AC-2(7): Privileged User Accounts

AC-2(7): Privileged User Accounts requires you to formally define, create, and manage privileged accounts under a controlled process, so elevated access is granted only when authorized and is consistently administered. Operationalize it by inventorying privileged accounts, setting standard provisioning and deprovisioning workflows, assigning ownership, and retaining evidence that administration matches your defined parameters. ¹

Key takeaways:

• Define what “privileged” means in your environment, then manage those accounts under stricter rules than standard user accounts. ²
• Build an auditable lifecycle: request, approval, provisioning, review, change, and termination for privileged accounts. ¹
• Keep a minimum evidence bundle per cycle so you can prove the control operates, not just that a policy exists. ²

“Privileged” is not a title; it’s a capability. If an account can change security settings, create or remove identities, access sensitive production data, bypass normal controls, or administer core infrastructure, it deserves a higher bar than ordinary access. AC-2(7) is the NIST SP 800-53 requirement that pushes you to treat those identities as a distinct class: explicitly established and explicitly administered under defined rules. ²

For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing ac-2(7): privileged user accounts requirement is to turn it into a repeatable runbook with three anchors: (1) a crisp definition and scope, (2) a lifecycle workflow with named owners and systems of record, and (3) an evidence bundle that can survive an audit, customer diligence, or incident review. ²

This page is written to help you do that quickly: identify which accounts are privileged, decide how they are requested and approved, enforce administration through IAM and ITSM tooling, and produce artifacts that demonstrate consistent operation across employees, contractors, and third parties with elevated access. ²

Regulatory text

Requirement (excerpt): “Establish and administer privileged user accounts in accordance with {{ insert: param, ac-02.07_odp }};” ¹

Operator meaning: You must (a) set the rules for privileged accounts (the “accordance with” parameters in your organization-defined policy), then (b) run privileged account creation and ongoing administration according to those rules every time. Auditors will look for consistency between the written parameters and what your IAM, directories, cloud consoles, and ticketing records show in practice. ²

Plain-English interpretation

AC-2(7) expects you to treat privileged accounts as a controlled population with tighter governance than standard accounts. You are proving two things:

1. You intentionally establish privileged accounts (not accidentally via ad-hoc admin grants).
2. You actively administer privileged accounts through a defined lifecycle (provisioning, changes, periodic checks, and removal). ²

This is a requirement about discipline and traceability: who approved the elevated access, who owns the account, what it’s used for, where it exists, and how you know it’s still appropriate. ²

Who it applies to

Entity scope: Federal information systems, federal contractors, contractor systems handling federal data, and service organizations adopting NIST SP 800-53 as the control baseline. ²

Operational scope (what systems and identities):

• Human admin accounts: domain admins, cloud tenant admins, database admins, security tool admins.
• Privileged roles in SaaS: admin roles in identity providers, ticketing systems, code repositories, monitoring/logging, endpoint management.
• Privileged service accounts: automation accounts with admin scopes, CI/CD runners with production deploy rights.
• Third-party privileged access: MSPs, incident response firms, consultants, and cloud support accounts where you grant elevated roles. Use “third party” as the umbrella; “vendor” is only one type. ²

If an identity can materially change security posture or access sensitive production workloads, treat it as privileged even if it looks “normal” in your directory. ²

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

Use this as an implementation runbook for the ac-2(7): privileged user accounts requirement.

1) Define “privileged” and document the rules (your organization-defined parameters)

Create a short standard that answers:

• What permissions/roles qualify as privileged (by platform)?
• Which systems are in scope (IdP, cloud, endpoints, databases, CI/CD, security tools)?
• Who can approve privileged access (by domain)?
• When you require separate admin accounts vs elevating a daily user account.
• How fast you remove privileged access on termination or role change (define your internal SLA; don’t guess a “standard” number). ²

Deliverable: a “Privileged Account Standard” referenced by your access control policy. ²

2) Inventory privileged accounts across systems

Build an authoritative list from:

• Identity provider privileged groups/roles
• Cloud IAM roles and subscriptions/tenants
• Local admin and directory admin groups
• SaaS admin role exports
• Service accounts with high-risk scopes (tokens, keys, deploy roles) ²

Practical tip: treat this as a mapping exercise. You are creating the denominator for future reviews and proving you know where privileged access exists. ²

3) Assign ownership for each privileged account and privileged role set

For each privileged identity, record:

• Named owner (human) and backup owner
• Business purpose (one sentence)
• System(s) and role(s)
• Whether it is human, service, or third-party
• Approval authority (role/position) ²

4) Standardize request + approval workflow (ITSM + IAM)

Define a single intake path for privileged access:

• Request ticket with role requested, justification, duration/expiry if applicable, and owner
• Approval step by designated approver(s)
• Provisioning step executed by IAM automation or admins
• Confirmation step: requestor validation and access recorded ²

If you cannot enforce “single path,” document allowed exceptions and require after-the-fact validation with evidence. ²

5) Enforce administrative guardrails in tooling

Common guardrails that map cleanly to AC-2(7) administration goals:

• Separate admin accounts (or tightly controlled elevation) for privileged actions
• Strong authentication and conditional access for privileged identities
• Limit privileged access to managed devices and approved networks where feasible
• Centralize assignment through groups/roles, not one-off direct grants ²

6) Implement recurring administration checks (“control health checks”)

Run a recurring check that answers:

• Who has privileged access today?
• Does each privileged assignment have an owner, justification, and approval trail?
• Are there orphaned privileged accounts (no owner, terminated user, stale third-party)?
• Are privileged roles assigned outside standard groups or workflows? ²

Track findings to closure with due dates and validation evidence. This is where teams often fail because they run the report once and never prove sustained operation. ²

7) Deprovision and remove privileged access reliably

Tie privileged access removal to:

• HR termination events
• Contract end dates for third parties
• Role changes and transfers
• Expiration dates for time-bound admin access ²

Prove removals with system logs, ticket closures, and IAM change records. ²

Required evidence and artifacts to retain

Build a minimum evidence bundle you can hand to an auditor without scrambling. Recommended artifacts:

• Privileged Account Standard (definition, rules, approvals, exceptions) ²
• Privileged account inventory (export + curated register, with owners and purposes) ²
• Access request/approval records for privileged grants (tickets/workflow approvals) ²
• Provisioning and change logs (IAM audit logs, admin console logs, group membership changes) ²
• Recurring review output (attestations, findings list, remediation tickets, closure evidence) ²
• Exception register (what deviated, who approved, compensating controls, end date) ²

If you use Daydream, store the control card, runbook, and evidence links in one place so the “owner + cadence + evidence” story is consistent across audits and customer diligence. ²

Common exam/audit questions and hangups

Expect these, and prepare the artifacts above:

1. “Show me your privileged account population.” Auditors will sample across platforms, not just Active Directory. ²
2. “How do you know privileged access is approved?” They will follow a single user from request to grant in logs. ²
3. “What about service accounts and CI/CD?” Teams often skip them; auditors won’t. ²
4. “How do you handle third-party admin access?” They will ask for contract/engagement linkage and offboarding proof. ²
5. “How do you prove this runs continuously?” One-time screenshots fail. Provide recurring review outputs and remediation tracking. ²

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Defining privileged as “domain admin only”	Misses cloud, SaaS, and security tooling admins	Define privileged by capability and enumerate roles per platform. 2
Relying on policy without workflow	You can’t prove “administer”	Route grants through ITSM/IAM workflows with approvals and logs. 2
No owner for privileged service accounts	Orphans persist and become unaccountable	Require a human owner and purpose for every privileged non-human identity. 2
Exceptions handled in email/Slack	Evidence becomes non-auditable	Use an exception register and attach approvals and compensating controls. 2
Reviews performed but not tracked to closure	Findings repeat and audits flag “ineffective operation”	Create remediation tickets, due dates, and validation evidence. 2

Enforcement context and risk implications

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

Operationally, privileged account failures are high-impact because they can enable rapid lateral movement, configuration tampering, and data access across many systems. Treat AC-2(7) as a control that reduces blast radius and improves accountability during incident response: you can quickly answer who had admin rights, when they received them, and what changed. ²

Practical 30/60/90-day execution plan

Use phases with concrete deliverables. Adjust sequencing to your environment.

Day 30: Define and baseline

• Publish the Privileged Account Standard (definitions, in-scope systems, approval rules, exceptions). ²
• Produce a first-pass privileged account inventory across your top-risk platforms (IdP, cloud, endpoint admin, key SaaS). ²
• Assign owners for each privileged role set and known privileged accounts. ²

Day 60: Put administration on rails

• Implement a standardized request/approval workflow in your ticketing system for privileged access. ²
• Align IAM group/role assignment to that workflow; reduce direct grants. ²
• Stand up an exception register with an approver model and a review cadence. ²

Day 90: Prove ongoing operation

• Run your first recurring privileged access review, record results, open remediation items, and close them with validation evidence. ²
• Test offboarding: pick a terminated user and a departed third party, then prove privileged access removal with logs and tickets. ²
• Package the minimum evidence bundle in a single repository (Daydream or your GRC system) and map it to AC-2(7) so audits become retrieval work, not investigation. ²

Frequently Asked Questions

What counts as a “privileged user account” for AC-2(7)?

Any account that can administer systems, security controls, identities, or access sensitive production data at scale qualifies. Document your definition and list privileged roles per platform so scope is defensible. ²

Do service accounts and automation identities fall under this requirement?

Yes if they have elevated permissions. Give each privileged service account a human owner, a purpose, and lifecycle administration evidence (creation, change control, and removal). ²

Can we use just-in-time (JIT) elevation instead of separate admin accounts?

AC-2(7) does not force a specific architecture; it forces disciplined establishment and administration. If you use JIT, keep the approval trail, elevation logs, and periodic checks that show elevation is controlled and reviewed. ²

How do we handle third-party privileged access (MSPs, consultants, incident responders)?

Treat third-party admins as privileged accounts with the same request/approval and offboarding requirements, plus explicit ownership and engagement linkage. Keep evidence that access is removed when the engagement ends. ²

What evidence is usually missing during audits?

Teams often lack a complete privileged account inventory across SaaS and cloud, and they can’t connect privileged grants to approvals. Fix this by exporting role assignments, tying them to tickets, and retaining review outputs plus remediation closures. ²

We inherited many existing admins. How do we get compliant without stopping operations?

Start by inventorying and tagging each privileged assignment with an owner and justification, then run a cleanup cycle through your new workflow to retro-approve or remove access. Document exceptions with a short-term plan to migrate into the standard process. ²

Footnotes

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

2. NIST SP 800-53 Rev. 5