IA-2: Identification and Authentication (Organizational Users)

To meet the ia-2: identification and authentication (organizational users) requirement, you must ensure every organizational user is uniquely identified, strongly authenticated, and that any process acting for a user is tied back to that user identity for accountability. Operationalize it by standardizing identity sources, enforcing MFA where appropriate, eliminating shared accounts, and retaining audit-ready evidence. ¹

Key takeaways:

• Every user must have a unique identity; shared and generic accounts become controlled exceptions, not the norm. ¹
• Authentication must be enforced consistently across systems, including service pathways that act “on behalf of” a user. ¹
• Evidence matters: map ownership, procedures, and recurring artifacts so you can prove operation, not just intent. ¹

IA-2 is the control that makes individual accountability real. If you cannot prove “who did what” because identities are shared, authentication is inconsistent, or user actions flow through opaque automation, you will struggle to detect misuse, investigate incidents, and satisfy assessors. IA-2 also becomes a dependency for many other controls (access control, audit logging, incident response) because those functions rely on user identity as the primary key.

This requirement is deceptively simple: uniquely identify and authenticate organizational users, and associate that unique ID with processes acting on behalf of those users. ¹ In practice, it forces decisions about identity provider scope, account lifecycle, MFA rollout, third-party access patterns, API and RPA tooling, and how you handle edge cases like break-glass access and shared operational consoles.

This page is written for a Compliance Officer, CCO, or GRC lead who needs to turn IA-2 into an implementable standard quickly: what to configure, what to document, what evidence to retain, and where audits usually stall.

Regulatory text

Requirement excerpt (verbatim): “Uniquely identify and authenticate organizational users and associate that unique identification with processes acting on behalf of those users.” ¹

What the operator must do (plain meaning)

You must design and operate identity and authentication so that:

1. Each organizational user has a unique identity (one person, one account identity within your defined identity boundary).
2. Each login/session is authenticated to that identity using your defined authentication methods.
3. Automations and processes that act for a user are attributable back to that user identity (so activity can be traced and investigated). ¹

Assessors will look for two things: (a) your technical enforcement and (b) your ability to demonstrate it with repeatable evidence.

Plain-English interpretation of IA-2

IA-2 requires accountable access. If “AccountingTeam” logs into a finance system, you cannot attribute actions to a person. If a script runs privileged actions “for the helpdesk,” you need a way to associate that run with the requesting/approving user, or the initiating user, depending on your design. The outcome is traceability: user identity ties to authentication ties to activity records.

This is not only about employees. “Organizational users” typically includes any user population under your organization’s control model: employees, contractors, interns, and in many environments, third-party administrators with organizational accounts.

Who it applies to

Entity scope

• Federal information systems and contractor systems handling federal data commonly adopt NIST SP 800-53 controls, including IA-2. ²

Operational scope (where IA-2 must be implemented)

Apply IA-2 across:

• Workforce identity: corporate directory / SSO / Identity Provider (IdP).
• Privileged access: admin consoles, cloud control planes, hypervisors, network devices.
• Business applications: ERP/HRIS/CRM and internal tools with sensitive workflows.
• Remote access paths: VPN/ZTNA, VDI, bastion hosts.
• Automation acting for users: CI/CD pipelines, RPA bots, workflow engines, ticket-driven scripts, and any integration that executes changes “as requested by” a user. ¹

If you have segmented environments (prod vs non-prod), define where IA-2 is mandatory versus risk-accepted with compensating controls.

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

1) Set the control boundary and control ownership

• Define the system boundary for IA-2: which platforms, apps, and environments are in-scope.
• Assign a control owner (often IAM lead, Security Engineering, or IT Ops) and a GRC owner accountable for evidence and audit response.
• Document the authoritative identity source (typically your IdP/directory) and exceptions.
  This directly supports audit readiness, and aligns with the recommended best practice to map IA-2 to an owner, procedure, and recurring evidence. ¹

2) Enforce unique identity (eliminate shared accounts by default)

• Require named accounts for workforce access.
• Identify shared/generic accounts (e.g., “admin,” “reception,” “nightops”) and decide:
  • Remove and replace with individual accounts, or
  • Treat as an exception with approvals, compensating controls, and monitoring.
• Ensure your joiner/mover/leaver process creates, updates, and disables accounts in a timely, auditable way.

Practical rule: if a user cannot be uniquely identified in logs and access reviews, IA-2 is not operating as intended. ¹

3) Standardize authentication paths (centralize to SSO where possible)

• Publish an authentication architecture:
  • Which apps must use SSO/IdP?
  • Which apps remain local-auth (and why)?
• For systems that cannot integrate with SSO, implement documented compensating controls (strong password policy, restricted network access, additional monitoring).

4) Require stronger authentication where risk justifies it (MFA and conditional access)

IA-2 does not prescribe a single mechanism in the excerpt provided, but assessors will still expect authentication strength aligned with system risk. Implement:

• MFA for privileged access and remote access paths.
• Conditional access controls (device posture, geo, impossible travel, risk-based prompts) where supported.
• Session controls (reauth for high-risk actions, step-up authentication).

Document your decision criteria so the program is defensible during assessment. ¹

5) Associate user identity with “processes acting on behalf of users”

This is the part teams miss. Build a pattern library for common scenarios:

Scenario A: Ticket-driven admin work

• Requirement: each privileged action maps back to the approving/requesting user.
• Implementation: ticket ID in change records; privileged session launched from a named admin account; logs link session to ticket and user.

Scenario B: CI/CD pipeline deployments

• Requirement: attribute deployment triggers to a user identity.
• Implementation: pipeline requires authenticated commits/approvals; deployment events include initiating user, approver, and build provenance.

Scenario C: RPA/bot actions

• Requirement: bot runs must be attributable to a human workflow.
• Implementation: bot identity is distinct (service account) plus workflow logging ties run to initiating user and approval.

Your evidence should show this association works end-to-end for representative workflows. ¹

6) Implement access logging that records the unique identity

IA-2 is hard to prove without logs. Confirm logs capture:

• Unique user identifier (immutable ID preferred)
• Timestamp, system, action/outcome
• Source (IP/device) where applicable
• Correlation IDs for workflows and service-mediated actions

Make sure logging is consistent across SSO, key apps, and privileged systems so you can reconstruct events.

7) Operationalize: monitoring, reviews, and exception handling

• Run periodic checks for:
  • accounts without owners,
  • dormant accounts,
  • shared accounts,
  • local users outside IdP.
• Maintain an exception register for any non-unique identities or alternate authentication methods, with compensating controls.

Where Daydream fits (without adding friction)

Most IA-2 programs fail on evidence consistency across teams. Daydream is typically introduced after the technical baseline exists to keep IA-2 mapped to an owner, a written procedure, and recurring evidence artifacts, so audits pull from a predictable package instead of Slack archaeology. ¹

Required evidence and artifacts to retain

Keep artifacts that prove both design and operation:

Policies and standards

• Identity & Access Management policy (unique accounts, authentication requirements)
• Authentication standard (SSO/MFA/conditional access requirements by system class)
• Exception process and risk acceptance template

Technical configurations (screenshots/exports)

• IdP/SSO configuration showing enforcement (MFA policy, conditional access rules)
• System configuration showing local-auth disabled where applicable
• Privileged access tooling configuration (if used)

Operational records (repeatable evidence)

• User provisioning/deprovisioning samples (joiner/mover/leaver tickets or HR-driven records)
• Access review outputs showing named users and approvals
• Authentication logs (SSO logs, VPN/ZTNA logs, admin console logs) that include unique IDs
• Workflow evidence for “processes acting on behalf of users” (ticket-to-session correlation, pipeline approvals, bot run audit trails)

Control mapping package (audit binder)

• IA-2 control narrative (what systems, what methods)
• Control owner, RACI, and cadence for evidence collection ¹

Common exam/audit questions and hangups

Expect these questions and prepare short, evidence-backed answers:

1. “Show me that every user is uniquely identified in System X.”
   Hangup: legacy apps with shared logins or local users.

2. “How do you authenticate admins vs standard users?”
   Hangup: admins authenticating with the same methods as low-risk users, without step-up controls.

3. “Prove that automated changes are attributable to an individual.”
   Hangup: pipelines or scripts run under a single service account without traceability to the triggering/approving user. ¹

4. “What are your exceptions, and who approved them?”
   Hangup: exceptions handled informally with no register.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails IA-2	Fix
Keeping shared accounts for convenience	Breaks unique identification and accountability	Replace with named accounts; treat remaining shared accounts as exceptions with compensating controls and monitoring. 1
“SSO for most apps” without proving coverage	Auditors test the outliers first	Maintain an app inventory with auth method, owner, and justification for non-SSO apps.
Service accounts used as a proxy for human identity	Loses association “on behalf of” a user	Add request/approval linkage and logs that tie the action back to a unique user. 1
No recurring evidence	Control exists only in theory	Define an evidence cadence and store exports/screenshots centrally under change control.

Enforcement context and risk implications

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

Risk-wise, IA-2 failures commonly lead to: inability to investigate incidents, weak non-repudiation, elevated insider risk, and broader access control failures because access decisions and audit trails depend on identity quality. ¹

Practical 30/60/90-day execution plan (without hard timelines)

Use phases rather than day counts for defensible planning across different org sizes.

Immediate phase (stabilize and define)

• Name the IA-2 control owner and GRC evidence owner. ¹
• Write the IA-2 control narrative: scope, identity source, authentication methods, and exception approach.
• Inventory in-scope systems and classify by authentication pattern (SSO, local, shared, service-mediated).

Near-term phase (fix high-risk gaps)

• Eliminate shared accounts in the highest-risk systems first (admin consoles, remote access, production).
• Turn on/enforce MFA and conditional access for privileged and remote access paths where supported.
• Implement traceability for “processes acting on behalf of users” in at least your top operational workflows (ticketing, CI/CD, RPA). ¹

Ongoing phase (make it auditable and repeatable)

• Establish recurring evidence collection: SSO policy exports, access review outputs, sample logs, exception register updates.
• Add automated checks for unmanaged/local accounts and authentication drift.
• Use Daydream to keep the owner/procedure/evidence mapping current, so assessments pull a consistent IA-2 package without scramble. ¹

Frequently Asked Questions

Does IA-2 prohibit all shared accounts?

IA-2 requires unique identification for organizational users, so shared accounts conflict with the core intent. If you keep a shared account for operational reasons, treat it as an exception with compensating controls and audit trails that restore accountability. ¹

Are service accounts “organizational users” under IA-2?

IA-2 explicitly covers “organizational users” and also requires association of user IDs with processes acting on behalf of users. Treat service accounts as controlled technical identities, and design logging so actions can be traced to the initiating/approving human where the process acts for a user. ¹

What does “associate that unique identification with processes acting on behalf of those users” mean in practice?

Your automation must carry or record the initiating user identity through the workflow. Common patterns include ticket correlation IDs, pipeline approval records, and workflow logs that map the automation run back to a named user. ¹

If we have SSO, are we automatically compliant with IA-2?

Not by itself. You still need to show unique identities, consistent authentication across the in-scope application inventory, and traceability for user-driven automation and service-mediated actions. ¹

How do we handle third-party administrators?

Provide them named organizational accounts or federated identities with unique IDs, and enforce the same authentication rules as your workforce for comparable risk. Document the access path and retain logs that tie activity to the individual. ¹

What evidence should we hand an auditor first for IA-2?

Start with your IA-2 control narrative and system inventory, then show IdP/SSO authentication policies, sample logs demonstrating unique IDs, and a workflow example where automation activity is tied back to a user identity. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5