03.05.12: Authenticator Management

To meet the 03.05.12: authenticator management requirement, you must control the full lifecycle of authenticators (passwords, keys, tokens, certificates): issuance, storage, use, rotation, revocation, and recovery, with repeatable evidence. Operationalize it by standardizing authenticator types, hardening how they’re stored and transmitted, and proving ongoing administration across all systems handling CUI. ¹

Key takeaways:

• Define and enforce approved authenticator types per system and user population, then restrict everything else.
• Implement lifecycle controls (issue, rotate, revoke, recover) with logging and role-based administration.
• Maintain audit-ready evidence: standards, configurations, inventories, logs, and access reviews mapped to 03.05.12.

Authenticator failures are one of the fastest paths from “compliant on paper” to real exposure: credential reuse, unmanaged API keys, stale service account passwords, orphaned certificates, and shared break-glass accounts. The 03.05.12: authenticator management requirement in NIST SP 800-171 Rev. 3 expects you to treat authenticators as controlled security assets, not incidental IT debris. ¹

For a Compliance Officer, CCO, or GRC lead, the operational goal is simple: you need a clear authenticator policy that engineering and IT can implement, plus proof that it runs continuously. That means you can answer, quickly and consistently: Which authenticators are allowed? Where are they stored? Who can mint or reset them? How do you revoke them when people leave or systems change? What evidence shows this is happening for the systems that process, store, or transmit CUI? ¹

This page gives requirement-level implementation guidance you can hand to IAM, IT, and platform teams, and then use to drive an assessment-ready control narrative and evidence pack for 03.05.12.

Regulatory text

Requirement: “NIST SP 800-171 Rev. 3 requirement 03.05.12 (Authenticator Management).” ¹

Operator interpretation (what the assessor expects): You manage authenticators across their lifecycle so they are issued securely, protected at rest and in transit, changed/rotated appropriately, revoked promptly, and recoverable through controlled processes. You can demonstrate this management through documented standards, system configurations, and repeatable evidence tied to systems handling CUI. ¹

Plain-English interpretation of the requirement

“Authenticator management” means you treat passwords, MFA secrets, cryptographic keys, API tokens, SSH keys, and certificates as governed items with owners and rules. You:

• Standardize which authenticators are allowed for which access paths (workforce login, admins, service-to-service, remote access).
• Protect them against disclosure (no plaintext storage, no hardcoding in source, protected secret stores).
• Control admin actions (who can reset, mint, or bypass).
• Maintain hygiene (rotation/replacement, revocation, and cleanup).
• Prove it with artifacts an assessor can test. ¹

Who it applies to (entity and operational context)

Entities: Federal contractors and other nonfederal organizations that handle Controlled Unclassified Information (CUI) in nonfederal systems, where NIST SP 800-171 Rev. 3 is contractually flowed down or otherwise required. ¹

Operational scope (what to include):

• Human access: SSO/IAM, Windows/macOS/Linux logins, privileged access, VPN/remote access, SaaS admin consoles used for CUI.
• Non-human access: service accounts, CI/CD credentials, API keys, database passwords, managed identities, certificate-based auth, SSH keys.
• Third parties: MSPs, engineers, and other third parties with admin or support access into CUI environments. Treat their authenticators as in scope when they can reach CUI systems. ¹

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

Use this as an execution checklist. Assign an owner for each step (IAM, IT, SecOps, Platform, App Owners) and track completion per CUI boundary.

Step 1: Define your authenticator inventory model (human + non-human)

1. Define authenticator categories you will govern: passwords, MFA factors, API tokens, SSH keys, certificates, and private keys.
2. Decide what “system of record” is for each category (IdP for workforce identities, PAM for privileged creds, secrets manager for app secrets, PKI/cert manager for certs).
3. Produce an initial inventory for in-scope systems: where authenticators exist, who owns them, and how they’re issued. ¹

Practical tip: Don’t try to inventory “the enterprise.” Start with the CUI enclave/boundary and expand outward only where trust relationships exist.

Step 2: Publish authenticator standards (what’s allowed, how it’s handled)

Write a short standard that engineering can follow, covering:

• Approved authenticator types by use case (workforce, admin, service accounts, APIs).
• Storage requirements (approved secret stores; no plaintext; no code repos).
• Transmission requirements (no secrets over email/chat; use approved channels).
• Minimum administrative controls (RBAC for reset/mint/bypass; ticketing for changes). ¹

Map each statement to where it will be enforced (IdP config, PAM policy, secrets manager guardrails, CI checks, code scanning rules, configuration baselines).

Step 3: Lock down issuance and reset processes

Implement and document:

• Identity proofing / requester validation for resets (help desk scripts, admin runbooks).
• Separation of duties for privileged authenticator issuance when feasible (request/approve/provision).
• Break-glass issuance rules (who can create, how to store, how to access, how to review after use). ¹

Evidence focus: show the workflow and show it happened (tickets, approvals, logs).

Step 4: Protect authenticators at rest and in transit

Your technical teams should:

• Store secrets in approved managed stores (enterprise password manager, PAM vault, cloud secrets manager).
• Prevent long-lived secrets from being exposed in logs, monitoring tools, build output, or chatops.
• Enforce encryption and access controls on secret repositories (RBAC, least privilege, audit logging). ¹

What auditors test: whether secrets are hardcoded, shared broadly, or retrievable without control.

Step 5: Implement lifecycle hygiene (rotation, revocation, replacement)

Define triggers and actions:

• Personnel events: terminate access and revoke authenticators for offboarding; handle role changes.
• Compromise/suspicion: revoke and reissue; invalidate sessions/tokens where applicable.
• System changes: rotate service credentials during migrations, vendor changes, and incident response.
• Cryptographic lifecycle: certificate issuance, renewal, and revocation with ownership and monitoring. ¹

You don’t need one rotation rule for everything. You do need a rule that is intentional, documented, and followed, with evidence.

Step 6: Centralize logging and review of authenticator administration

At minimum, capture logs for:

• Credential resets
• MFA enrollments and resets
• Privileged credential check-out/check-in (if PAM)
• API key creation and deletion
• Certificate issuance and revocation actions ¹

Then operationalize review:

• Define who reviews which logs and what constitutes an escalation.
• Document exceptions and remediation (tickets, incident records).

Step 7: Prove it continuously (recurring evidence collection)

Build an evidence calendar that collects:

• Samples of reset tickets with approvals
• Access reviews for privileged authenticator administrators
• Vault/secrets manager access logs
• Configuration exports from IdP/PAM showing policies in force
• Inventory deltas (new secrets created, old ones removed) ¹

Where Daydream fits (earned, not forced): Daydream can act as the system to map 03.05.12 to your policy, control statements, and a recurring evidence checklist so you don’t rebuild the same evidence pack every assessment cycle. ¹

Required evidence and artifacts to retain

Keep artifacts tied to the CUI scope boundary and label them with owners and dates.

Policy and standards

• Authenticator Management Standard (covers types, storage, issuance, reset, revocation)
• Access control / IAM policy references that govern authenticators ¹

Technical configurations (export or screenshots with timestamps)

• IdP settings: MFA enrollment, reset controls, admin roles
• PAM settings: vault policies, approvals, session recording (if applicable)
• Secrets manager policies: RBAC, audit logging, encryption settings
• Certificate management settings: issuance and revocation controls ¹

Operational records

• Authenticator inventory for in-scope systems (human and non-human)
• Samples of password/MFA reset tickets and approvals
• Offboarding records showing revocation actions
• Break-glass access logs and post-use review records
• Log review evidence and incident/ticket follow-up ¹

Common exam/audit questions and hangups

Expect these, and prepare the artifacts above:

1. “Show me where authenticators are stored for this application.” If the answer is “in env vars on a server” or “in a spreadsheet,” you will struggle.
2. “Who can reset MFA or issue new tokens?” Auditors look for tightly controlled admin roles and evidence of review.
3. “How do you handle service account credentials and API keys?” Many programs only cover workforce SSO and ignore non-human access.
4. “What happens to authenticators when someone leaves?” They will test HR-driven offboarding plus system-specific revocation.
5. “Prove this is operating.” A policy without tickets, logs, or configuration exports reads as non-operational. ¹

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	How to avoid it
Treating authenticator management as “password policy only”	Leaves API keys, SSH keys, certs, and service accounts unmanaged	Expand scope to human + non-human authenticators; inventory by CUI system
No system of record for secrets	Secrets sprawl across repos, wikis, and shared drives	Mandate approved vault(s) and block alternatives through scanning and reviews
Break-glass accounts exist but aren’t governed	Shared credentials become a quiet backdoor	Put break-glass in PAM/password manager with logging and post-use review
Reset process is informal	Help desk actions can be abused	Use documented verification steps, ticketing, and restricted admin roles
Evidence is ad hoc	You can’t prove operation over time	Set a recurring evidence checklist and retain time-stamped exports/log samples 1

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. Practically, the risk is straightforward: unmanaged authenticators increase the likelihood of unauthorized access to CUI systems through credential theft, shared secrets, and orphaned access paths. For contractors, failure to implement and evidence controls against NIST SP 800-171 requirements can create contractual and assessment risk tied to CUI protection obligations. ¹

A practical execution plan (30/60/90-day)

These are phases, not promises of elapsed time. Use them as sequencing.

First 30 days (Immediate stabilization)

• Define CUI boundary and list in-scope systems and admins. ¹
• Publish a draft Authenticator Management Standard covering human and non-human authenticators. ¹
• Pick systems of record: IdP, PAM/password vault, secrets manager, certificate manager. ¹
• Start an initial authenticator inventory for the top-risk systems (admin access, CI/CD, production apps). ¹

Next 60 days (Control implementation + initial evidence)

• Implement enforcement: restrict who can reset MFA, issue tokens, and administer vaults. ¹
• Migrate high-risk secrets out of code repos and shared documents into approved secret storage. ¹
• Establish break-glass controls with logging and post-use review. ¹
• Stand up evidence collection: configuration exports, sample tickets, and log collection for auth admin actions. ¹

Next 90 days (Operational maturity)

• Expand inventory coverage to remaining in-scope systems and third-party access paths. ¹
• Formalize lifecycle actions: revocation and replacement triggers tied to HR offboarding and incident response. ¹
• Run the first internal “mini-assessment” of 03.05.12 with sampled systems and produce a corrective action list. ¹
• If you use Daydream, map 03.05.12 to control owners and automate recurring evidence requests so each cycle produces the same artifacts. ¹

Frequently Asked Questions

Does 03.05.12 only apply to employee passwords?

No. Treat API keys, service account credentials, SSH keys, tokens, and certificates as authenticators in scope when they provide access to systems handling CUI. ¹

What’s the minimum evidence an assessor will accept for authenticator management?

A written standard plus proof of operation: system configurations (IdP/vault/secrets manager), tickets or workflows for issuance/resets, and logs or reports showing revocation and administrative actions. ¹

We use a third party MSP. Are their credentials part of our compliance obligation?

If the third party can access your CUI systems, their access path and authenticators are in scope for your control design and monitoring expectations. Document the access method and how you govern issuance, reset, and revocation. ¹

How do we handle break-glass accounts without failing the requirement?

Keep break-glass credentials in a controlled vault, restrict who can access them, log every checkout/use, and require a post-use review with documented justification and follow-up actions. ¹

Are rotation schedules mandatory?

NIST SP 800-171 Rev. 3 calls for authenticator management, which includes lifecycle hygiene. Define rotation and replacement rules that fit each authenticator type, and retain evidence that the rules are followed. ¹

What’s the fastest way to get assessment-ready for 03.05.12?

Start with a CUI-scoped authenticator inventory, pick a system of record for each authenticator type, and collect a repeatable evidence set (configs, logs, tickets). Tools like Daydream help keep the mapping and evidence collection consistent across cycles. ¹

Footnotes

1. NIST SP 800-171 Rev. 3