AU-9(4): Access by Subset of Privileged Users

To meet the au-9(4): access by subset of privileged users requirement, restrict who can manage audit logging (enable/disable logging, change audit policies, modify agents/collectors, alter log routing/retention) to a tightly defined, approved subset of privileged administrators. Then prove it with role design, system configurations, and recurring access reviews tied to audit-log management permissions. ¹

Key takeaways:

• Define “audit logging management” actions and map them to explicit permissions in each platform you run.
• Limit those permissions to a small, named admin subset via RBAC/PAM, with separation from day-to-day system admins where feasible.
• Keep durable evidence: role definitions, access lists, approval tickets, configuration snapshots, and review attestations.

AU-9(4) is a practical control: it forces you to prevent the wrong privileged people from changing the very mechanism you rely on to detect and investigate issues. If too many admins can disable audit logging, reduce verbosity, alter forwarding, or change retention, you lose evidentiary integrity and increase the chance that security events go undetected or become uninvestigable.

Operationalizing this control starts with a scoping decision you must make explicit: what systems are “in scope” for audit logging management (SIEM, EDR, cloud audit trails, databases, identity platforms, network devices, and the hosts running collectors), and what specific actions count as “management of audit logging functionality.” Then you translate that into enforceable access controls: roles, groups, PAM entitlements, conditional access, and change control gates. Finally, you retain evidence that the restriction is implemented and stays implemented.

This page gives requirement-level guidance you can hand to control owners, IAM teams, and platform admins to implement AU-9(4) quickly and withstand an assessor’s sampling. Control text reference: AU-9(4). ²

Regulatory text

Requirement (excerpt): “Authorize access to management of audit logging functionality to only {{ insert: param, au-09.04_odp }}.” ¹

What the operator must do

1. Decide and document who “{{…au-09.04_odp}}” is for your environment. In practice, this is a named subset such as “Security Logging Administrators” or “SIEM Platform Administrators,” not “all sysadmins.”
2. Enforce the decision technically by granting audit-log management permissions only to that subset (RBAC groups, PAM roles, cloud IAM policies, database privileges).
3. Prevent privilege sprawl over time with approvals, monitoring, and recurring reviews focused specifically on audit-log management access.

AU-9(4) is about authorization and restriction of management functions, not general read-only access to logs for analysts or auditors. ²

Plain-English interpretation

Audit logs only help if they are hard to tamper with. AU-9(4) requires you to:

• Identify the small set of privileged users who can change logging controls (what gets logged, where it goes, whether it runs, and how long it is kept).
• Block everyone else, including other privileged admins, from making those changes.
• Show evidence that access is restricted by design and is actively governed.

A good internal test: if a domain admin, cloud admin, or database admin can quietly disable logging or reroute logs without being part of your approved logging-admin subset, you likely fail the intent of AU-9(4).

Who it applies to (entity and operational context)

AU-9(4) is most relevant for:

• Federal information systems and contractor systems handling federal data that align to NIST SP 800-53. ¹
• Environments where audit logging is centrally relied on for detection, investigations, compliance reporting, or incident response (SIEM/SOAR, EDR consoles, cloud control planes, identity providers).

Operational contexts where assessors focus:

• Central logging platforms (SIEM, log pipelines, collectors/forwarders).
• Cloud-native audit trails (control-plane logs) and who can change their configuration.
• Identity and access platforms because IAM logs often establish “who did what.”
• Admin tooling (PAM, configuration management, “break glass” processes) because these are common paths to gaining log-control privileges.

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

Step 1: Define “audit logging management” for your organization

Create a short, explicit list of actions that count as “management of audit logging functionality.” Use it consistently in policy, RBAC design, and evidence. Include at least:

• Enable/disable logging or collectors/agents
• Change audit policy (events captured, verbosity, inclusion/exclusion filters)
• Modify forwarding destinations, routing rules, or pipelines
• Change retention, deletion controls, immutability settings
• Edit parsing/normalization rules when it affects what is recorded or preserved

Deliverable: a one-page “Audit Logging Management Actions” definition owned by Security/GRC and acknowledged by platform owners.

Step 2: Name the authorized subset and codify it in roles/groups

Decide the subset (the “only” group) for each layer:

• Platform layer: SIEM/log pipeline admins
• Source layer: cloud audit trail admins, IdP audit config admins, database audit config admins
• Transport layer: collector/forwarder admins

Convert that into RBAC roles or directory groups with clear naming (example: SEC-LOGGING-ADMINS) and documented membership criteria (job role, training, background checks if applicable internally, and manager approval path).

Practical rule: keep the subset small and stable. If turnover forces frequent membership changes, you need a tighter onboarding/offboarding workflow.

Step 3: Implement least privilege in each system (technical enforcement)

For each in-scope system, implement controls that make the subset real:

• IAM/RBAC: map the “audit logging management” actions to specific permissions and attach only to the authorized group.
• PAM: require privileged session access or just-in-time elevation for log-management tasks, especially for “disable logging,” “change retention,” and “edit routing.”
• Separation from general admins: where possible, prevent general infrastructure admins from inheriting logging-management permissions “because it was easier.”

Evidence-friendly configuration choices:

• Prefer group-based entitlements over individual user grants.
• Prefer role definitions that can be exported or screenshotted consistently.
• Prefer approval-backed elevation for high-risk actions (disable, delete, retention changes).

Step 4: Add change control gates for logging configuration

Treat audit-log management as a controlled change surface:

• Require a ticket/change record for logging configuration changes.
• Record approver, reason, scope, and rollback plan.
• For emergency changes, allow an exception path but require after-the-fact review.

This is where many teams operationally fail AU-9(4): access is restricted, but changes still happen without traceable authorization.

Step 5: Monitor and review access to logging management

Set up recurring governance that is narrowly scoped to AU-9(4):

• Access reviews: validate membership of the logging-admin subset and confirm no shadow admin paths exist (e.g., a generic “Cloud Admins” group that also grants audit config permissions).
• Alerting: generate alerts for additions to the logging-admin group(s) and for changes to logging configuration.

If you do one thing for audit readiness, do this: maintain a single, current list of “who can manage logging” per platform, with evidence of review.

Step 6: Validate with an auditor’s sampling mindset

Before an assessment, test:

• Can a non-authorized privileged user change audit settings?
• Can they stop an agent/collector?
• Can they change retention or delete controls?
• Can they reroute logs to an unapproved destination?

Document results and remediate gaps immediately.

Required evidence and artifacts to retain

Keep evidence in a format you can produce quickly under sampling.

Design evidence

• Policy/standard: definition of “audit logging management” actions and the authorized subset (by role/group)
• RBAC/PAM design documentation mapping permissions to roles

Implementation evidence ¹

• Role/group configuration exports or screenshots showing permissions for audit-log management
• Current membership list for authorized groups
• PAM policy showing JIT elevation or restricted entitlements for logging administration

Operational evidence

• Access review records (attestation, reviewer, date, findings, remediation)
• Change tickets for logging configuration changes (including emergency exceptions and post-review)
• Alerts or audit records showing additions/removals to logging-admin groups, plus follow-up where needed

Tip: Store evidence in a single control folder per system (SIEM, cloud, IdP, database). Daydream customers typically keep this as a repeating evidence request with consistent naming so audits do not become a scavenger hunt.

Common exam/audit questions and hangups

Assessors and internal audit teams tend to ask:

• “Show me who can change audit logging settings in System X. Is it limited to a defined subset?” ¹
• “Prove that access is enforced technically, not just by policy.”
• “How do you prevent a broader admin role from inheriting logging-management permissions?”
• “What is your review cadence and what did you do with findings?”
• “Can someone disable logging during an incident without detection or approval?”

Common hangup: teams present “we have admins” without showing the specific permission boundary around audit management functions.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails AU-9(4)	Avoid it by doing this
“All cloud admins can manage audit trails”	You did not limit to a subset; you expanded it	Create a dedicated logging-admin role; remove audit config rights from broad admin roles
Individual user grants (“just give Sam access”)	Hard to review and easy to forget	Require group-based access only; block direct grants
Logging admin group exists, but “break glass” bypass isn’t governed	The control surface still exists outside the subset	Put break-glass behind PAM + after-action review; keep membership extremely limited
No evidence of ongoing review	Control might exist but is not proven to operate	Schedule access reviews and retain sign-offs and remediation tickets
Confusing “view logs” with “manage logging”	You may over-restrict analysts and still miss the real risk	Separate read-only analyst roles from logging-management roles

Enforcement context and risk implications

No public enforcement cases were provided in the supplied source material for AU-9(4). Your risk argument should stay grounded in operational impact:

• If unauthorized admins can alter logging, you risk loss of forensic integrity, undetected malicious activity, and failed investigations because the record of events is incomplete or untrustworthy.
• If auditors cannot confirm restricted access and durable evidence, you risk assessment findings that can cascade into broader conclusions about control effectiveness in the AU family. ²

Practical 30/60/90-day execution plan

First 30 days (stabilize scope and ownership)

• Assign a control owner (Security or GRC) and technical owners per platform.
• Inventory in-scope audit logging components (SIEM, cloud audit trails, IdP, EDR, databases, collectors).
• Write your “audit logging management actions” definition and get sign-off.
• Identify current roles/groups with audit-log management permissions; capture baseline evidence snapshots.

Days 31–60 (implement and close the biggest access gaps)

• Create dedicated logging-admin roles/groups and migrate permissions off broad admin roles.
• Enforce PAM/JIT for high-risk logging changes where feasible.
• Implement ticketing requirements for logging configuration changes.
• Add monitoring for group membership changes and key logging-configuration changes.

Days 61–90 (operationalize and get audit-ready)

• Run your first formal access review for logging-admin groups; remediate findings.
• Perform a negative test: attempt logging-management actions from non-authorized privileged accounts and document outcomes.
• Package evidence by platform into a repeatable “AU-9(4) evidence set” for audits.
• If you manage many systems, track all of the above in Daydream as a single requirement with per-system implementation notes and recurring evidence tasks so the control does not degrade between assessments.

Frequently Asked Questions

Does AU-9(4) mean only security can access logs?

No. AU-9(4) is about who can manage audit logging functionality, not who can read logs. Keep read-only access separate from permissions that enable/disable logging, change policies, or alter retention. ¹

Are “cloud admins” an acceptable authorized subset?

Only if you explicitly designate cloud admins as the authorized subset and can show the set is restricted and approved. In most environments, “cloud admin” is too broad; create a narrower role that includes audit configuration permissions and remove them from general admin roles. ¹

What counts as “management of audit logging functionality” in practice?

Any permission that changes what gets logged, whether logging runs, where logs go, or how long they are retained should be treated as audit-log management. Document the list and map it to concrete permissions per platform. ²

Can we allow emergency access to change logging during an incident?

Yes, but keep it inside the authorized subset or behind controlled elevation with documented approval and after-action review. Auditors will focus on whether emergency paths bypass the subset without governance. ¹

What evidence is most persuasive to an assessor?

Permission-boundary proof (role definitions, IAM policy exports, PAM entitlements) plus an up-to-date membership list and completed access reviews. Pair that with change tickets for logging configuration changes to show authorization in operation. ²

We outsource SIEM operations to a third party. How does AU-9(4) apply?

Treat the third party’s administrators as part of the “authorized subset” and enforce it contractually and technically where possible (named accounts, least privilege roles, PAM, and reviewable access lists). Retain the third party’s access evidence alongside your internal evidence for the same control. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5