, or “temporary” exceptions that never expire. A CCO or GRC lead can operationalize 03.13.08 quickly by forcing clarity on four decisions: what counts as an authenticator, where they are allowed to live, how they are protected at rest and in backup/replication, and what evidence you will show an assessor.

This page gives requirement-level implementation guidance mapped to NIST SP 800-171 Rev. 3 and written for teams supporting federal contracting and other nonfederal environments handling CUI. ¹

Regulatory text

Requirement: “NIST SP 800-171 Rev. 3 requirement 03.13.08 (for authenticators stored in organizational).” ¹

Operator interpretation (what you must do)

You must ensure that authenticators your organization stores are protected so they cannot be feasibly extracted, reversed, or reused by an unauthorized party. Practically, that means:

• Approved storage locations (central secret stores or identity systems designed for credential protection).
• Cryptographic protection appropriate to the authenticator type (password hashing for passwords; encryption and key management for secrets/keys/tokens).
• Tight access control and monitoring around the systems where authenticators reside.
• Lifecycle controls (issuance, rotation, revocation, backup handling, and secure disposal) so stale secrets do not linger.

This requirement is assessed in the real world by looking at your directory services, SSO/IAM, secret vaults, application config patterns, endpoint management, CI/CD pipelines, and backup platforms.

Plain-English interpretation of the requirement

If your systems store “things that prove identity,” you have to store them in a way that prevents theft and reuse.

“Authenticator” should be treated broadly in your control language. Include, at minimum:

• User password representations (for example, hashes in IAM or application databases)
• API tokens and bearer tokens
• OAuth client secrets
• Service account credentials
• SSH private keys
• TLS private keys and certificate keystores
• Database passwords embedded in apps
• Cloud access keys
• Recovery codes or reset tokens (where stored)

A useful rule for scoping: if an attacker steals it and can sign in as someone (person or service), treat it as an authenticator.

Who it applies to (entity and operational context)

Applies to:

• Nonfederal organizations that process, store, or transmit CUI for federal programs or downstream supply chains aligned to NIST SP 800-171 Rev. 3. ¹
• Internal teams operating: IAM/SSO, directory services, endpoint management, DevOps/CI/CD, application engineering, database administration, cloud operations, security operations, and backup/DR.

Operational contexts to include in scope:

• Production and non-production environments that can access CUI or connect to CUI systems
• Centralized logging and monitoring platforms (they often ingest secrets accidentally)
• Backups, snapshots, replicas, and DR sites (secrets propagate there)
• Third parties that host or process your authenticators (IdP, managed databases, CI/CD providers). Treat them as third-party risk items with contractual and control verification.

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

Step 1: Define “authenticator” and write the storage standard

Create a one-page standard that answers:

• What types of authenticators exist in your environment (user, service, machine, app)?
• Which systems are approved to store them (for example, IdP, PAM, secrets vault, HSM/KMS-backed secret manager)?
• Which storage patterns are prohibited (source code, shared drives, ticket attachments, spreadsheets, endpoint local files, chat tools).
• Minimum protection requirements by type:
  • Passwords: salted one-way hashing (your app teams should never store plaintext).
  • Keys/tokens/secrets: encryption at rest plus strong key management, access control, and rotation.

Keep it testable. Your standard should let an auditor pick a random app and determine “pass/fail” quickly.

Step 2: Build an authenticator inventory (systems + secret types)

You need two inventories:

1. Authoritative stores (where authenticators are supposed to be): IdP, vault, PAM, key management system, certificate management platform.
2. Likely leak surfaces (where authenticators often end up): code repos, CI/CD variables, endpoint files, container images, backups, database tables, wikis.

Make owners explicit (system owner + control owner). Tie each system to whether it is in the CUI boundary or supports it.

Step 3: Standardize secure storage technical patterns

Pick a small set of sanctioned patterns and force adoption:

• Applications retrieve secrets at runtime from an approved secret manager; no hardcoding.
• CI/CD pulls secrets from a vault with scoped, short-lived access; prevent secrets from being printed to logs.
• Certificates and private keys live in managed key stores; restrict export where feasible.
• Databases do not store user passwords except as strong hashes; admin/service passwords are vaulted and rotated.

Document the approved patterns as reference architectures and short engineering checklists.

Step 4: Lock down access to authenticator stores

Assessors will ask who can read secrets and how you know. Implement:

• Least privilege RBAC for secret retrieval and administration
• Separate admin roles from read roles
• Break-glass access with approval and logging
• Central logging of secret access events and administrative changes
• Periodic access reviews focused on “who can extract authenticators”

Step 5: Manage authenticator lifecycle (issue, rotate, revoke, dispose)

Operationalize:

• New secret request workflow (ticket or automated request with owner, system, purpose)
• Rotation triggers (scheduled rotations plus event-based rotations after incidents or role changes)
• Revocation process (terminate compromised tokens, rotate keys, disable accounts)
• Secure disposal (remove from old configs, decommissioned systems, and historical backups where feasible; document compensating controls when deletion is impractical)

Step 6: Validate continuously (detection + sampling)

You need a detection layer because policy alone fails.

• Scan repos and build artifacts for secrets.
• Scan endpoint and server configs for prohibited secret storage.
• Sample critical apps quarterly (or at a cadence you can sustain) and prove their secrets come from approved stores.
• Review backup configurations to confirm encryption and restricted restore access for systems containing authenticators.

Step 7: Make it assessable (map control → evidence)

Create a control narrative that ties:

• Policy/standard
• Technical implementation (vault, KMS, IAM)
• Operational procedures (rotation, access review)
• Monitoring and exceptions

Daydream fits naturally here as the system of record to map 03.13.08 to your policy language, track control owners, and schedule recurring evidence pulls so you are not rebuilding proof during an assessment.

Required evidence and artifacts to retain

Keep evidence that proves both design and operation:

Governance artifacts

• Authenticator Storage Standard (approved, versioned)
• Data flow / boundary notes showing where authenticators are stored for CUI-supporting systems
• Exception register for prohibited storage patterns (with expiration and compensating controls)

Technical evidence (screenshots, exports, configs)

• Secret manager/vault configuration showing encryption at rest and access control model
• IAM role/policy exports for secret read/admin permissions
• Password storage design notes for in-house apps (hashing approach, no plaintext)
• Certificate/private key storage configs (keystore location, export restrictions, access logs)

Operational evidence

• Rotation logs or change tickets showing secret/key rotations occurred
• Access review records for secret store permissions
• SIEM/log samples showing secret access events and administrative actions
• Repo/CI/CD scanning results and remediation tickets for findings

Third-party evidence (where applicable)

• Contract clauses requiring secure storage and access control for authenticators
• Due diligence responses for the third party systems that store or manage secrets
• SOC reports or equivalent assurance artifacts you can lawfully retain and reference (where obtained)

Common exam/audit questions and hangups

Expect these lines of inquiry:

• “Show me where application X stores its database password. Prove it isn’t in code or a file.”
• “Who can read secrets in the vault? Show current access and approvals.”
• “How do you store user passwords? Are they ever recoverable by admins?”
• “Do backups contain authenticators? Who can restore backups and access that data?”
• “What happens when an engineer leaves? How do you rotate shared secrets?”
• “How do you detect secrets committed to repositories or exposed in CI logs?”

The hangup is usually consistency: one legacy app or one team’s pipeline breaks the standard.

Frequent implementation mistakes and how to avoid them

• Mistake: Defining “authenticator” too narrowly (user passwords only).
  Fix: Include service and machine credentials, tokens, and keys in the definition and inventory.

• Mistake: Allowing “temporary” plaintext secrets in tickets, chat, or wikis.
  Fix: Prohibit those channels for secret sharing; provide an approved method (vault sharing, time-bound access).

• Mistake: Vault exists, but engineers still hardcode secrets for speed.
  Fix: Add repo scanning and CI guardrails; block merges with detected secrets; provide reference code.

• Mistake: Access reviews ignore secret-read permissions.
  Fix: Make “can extract authenticators” a specific access review scope item.

• Mistake: Backup/DR treated as out-of-scope.
  Fix: Inventory which backups include authenticator stores; restrict restore permissions and log restores.

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 enforcement actions.

Risk-wise, stored authenticator compromise is a common root cause of lateral movement: attackers who obtain tokens, private keys, or service account credentials often bypass perimeter controls and appear as legitimate users or services. For CUI environments, that can translate into unauthorized access to CUI systems and contractual noncompliance findings during assessments. ¹

Practical 30/60/90-day execution plan

First 30 days (stabilize and set the rule)

• Publish the Authenticator Storage Standard and prohibited storage list.
• Stand up the authenticator inventory (authoritative stores + leak surfaces) with named owners.
• Identify your top “authenticator stores” (IdP, vault, certificate store, CI/CD secrets) and confirm logging is enabled.
• Start an exception register to prevent quiet, permanent drift.

Days 31–60 (force adoption in the highest-risk paths)

• Implement repo and CI/CD secret scanning with a remediation workflow.
• Migrate highest-risk application secrets into the approved secret manager.
• Tighten vault permissions: remove broad read access, implement break-glass, and document admin separation.
• Establish a repeatable rotation process for shared/service secrets tied to offboarding and incident response.

Days 61–90 (prove operations and close edge cases)

• Run a targeted access review for “who can read/export authenticators.”
• Sample multiple systems and produce an assessor-ready evidence pack (configs, logs, rotation records).
• Address backups: validate encryption and restrict restore access for systems containing authenticators.
• Operationalize monthly reporting: new secrets issued, secrets rotated, findings from scanning, exceptions opened/closed.

Daydream can help by turning the above into an owned control with recurring evidence tasks, mapped systems, and an audit-ready package aligned to 03.13.08.

Frequently Asked Questions

What counts as an “authenticator” for 03.13.08?

Treat anything that can be presented to gain access as an authenticator: passwords (or their stored representations), API tokens, private keys, certificates’ private key material, and service account credentials. If theft enables impersonation, include it.

Do we fail 03.13.08 if a legacy app stores passwords?

Storing passwords is not automatically a failure, but storing them in plaintext or recoverable form is a major red flag. You need a documented design showing strong one-way hashing for passwords and tight controls around the database and backups.

Are CI/CD environment variables an acceptable place to store secrets?

Sometimes, but only if your standard explicitly approves the pattern and you can prove strong access control, audit logging, and lifecycle management. Many teams use CI/CD variables as a convenience store; assessors will ask how you prevent sprawl and who can read them.

How should we handle secrets in backups and snapshots?

Assume backups contain authenticators if they back up systems that store them. Restrict restore permissions, encrypt backups, and log restores; document how you control and monitor access to restored data.

What evidence is most persuasive to an assessor?

A small set of artifacts that connect policy to reality: an authenticator inventory, vault/IAM access exports, sample application configurations showing runtime secret retrieval, rotation records, and logs proving secret access is monitored.

We use a third party IdP and a managed database. Does 03.13.08 still apply?

Yes. You still must ensure authenticators are protected in those services through configuration, access control, and third-party due diligence. Keep contracts, assurance reports you have obtained, and configuration evidence that demonstrates secure storage and limited access.

Footnotes

1. NIST SP 800-171 Rev. 3