AC-2(6): Dynamic Privilege Management

AC-2(6): dynamic privilege management requirement means you must implement a mechanism to adjust user privileges dynamically based on defined conditions, rather than relying only on static, long-lived access. To operationalize it fast, define the triggers (risk, context, task), enforce automatic privilege changes through your IAM/PAM stack, and retain evidence that changes occurred as designed. ¹

Key takeaways:

• Define “dynamic” in your environment: the triggers, decision logic, and systems in scope (IAM, PAM, cloud, SaaS). ¹
• Implement technical enforcement (not policy-only) that can raise/lower privileges and log the decision trail. ¹
• Build an evidence bundle that proves privilege changes happen, are approved/justified, and are reviewable. ¹

Dynamic privilege management is the operational answer to a common audit failure: access that made sense yesterday is still present today, even though the user’s task, device health, location, or risk posture changed. AC-2(6) sits under Account Management and expects you to move beyond “assign roles and review quarterly” toward conditional and time-bound privilege decisions that can change during a session or across defined events. ¹

For a CCO, Compliance Officer, or GRC lead, the hard part is not the concept. It is scoping it cleanly, getting security engineering to implement enforcement, and collecting evidence that will satisfy an assessor without turning operations into a ticket backlog. You need a tight control design: a short list of triggers, a single source of truth for entitlements, and a repeatable way to show what changed, when, why, and who approved exceptions.

This page gives requirement-level implementation guidance you can hand to IAM/PAM owners and then audit internally. It includes step-by-step execution, artifacts to retain, and the exam questions that typically surface when “dynamic” is interpreted loosely. ¹

What is AC-2(6): dynamic privilege management requirement (plain English)

You must implement a capability that changes privileges based on conditions. Conditions can be time-based (privileges expire), context-based (device posture, network, geo), risk-based (high-risk login), or workflow-based (privilege granted only while a change ticket is active). The key is that privileges are not purely static assignments; they can be adjusted automatically or through controlled, rapid mechanisms as conditions change. ¹

What auditors look for: proof that the mechanism exists, is configured with defined rules, and is operating. “We have MFA” or “we do access reviews” is not a substitute for dynamic privilege changes.

Regulatory text

Excerpt: “Implement {{ insert: param, ac-02.06_odp }}.” ²

Operator interpretation: NIST is telling you to implement your organization-defined parameter for AC-2(6). In practice, that means you must explicitly define what “dynamic privilege management” means in your system (the triggers, systems, roles, and constraints) and then implement it with technical enforcement and logging. Your biggest work product is the organization-defined policy/runtime decision points that your IAM/PAM tools enforce. ¹

Who it applies to (entity and operational context)

Entities: Federal information systems, federal contractors, contractor systems handling federal data, and service organizations supporting those environments. ¹

Operational contexts where AC-2(6) matters most:

• Privileged administration: domain admin, cloud admin, database admin, security admin.
• Production access paths: CI/CD, break-glass accounts, SRE access, data platform access.
• Third-party access: MSPs, integrators, outsourced help desk, incident response retainers.
• High-impact applications: systems handling regulated, sensitive, or mission data.

If you are scoping quickly: start with privileged access and production access. Dynamic privilege management for standard end-user SaaS access can follow once the privileged path is stable.

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

Step 1: Write the control card (single page)

Create a “control card” that includes:

• Objective: privileges change dynamically based on defined conditions.
• Owner: IAM/PAM product owner; secondary owner in GRC for testing.
• Systems in scope: IAM, PAM, cloud IAM (AWS/Azure/GCP), key SaaS admin consoles.
• Trigger events: list them explicitly (see Step 2).
• Execution steps: how privileges are granted, adjusted, revoked.
• Exceptions: who can approve, maximum duration, compensating controls.
  This is the artifact that stops the control from being “policy-only.” ¹

Step 2: Define your “dynamic” triggers and decision logic

Pick a small set of triggers you can enforce and evidence. Common, auditable triggers:

• Time-bound elevation: admin rights granted for a defined window, then removed automatically.
• Ticket-bound elevation: privileges granted only if a change/incident ticket is approved and active.
• Risk-based step-up: elevation requires additional authentication when risk signals appear.
• Posture-based restriction: block or reduce privileges if device posture is noncompliant.

Document each trigger with:

• Inputs (signals, ticket status, group membership, device posture)
• Decision rule (if/then)
• Enforcement point (PAM broker, cloud policy, conditional access, identity governance)
• Logging requirement (what must be captured)

Step 3: Implement technical enforcement in IAM/PAM (not manual tickets)

Your engineering team should implement one or more of these patterns:

• Just-in-Time (JIT) privileged access through a PAM system with automatic expiry and session logging.
• Just-Enough-Access (JEA) via constrained roles, scoped permissions, and task-based profiles.
• Conditional access policies for admin portals (step-up auth, device compliance requirements).
• Automated deprovisioning tied to HR events plus immediate revocation for risk events.

From a compliance standpoint, require:

• A controlled entitlement source (groups/roles as the “truth”)
• Automatic removal/expiry
• Immutable logs (or protected logs) for decisions and actions

Step 4: Build the minimum evidence bundle ¹

Define what “good evidence” means before you test. Minimum bundle:

• Configuration export or screenshots of dynamic rules (dated, with system name)
• Sample event logs showing an elevation granted and later removed (with timestamps and actor)
• Approval evidence when required (ticket, workflow approval, change record)
• Exception register entries (if any) and compensating controls
• Access inventory for privileged roles in scope and who currently has standing access

Store it in a named repository location with retention rules aligned to your audit needs. ¹

Step 5: Operate and test it on a recurring cadence

Run control health checks that answer:

• Are dynamic rules still enabled?
• Are elevations expiring as designed?
• Are there standing privileged accounts that bypass the dynamic path?
• Are logs complete and reviewable?

Track findings to closure with owners and due dates. Auditors respond well to a visible remediation trail. ¹

Required evidence and artifacts to retain (audit-ready)

Use this checklist as your evidence index:

• Control card / runbook for AC-2(6) with scope, triggers, exceptions ¹
• Privilege model: role catalog, privileged group list, entitlement definitions
• Dynamic policy configuration evidence: exports, screenshots, policy-as-code commits
• Workflow evidence: approved tickets/requests tied to elevation events
• PAM session records (where applicable): who elevated, what they did, when access ended
• System logs proving automatic de-elevation occurred
• Exception register with time bounds, approver, justification, compensating controls
• Control test results from periodic checks and remediation tracking ¹

Common exam/audit questions and hangups

“Define dynamic. What conditions cause privilege changes?”

Have the trigger list ready, with examples mapped to systems. If you cannot name triggers, you do not have an implementable control.

“Show me that privileges are actually removed.”

Expect to produce at least one end-to-end trace: request/approval → privilege granted → logs of use → privilege removed automatically.

“What about service accounts and automation?”

Auditors will ask whether non-human identities have standing privileges. Your answer should include how you constrain and rotate secrets, and how you prevent service accounts from becoming a bypass path.

“How do third parties get admin access?”

Have a standard method: third party admins go through the same JIT/JEA path, with session recording and explicit expiration.

Frequent implementation mistakes (and how to avoid them)

1. Calling periodic access reviews “dynamic.” Reviews are important, but AC-2(6) expects condition-based privilege changes. Keep reviews as complementary evidence, not the core mechanism. ¹

2. Too many triggers too soon. Over-scoping creates brittle policies and evidence gaps. Start with time-bound JIT for privileged access, then add risk/posture triggers once logging is stable.

3. No exception discipline. “Temporary admin” that never ends is the classic failure mode. Require expiry, require an approver, and record compensating controls in the exception register.

4. Logs exist but are not reviewable. If logs are scattered across tools with no correlation, you will struggle in an audit. Define where the authoritative logs live and how you retrieve them.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page focuses on audit and assurance expectations rather than case law.

Operationally, weak dynamic privilege management increases blast radius during account compromise and raises the likelihood of unauthorized changes in production. It also creates recurring audit findings because standing privileged access is easy to detect during sampling.

Practical 30/60/90-day execution plan

First 30 days (design and scope)

• Name the AC-2(6) control owner and approver path. ¹
• Scope the first tranche: privileged roles for production systems and cloud control planes.
• Publish the control card with triggers, enforcement points, exceptions, and evidence bundle definition. ¹
• Identify bypass paths: shared admins, local accounts, hard-coded keys, legacy jump boxes.

Days 31–60 (implement and instrument)

• Implement JIT elevation for the highest-risk admin roles through PAM or equivalent mechanism.
• Add automatic expiry and validate de-elevation with logs.
• Standardize request/approval workflow (ticketing or access request system) tied to elevation.
• Centralize evidence collection: config exports + sample event traces in a single audit folder.

Days 61–90 (prove operation and harden)

• Run a control health check: sample elevations, confirm expiry, confirm session logging.
• Reduce standing privilege: migrate remaining admins to the dynamic path or document exceptions.
• Operationalize exception management with expirations and periodic review.
• Prepare an assessor-ready packet: control card, configuration, logs, samples, and test results.

If you need this to run consistently across teams, Daydream is a natural fit for turning the control card, evidence bundle, and recurring health checks into assigned workflows with auditable outputs, without rebuilding your GRC process from scratch.

Frequently Asked Questions

Do we need a PAM tool to meet AC-2(6)?

No, but you do need technical enforcement that can change privileges based on conditions and produce logs. PAM commonly satisfies JIT, expiry, and session recording expectations more cleanly. ¹

Does “dynamic” mean real-time changes during a user session?

It can, but it does not have to be real-time for every system. Define the conditions you enforce (time-bound, ticket-bound, risk-based) and show consistent operation and evidence. ¹

How do we handle break-glass access without failing AC-2(6)?

Allow break-glass accounts, but force compensating controls: strong authentication, logging, rapid notification, and post-use review. Treat break-glass as an exception path with strict governance and evidence.

What evidence is most persuasive to auditors?

An end-to-end trace: the approval/request record, the system log showing privilege grant, and the later log showing automatic revocation. Pair it with the policy/configuration that enforces the rule. ¹

Are service accounts in scope for dynamic privilege management?

Assessors commonly ask about non-human identities because they often have persistent privileges. Include them in scope for constrained permissions, controlled issuance, and monitoring, even if the “dynamic” mechanism differs from human JIT.

We have RBAC and least privilege. Is that enough?

RBAC is a foundation, but AC-2(6) expects privilege changes based on conditions, not only static role assignment. Add time-bound or workflow-bound elevation for privileged actions and retain evidence it operates. ¹

Footnotes

1. NIST SP 800-53 Rev. 5

2. NIST SP 800-53 Rev. 5 OSCAL JSON