SC-32(1): Separate Physical Domains for Privileged Functions

SC-32(1) requires you to run privileged functions in separate physical domains so that high-impact administrative actions cannot be performed from the same physical environment used for routine user activity. Operationalize it by identifying “privileged functions,” designating an isolated admin domain (workstations, network paths, and management planes), then proving separation with architecture diagrams, configurations, and access records. ¹

Key takeaways:

• “Separate physical domains” is a design constraint: admins do admin work from a physically distinct domain, not their daily-use environment. ¹
• Your implementation lives or dies on clear scope: which privileged functions, which systems, and what counts as “separate” in your architecture.
• Auditors will ask for evidence of separation, not policy statements: diagrams, build standards, endpoint/network configs, and privileged access logs.

The sc-32(1): separate physical domains for privileged functions requirement is an architectural control enhancement that forces you to isolate privileged activity so it is harder to intercept, spoof, or subvert. The practical goal is straightforward: reduce the chance that a compromise of an everyday user environment (phishing, malware, browser exploit, stolen cookie) becomes an immediate path to domain admin, cloud admin, or security-tool admin.

For most enterprises, SC-32(1) becomes real in one place: how administrators access management planes (identity providers, hypervisors, cloud consoles, network devices, EDR/SIEM, backup systems) and where they perform privileged tasks. If your admins browse the internet, read email, and run admin sessions from the same workstation and network, you will struggle to show “separate physical domains” in any credible way.

This page gives requirement-level, execution-first guidance: how to define privileged functions, pick a separation model that matches your environment, implement the isolation (endpoints + networks + management interfaces), and package evidence so an assessor can verify the partitioning quickly. The focus is operational readiness for federal systems and contractor systems handling federal data, where NIST SP 800-53 is a common assessment baseline. ²

Regulatory text

Requirement: “Partition privileged functions into separate physical domains.” ¹

Operator interpretation (what you must do):

• Identify the set of privileged functions (administrative actions that can change security posture, configurations, identities, or monitoring).
• Implement a physically distinct domain for performing those functions.
• Ensure the privileged domain is not casually reachable from normal user environments and that privileged activity is constrained to that domain as a standard operating model.

NIST uses compact language here, so your job is to translate it into a verifiable boundary: “This is where privileged functions can be executed; this is where they cannot.”

Plain-English interpretation

Partitioning privileged functions into separate physical domains means you create a dedicated, isolated environment for admin work and you treat everyday user environments as untrusted for privileged actions.

A workable mental model:

• User domain: endpoints and networks optimized for productivity (email, web, SaaS).
• Privileged domain: endpoints and network paths optimized for control and integrity (restricted apps, hardened builds, strong device identity, narrow egress, strong logging).

“Physical domain” is commonly implemented as separate admin workstations and separated network segments with restricted connectivity to management interfaces. In some organizations it also means dedicated admin rooms, jump hosts in secured racks, or physically separated management networks in data centers.

Who it applies to (entity and operational context)

This requirement most often applies when you are aligning to NIST SP 800-53 for:

• Federal information systems, including agencies and integrators delivering systems subject to federal security requirements. ²
• Contractor systems handling federal data, where 800-53 is flowed down by contract, ATO requirements, or program security needs. ²

Operationally, it applies to any environment where staff perform privileged functions, including:

• Identity and access administration (IdP, PAM, directory services)
• Network and firewall administration
• Cloud control plane administration
• Endpoint security administration (EDR, MDM)
• Security monitoring administration (SIEM, SOAR)
• Backup/restore and key management administration

If you have third parties performing administrative functions (MSPs, consultants, managed SOCs), treat them the same way: their privileged access path must originate from the privileged domain or an equivalent physically separated domain you can validate.

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

1) Define “privileged functions” for your environment (make it auditable)

Create a short, explicit list of privileged functions and map each to systems and roles. Keep it narrow enough to manage, broad enough to cover real power.

Examples to include:

• Creating/modifying privileged accounts and role assignments
• Changing security policies (conditional access, MFA rules, EDR policies)
• Changing logging/alerting rules or disabling sensors
• Changing network routes, firewall rules, VPN configs
• Managing hypervisors, container orchestration control planes, cloud IAM

Deliverable: a Privileged Functions Register with columns: function, system, admin interface, role/group, and required access path.

2) Choose your separation model (and write down what “separate” means)

Pick one primary pattern and make it a standard.

Common patterns that satisfy the intent:

• Dedicated Privileged Access Workstations (PAWs): separate physical laptops/desktops for admin work, hardened and restricted.
• Secured jump hosts reached only from a controlled location: admin sessions can only originate from a locked-down terminal in a restricted area.
• Dedicated management network: management interfaces live on a physically separate network with tightly controlled ingress.

Decision criteria to document:

• Which privileged actions must originate from the privileged domain
• Which admin interfaces are reachable only from the privileged domain
• Whether emergency access exists, and how it is controlled and logged

Deliverable: a one-page SC-32(1) Implementation Standard describing the chosen model and the boundary.

3) Build the privileged domain endpoints (PAW or equivalent)

Your privileged endpoint build should be measurably different from user endpoints:

• Separate device inventory category (“Privileged Admin Workstation”)
• Hardened configuration baseline (reduced software, restricted browsers/extensions, strong local controls)
• Strong device identity and posture checks if your IdP supports it
• Separate admin accounts from daily accounts, with strict login rules

Make “no email/no general web” a default expectation for admin endpoints unless you have a written exception process with compensating controls.

Artifacts: endpoint build standard, configuration baseline, asset inventory export.

4) Separate network paths to management planes

Separation must show up on the wire:

• Create a management segment / VLAN / subnet for admin endpoints.
• Restrict management-plane ingress so only the privileged domain can reach admin interfaces (firewall rules, security groups, ACLs).
• Block lateral movement paths from user networks to management networks.
• Constrain egress from the privileged domain to what admins need (updates, specific management portals, ticketing, code repos if required).

Artifacts: network diagram, firewall/ACL rule exports, security group configurations, routing documentation.

5) Partition admin interfaces and privileged tooling

Lock down the interfaces that actually perform privileged functions:

• Admin portals for IdP, cloud, EDR, SIEM, backup, network devices
• Remote management protocols and admin APIs
• Privileged command execution pathways

Concrete control: “Administrative access to [system] is only permitted from [privileged domain subnet/device group].”

Artifacts: system access control settings, conditional access policies, admin portal access restrictions, PAM configuration snapshots.

6) Implement exceptions and “break glass” safely

Most environments need emergency access. That does not kill the control if you manage it tightly:

• Define what qualifies as emergency
• Pre-stage break-glass accounts with strong protections
• Require documented approval and post-incident review
• Log and alert on break-glass use

Artifacts: exception procedure, approval records, break-glass account inventory, event logs demonstrating monitoring.

7) Prove it works (test like an assessor)

Test from both directions:

• From a normal user workstation/network, attempt to reach admin interfaces and confirm it fails.
• From a privileged workstation/network, confirm required admin access works and is logged.

Artifacts: test scripts/results, screenshots, change tickets, and log extracts showing both denied and allowed paths.

8) Assign ownership and recurring evidence (assessment readiness)

SC-32(1) often fails on evidence. Assign a control owner and define what you’ll collect on a cadence:

• Quarterly: network rule review, privileged endpoint inventory validation
• Monthly: privileged access log review for “non-privileged domain” origins
• Ongoing: exception tracking and break-glass monitoring

Daydream fit: many teams use Daydream to map SC-32(1) to a named owner, attach the implementation standard, and request recurring artifacts (diagrams, firewall exports, endpoint inventory) so evidence is ready before an assessment.

Required evidence and artifacts to retain

Keep evidence that shows design, implementation, and operation.

Minimum artifact set:

• SC-32(1) implementation standard (what you chose and why) ¹
• Privileged Functions Register (scope)
• Network architecture diagram showing privileged domain separation (dated/versioned)
• Firewall/ACL/security group configurations enforcing restricted management-plane access
• Privileged endpoint inventory (list of PAWs/jump terminals), with build baseline reference
• Conditional access / access policy configs restricting admin portals to privileged domain
• Privileged access logs showing admin actions originate from the privileged domain
• Exception/break-glass records with approvals and post-use reviews
• Test evidence (deny from user domain, allow from privileged domain)

Common exam/audit questions and hangups

Expect these lines of questioning:

1. “Define privileged functions.” If you cannot point to a scoped list, the assessor will treat your boundary as undefined.
2. “Show me the boundary.” They will ask for diagrams and live configs, not narratives.
3. “Can an admin do privileged work from a normal laptop?” If yes, you need a defensible exception mechanism and proof it is rare, approved, and monitored.
4. “How do third parties administer systems?” If an MSP logs in from any device, you likely have a gap. Require equivalent privileged-domain access paths.
5. “Prove enforcement.” They will ask for deny evidence: blocked connections, rejected policies, or access attempts.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails SC-32(1)	How to avoid
“We have MFA, so admin work is safe from anywhere.”	MFA does not create physical domain separation.	Enforce admin portal access only from the privileged domain and keep proof.
PAWs exist, but admins still do real admin work from daily devices.	The privileged domain becomes optional.	Make privileged-domain origination mandatory for privileged functions, with alerts on violations.
Jump host is shared and reachable from user network.	You removed separation at the entry point.	Restrict jump host access to privileged domain only, or place it in a restricted physical location.
No documentation of what “separate physical domain” means internally.	Assessors cannot test against an undefined standard.	Write an implementation standard with clear boundary statements and examples.
Evidence is missing or stale.	Control may be implemented but not provable.	Assign an owner and collect recurring artifacts in a system of record (often a GRC tool like Daydream).

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat SC-32(1) primarily as an assessment and risk driver rather than a cited enforcement hot spot.

Risk-wise, SC-32(1) is a direct response to common attack chains: compromise a user workstation, steal tokens/credentials, pivot into admin consoles, then disable defenses and create persistence. Physical domain separation reduces the chance that a single endpoint compromise becomes total control.

A practical 30/60/90-day execution plan

First 30 days (Immediate)

• Assign a control owner and approver for exceptions. ¹
• Build your Privileged Functions Register and identify the admin interfaces that matter most.
• Choose the separation model (PAW, jump host in controlled space, management network) and publish the SC-32(1) implementation standard.
• Identify which admins (employees and third parties) perform privileged functions and how they currently connect.

Days 31–60 (Near-term)

• Stand up the privileged domain: provision privileged endpoints or controlled terminals.
• Implement network segmentation and restrict management-plane access paths.
• Apply admin-portal restrictions (where supported) so privileged actions require privileged-domain origination.
• Stand up monitoring: alerts for privileged logins from non-privileged origins; track exceptions.

Days 61–90 (Operationalize)

• Run deny/allow tests and store results as evidence.
• Train admins on the new workflow and enforce it through technical controls, not memos.
• Review third-party admin access paths; amend contracts and access methods where needed.
• Set recurring evidence tasks (diagrams, inventories, firewall rule exports, access log samples). Daydream can track these tasks and keep artifacts versioned for assessment readiness.

Frequently Asked Questions

What counts as “separate physical domains” in practice?

A defensible implementation uses physically distinct admin endpoints and a management network path that normal user devices cannot use to reach admin interfaces. Your standard should describe the boundary in terms an assessor can test against system configs. ¹

Do virtual desktops or VDI satisfy SC-32(1)?

They can, if the VDI access point and the VDI admin environment together form a physically separated domain with restricted connectivity to management planes. Document the boundary and show that privileged functions cannot be executed from normal endpoints.

Can admins have email and web browsing on PAWs?

You can allow limited access if you can still demonstrate strong separation and reduced exposure, but it increases risk and complicates your story. Many teams keep PAWs restricted and route productivity tasks to non-privileged devices.

How do we handle third-party administrators (MSP/SOC) under SC-32(1)?

Require them to use your privileged domain (or an equivalent controlled access path) for privileged functions, and restrict admin interfaces to that path. Keep contract language, access design, and logs showing compliance.

What evidence is most persuasive to auditors?

Architecture diagrams plus live configuration exports that show management interfaces are reachable only from the privileged domain, and access logs showing privileged actions originate there. Pair that with a clear privileged functions scope document.

If we can’t fully implement separation everywhere, what’s the minimum viable scope?

Start with the highest-impact privileged functions: identity administration, security tooling administration, network controls, and backup/restore administration. Document scope boundaries explicitly and track a roadmap for expansion.

Footnotes

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

2. NIST SP 800-53 Rev. 5