AC-3(2): Dual Authorization

The ac-3(2): dual authorization requirement is a targeted enhancement to access enforcement: for certain sensitive actions, you must require two distinct, authorized individuals to approve (or jointly complete) the action. In practice, this requirement is most often used to prevent a single compromised account, malicious insider, or rushed operator from creating irreversible harm such as disabling logging, granting powerful privileges, changing access rules, or releasing sensitive data to an untrusted destination.

Compliance teams often stall on one point: the NIST text is intentionally parameterized, so you must decide what “dual authorization” applies to in your environment. That decision must be explicit, defensible, and translated into system-enforced workflows. “We require approvals by policy” is not enough if the system still lets one admin click through.

This page gives you requirement-level implementation guidance you can put into a control card and runbook: who owns it, how to scope it, how to implement the gates, what evidence to retain, and what examiners typically challenge. The goal is simple: you can prove dual authorization is required, is technically enforced, and is operating consistently for the actions you defined.

Regulatory text

Requirement (excerpt): “Enforce dual authorization for {{ insert: param, ac-03.02_odp }}.” ¹

What the operator must do: You must (1) define the set of access-related actions and decisions that require dual authorization in your system context, and (2) implement enforcement so those actions cannot complete unless an independent second authorized party approves (or participates), with traceable records that prove it happened. This is an access enforcement requirement under AC-3 with a dual-approval enhancement ².

Plain-English interpretation

Dual authorization means “two-person control” for sensitive actions. One person initiates a restricted action; a different person approves it (or completes a required second step) before the system executes the action.

What counts as “dual” in audits:

• Two distinct identities (no shared admin accounts).
• Independence (the approver cannot be the same person, and should not be able to self-approve through role stacking).
• System-enforced gating (the action is blocked without the second authorization).
• Event-level evidence (who requested, who approved, when, what was changed, and the resulting state).

What dual authorization is not:

• A Slack “+1” with no linkage to the change.
• A ticket marked “approved” after the change already occurred.
• A manager approval that the requester can impersonate via shared credentials.

Who it applies to (entity and operational context)

AC-3(2) commonly applies where you operate information systems aligned to NIST SP 800-53, including:

• Federal information systems and programs
• Federal contractors and service organizations handling federal data ²

Operational contexts where it’s typically scoped in:

• Privileged access management (PAM) actions (granting admin roles, creating break-glass accounts).
• Identity and access management (IAM) policy changes (SSO/MFA policy, conditional access rules).
• Access control enforcement points (firewall/security group changes, allow-listing).
• Data protection boundary changes (KMS key policy changes, secret rotation disablement).
• Audit and monitoring tampering risks (disabling logs, deleting audit trails).
• Production release controls when releases can alter authorization logic (depends on your defined scope).

If you are a CCO or GRC lead, your job is to force clarity: exactly which actions require dual authorization, in which systems, and what constitutes “approval.” The system owners then implement it.

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

Step 1: Write the scope statement (the parameter you must fill)

The NIST text is parameterized (“{{…}}”), so you must define the “organization-defined parameter” in plain terms ¹. Create a short scope table:

Action category	In scope?	Systems	Trigger event	Dual authorization method
Grant/modify privileged roles	Yes	IAM, Directory, Cloud IAM	Any role binding change to admin-tier roles	Ticket approval + system-enforced workflow
Disable audit logging	Yes	SIEM, Cloud logging	Any logging disable/delete	Change management approval + policy guardrail
Firewall / security group allow rules	Yes	Cloud networking	Internet exposure or broad CIDR	Pull request approval + protected branch
Break-glass access use	Yes	PAM	Checkout of emergency creds	Second approver in PAM + time-bound session

Keep it short, but explicit. Auditors prefer a bounded list over vague “all critical changes.”

Step 2: Define the approval rule set

Codify how the dual authorization works:

• Eligible approvers: roles or groups (e.g., Security Engineering approvers, not “any admin”).
• Independence rules: requester cannot approve; approver cannot be in the same “requester group” if that defeats separation; no shared accounts.
• When dual is required: for all events in scope, including emergencies (with a defined emergency path).
• What approval means: approve before execution, not after-the-fact.

Put these rules into your control card/runbook so the implementation is testable. This aligns with building a “requirement control card” with owner, triggers, steps, and exceptions ².

Step 3: Implement technical enforcement (choose your gating point)

Dual authorization must be enforced at a point that actually blocks execution:

Common enforcement patterns (pick what matches your architecture):

1. IAM workflow gating: native access request workflows that require two approvals before role assignment.
2. PAM checkout approvals: privileged session requires a second approver before credentials/session start.
3. Change management with automated enforcement: ticket approval required, plus a deployment pipeline that refuses to run without the approval artifact.
4. Policy-as-code guardrails: prevent direct changes; only approved code paths can modify sensitive resources.

Your design goal: remove “side doors” (direct console changes, direct API keys, local admin access) for the scoped actions.

Step 4: Define and control exceptions (especially emergencies)

Dual authorization breaks down during incidents unless you design for it. Create an exception rule set:

• Emergency path: allows action with dual approval on an accelerated timeline, or allows immediate action but forces rapid independent review with documented outcome.
• Break-glass boundaries: break-glass use still requires dual authorization when feasible, and always generates a high-priority review item.
• Documented rationale: who invoked exception, why, what was done, and what follow-up occurred.

Keep exception handling limited, logged, and reviewable.

Step 5: Build the minimum evidence bundle (make it reproducible)

Define a “minimum evidence bundle” for each execution cycle/event ². For each in-scope action, you should be able to produce:

• The request artifact (ticket, workflow request, PR).
• The two approver identities and timestamps.
• The object of approval (what exactly was approved: role, policy, rule, key).
• The system log showing enforcement (attempt blocked without approval, then executed after approval).
• The resulting state (post-change configuration, role binding, policy version).

Store evidence in a consistent location with retention aligned to your program requirements.

Step 6: Operate and health-check the control

Set a recurring control health check and track findings to closure ²:

• Sample in-scope events and verify dual approval occurred.
• Identify bypass paths (console hotfixes, direct API tokens).
• Confirm approver independence (no self-approval, no shared accounts).
• Review exception use and ensure follow-ups were completed.

Required evidence and artifacts to retain

Retain artifacts that prove both design and operation:

Design evidence

• Control card/runbook for AC-3(2): objective, owner, in-scope actions, triggers, exception rules ².
• System configuration screenshots/exports showing enforcement points (workflow requirements, protected branches, PAM policies).
• Role/approver group definitions and access lists.

Operating evidence (event-level)

• Tickets/requests with dual approval captured in the system of record.
• Change logs/audit logs mapping request → approval(s) → execution.
• Exception records and post-incident reviews where exceptions were used.

Oversight evidence

• Control health check results and remediation tracking to validated closure ².

Common exam/audit questions and hangups

Expect these questions and prepare crisp answers:

• “What actions require dual authorization, exactly?” Provide the scope table and rationale.
• “Show me an example.” Produce an event packet: request, approvals, logs, resulting config.
• “Can an admin bypass this in the console?” Demonstrate preventive controls (permissions, guardrails) and detective monitoring for attempted bypass.
• “How do you prevent self-approval?” Show workflow rules and role separation.
• “What happens during an incident?” Show emergency procedure and evidence it still produces reviewable approvals and logs.

Auditors get stuck when dual authorization exists “in policy” but the system still allows direct changes.

Frequent implementation mistakes and how to avoid them

• Mistake: Scope is “all critical changes,” with no list.
  Fix: publish an explicit action list tied to systems and triggers.
• Mistake: Two approvals happen after execution.
  Fix: require approval as a precondition in the workflow/pipeline.
• Mistake: Approvers are not independent.
  Fix: enforce “requester cannot approve,” prevent dual-role stacking, eliminate shared accounts.
• Mistake: Bypass paths remain open.
  Fix: restrict direct admin permissions, require changes through controlled pipelines, and monitor for direct API calls.
• Mistake: Evidence is scattered and non-repeatable.
  Fix: define a minimum evidence bundle and a single retention location ².

Enforcement context and risk implications

No public enforcement cases were provided in the source data for this control. Practically, AC-3(2) reduces exposure to:

• Single-actor privileged misuse
• Credential compromise that leads to privilege escalation
• Unauthorized policy changes that disable detection or expand access

For regulated customers and federal programs, inability to prove dual authorization often shows up as an audit finding because it is easy to test: auditors attempt to trace a sensitive change and see whether two independent approvals were required and recorded ².

Practical 30/60/90-day execution plan

First 30 days (stabilize scope and ownership)

• Assign a control owner and technical owners per system.
• Draft the AC-3(2) control card: scope, triggers, approver roles, exceptions ².
• Build the in-scope action inventory for IAM/PAM/cloud/networking.
• Identify bypass paths and decide the enforcement point for each action category.

By 60 days (enforce and prove)

• Implement workflow gates for the top-risk action categories (privileged role grants, logging disablement, perimeter rule changes).
• Configure logs to capture request/approval/execution linkage.
• Define the minimum evidence bundle and retention location ².
• Run a tabletop test: attempt an in-scope change without a second approver and confirm it is blocked.

By 90 days (operate and harden)

• Run a control health check, document results, and open remediation items ².
• Tune exception handling and confirm incident procedures generate reviewable evidence.
• Expand scope to additional sensitive actions and remove remaining bypass permissions.
• Prepare an “auditor-ready packet” with a few clean end-to-end examples.

If you manage this in Daydream, treat AC-3(2) like a requirement with a runbook and a standard evidence bundle: owners know what triggers the control, and auditors get consistent event packets without a scramble.

Frequently Asked Questions

Does dual authorization mean two signatures on a policy document?

No. AC-3(2) is about enforcing two-party approval for defined access-related actions in the system workflow ². A document-only approval does not prevent an unapproved execution.

Can the second approver be the requester’s manager?

Yes, if the manager is an authorized approver and the workflow prevents self-approval and shared credentials. Document the approver eligibility rule and enforce it in tooling.

What systems should I scope first?

Start where a single action can cause broad access expansion or loss of detection: IAM role grants, PAM/break-glass, and logging controls. Your scope should be explicit and tied to your environment’s highest-impact changes.

Is a pull request approval “dual authorization”?

It can be, if the merge is required to make the change and branch protections prevent the requester from self-approving or bypassing the process. You still need logs that show who approved and what was merged.

How do I handle emergencies without violating the control?

Create a documented emergency path with defined approvers and required follow-up review, and ensure evidence is captured in the system of record. Keep exceptions narrow and review them during control health checks ².

What evidence do auditors ask for most often?

A clean event trail: request, two independent approvals, execution log, and resulting configuration state for an in-scope action. If you cannot produce that quickly, your evidence bundle and retention design need work ².

Footnotes

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

2. NIST SP 800-53 Rev. 5