IA-2(3): Local Access to Privileged Accounts

IA-2(3): Local Access to Privileged Accounts requires you to strongly authenticate and tightly control any local (console or non-network) logon to privileged accounts on systems, especially for admin, root, or equivalent roles. Operationalize it by inventorying privileged local accounts, eliminating shared/local admin where possible, enforcing MFA or equivalent compensating controls, and retaining evidence that controls work. ¹

Key takeaways:

• Treat “local privileged access” as a separate risk path from network logons; secure console and break-glass routes.
• Reduce or remove local privileged accounts first, then harden what remains with strong authentication and logging.
• Build an auditable evidence bundle: inventory, configuration baselines, exceptions, and test results. ²

Local privileged access is where your clean identity stack often stops. Even if SSO and MFA protect remote admin tools, many environments still have local “Administrator,” “root,” single-user mode, iLO/iDRAC-style console access, kiosk maintenance accounts, or break-glass credentials that bypass normal network authentication. IA-2(3) targets that gap: it focuses on local access to privileged accounts and expects you to prove that only authorized admins can use those accounts and that the access path is governed, monitored, and reviewable. ¹

For a CCO, compliance officer, or GRC lead, the fastest way to make IA-2(3) real is to convert it into a short control runbook: define scope (which systems and which accounts), set a standard (how local privileged access must work), implement technical enforcement (authentication, lockouts, credential protection, logging), and create a repeatable cadence for review and evidence collection. This page gives you requirement-level implementation guidance you can hand to IT, Security Engineering, and endpoint/server owners and then audit with confidence against the ia-2(3): local access to privileged accounts requirement. ²

Regulatory text

Requirement: “NIST SP 800-53 control IA-2.3.” This enhancement is labeled IA-2(3): Local Access to Privileged Accounts. ¹

What the operator must do: Implement identity and access controls specifically for local logons to privileged accounts. In practice, auditors will expect you to (1) identify where local privileged authentication exists, (2) enforce strong authentication or compensating safeguards for those access paths, (3) prevent shared/weak credentials from becoming an unmonitored backdoor, and (4) keep evidence that enforcement is consistent across in-scope systems. ²

Plain-English interpretation (what IA-2(3) is really asking)

IA-2(3) is about the “keyboard-and-screen” admin path and other non-network logons that can bypass centralized identity controls. If someone can sit at a device (or connect through a console channel) and sign in as admin/root, you must be able to answer, quickly and with evidence:

• Which privileged local accounts exist?
• Who is allowed to use them, and how do they authenticate?
• How do you prevent shared credentials, reused passwords, or dormant admin accounts?
• How do you detect and investigate local privileged logons? ¹

A practical mental model: treat local privileged access like a “break in case of emergency” route unless you can move it behind centralized privileged access management.

Who it applies to (entity + operational context)

Entities: Federal information systems and contractor systems handling federal data commonly inherit or map to NIST SP 800-53 requirements. ²

Operational scope (what systems are usually in play):

• Servers (Windows/Linux) with local admin/root access
• Endpoints with local administrator rights
• Network devices and appliances with console access
• Virtualization hosts and management consoles
• OT/ICS or embedded systems where local privileged accounts are common
• Cloud images and “golden” templates that ship with default local accounts ²

Trigger events that expand scope fast:

• M&A or inherited environments
• New build standards, image pipelines, or device fleet expansions
• Incident response where break-glass access is created ad hoc
• Third-party managed services requiring console/admin access ¹

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

Use this sequence to operationalize the ia-2(3): local access to privileged accounts requirement without turning it into a months-long policy rewrite.

Step 1: Define “local privileged access” for your environment

Write a one-page standard that answers:

• What counts as local (physical console, KVM, hypervisor console, single-user mode, out-of-band console channels).
• What counts as privileged (Administrator, root, sudoers, local “wheel,” device enable mode, application-level local superusers).
• Which systems are in scope (production first, then corp endpoints, then labs/dev as risk warrants). ²

Output: “IA-2(3) Local Privileged Access Standard” (short, testable statements).

Step 2: Inventory privileged local accounts and access paths

You need an inventory you can reconcile during an audit:

• List privileged local accounts per platform (Windows local admins; Linux root and sudoers; appliance console accounts).
• Identify which accounts are human-named vs shared vs service vs break-glass.
• Record where local logon is technically possible (console enabled, single-user mode, recovery mode, out-of-band management enabled). ¹

Operator tip: If you cannot produce this inventory, you will end up “arguing intentions” in an exam instead of showing control operation.

Step 3: Reduce the number of local privileged accounts (preferred control)

Before you add stronger authentication everywhere, remove what you can:

• Disable or rename default local admin accounts where supported.
• Replace shared local admin with named administrative identities.
• Restrict who can obtain local admin rights on endpoints; remove standing local admin where feasible.
• For third parties, require named accounts and time-bounded access requests rather than “vendoradmin” style accounts. ²

Goal: Shrink the attack surface so the remaining local privileged access is rare, deliberate, and monitored.

Step 4: Enforce strong authentication or compensating controls for local privileged logon

Local authentication often cannot use your SSO MFA directly. You still need strong assurance. Common patterns:

• Privileged access tooling: Require admins to check out credentials (or broker sessions) through PAM, then rotate frequently.
• Device-bound protections: Use OS features that protect local credential material and block offline credential theft.
• Console hardening: Require physical controls (locked racks, controlled rooms) plus technical controls (BIOS/bootloader passwords, disable external boot, secure boot) where local console is feasible.
• Break-glass controls: Store break-glass credentials in an approved vault, enforce approvals, and rotate immediately after use. ²

Your standard should be explicit about what you accept as “strong enough” for each platform class and what compensating controls apply when MFA is not technically possible.

Step 5: Add detective controls for local privileged access

IA-2(3) will be tested through “show me” evidence. Build logging that answers:

• Who performed a local privileged logon?
• From which system?
• When?
• Was it break-glass?
• Was it authorized and ticketed? ²

Minimum expectations in most audits:

• Centralize local security logs (endpoint/server) into your SIEM or log store.
• Alert on local admin/root logons outside maintenance windows or without an associated change/incident.
• Review exceptions and investigate anomalies. ¹

Step 6: Formalize exceptions and compensating controls

You will have legacy systems and appliances. Document:

• Why the system cannot meet the standard (technical constraint).
• Compensating controls (physical controls, tighter monitoring, reduced exposure, restricted console enablement).
• Expiration date and remediation plan.
• Approver (system owner + security). ²

Step 7: Create the control card and evidence bundle (make it auditable)

Turn the above into an operating control with:

• Owner: IAM or Security Engineering; operators: endpoint/server teams; oversight: GRC.
• Cadence: event-driven (new system, new image, new admin) plus periodic health checks.
• Testing method: sampling across platforms; confirm settings, accounts, vault records, and log events. ¹

If you use Daydream, capture this as a requirement control card with trigger events, execution steps, and exception rules, then attach the recurring evidence bundle so audits are retrieval work, not archaeology. ²

Required evidence and artifacts to retain

Store evidence in a single, named location per audit period. Auditors typically ask for artifacts that prove both design and operation.

Core evidence bundle (keep current):

• IA-2(3) control card / runbook (objective, scope, owners, cadence, testing steps). ¹
• Privileged local account inventory (exported reports or CMDB extracts).
• Configuration baselines (GPOs, MDM profiles, Linux hardening standards, appliance config snapshots) relevant to local privileged access.
• Access approval records for creation of privileged local accounts and for break-glass usage.
• Credential vault records (check-out logs, rotation records) for any shared or break-glass credentials.
• Log evidence: SIEM queries/dashboards showing local privileged logons and alert handling.
• Exception register with compensating controls and expiry. ²

Common exam/audit questions and hangups

Expect questions like:

• “Show me every local privileged account on these sampled systems.” If you cannot enumerate, you fail on controllability. ²
• “How do you stop a technician from using a shared local admin password?” Auditors want either elimination of shared creds or strong vaulting/rotation plus monitoring.
• “How do you know when local root was used on a server?” Logging and review discipline get tested.
• “What’s your break-glass process and when was it last used?” They will ask for the last usage record and the rotation proof after use. ¹
• “Which third parties have local privileged access?” Expect evidence of named identities, approvals, and scoped access.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Treating SSO+MFA for remote admin as “done”	IA-2(3) targets local paths that bypass SSO	Map and control console, local logon, and break-glass routes. 2
No authoritative account inventory	You cannot prove completeness	Build an inventory pipeline from endpoint/server tooling; reconcile regularly.
Shared local admin passwords without controls	High lateral movement risk; hard to attribute actions	Replace with named admin accounts or vault + rotation + strict monitoring.
“Exceptions forever”	Legacy becomes permanent noncompliance	Add expiry dates and migration plans; track to closure in a remediation register. 1
Logging exists but isn’t reviewed	You can’t prove operation	Document review steps, keep tickets, and retain query results/screenshots per cycle.

Enforcement context and risk implications

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

Risk-wise, local privileged access failures commonly create three problems you will have to explain to customers and assessors: (1) bypass of centralized MFA, (2) weak attribution due to shared accounts, and (3) limited visibility when incidents involve console access or offline credential attacks. IA-2(3) gives you a clean compliance driver to close those gaps with measurable controls and evidence. ²

Practical execution plan (30/60/90-day)

Use phases rather than calendar promises. Move in an order that produces audit-grade evidence early.

First 30 days (Immediate)

• Assign control owner and publish the IA-2(3) control card (scope, definitions, enforcement standard, exception path). ¹
• Identify top-risk platforms: domain controllers, critical servers, virtualization hosts, security tooling, and out-of-band consoles.
• Produce a first-pass inventory of privileged local accounts for those platforms.
• Define break-glass rules: who can approve, where credentials live, how rotation works, what must be logged. ²

By 60 days (Near-term)

• Remove shared local admin where feasible; shift to named admin identities.
• Implement vaulting/rotation for any remaining shared or break-glass credentials.
• Standardize logging and central collection for local privileged logon events on in-scope systems.
• Stand up exception register with compensating controls and expiry. ²

By 90 days (Operationalize and prove)

• Run a control health check: sample systems, validate configurations, reconcile inventory, and test alerting + investigation workflow.
• Package evidence for auditors: inventories, config baselines, vault logs, exception approvals, and review tickets.
• Add “new system / new image” triggers so IA-2(3) is enforced at build time, not retrofitted. ¹

Daydream fits naturally here as the system of record for the control card, evidence bundle, and remediation tracking, so you can show sustained operation without chasing screenshots across teams. ²

Frequently Asked Questions

Does IA-2(3) apply to cloud workloads if we don’t “log on locally”?

Yes if you have a console-equivalent path or local privileged credentials on the instance or image. Treat cloud serial consoles, rescue modes, and break-glass keys as local privileged access paths. ²

Are shared local admin accounts automatically noncompliant?

The requirement focuses on controlling and authenticating local privileged access; shared accounts create attribution and control gaps. If you must keep one, vault it, rotate it, and monitor every use with approvals and logs. ²

What counts as “privileged” for IA-2(3)?

Administrator/root equivalents, accounts with sudo/wheel membership, and device or application superusers that can change security settings or access protected data. Define this clearly in your IA-2(3) standard and apply it consistently. ¹

How do we handle appliances where MFA for local console is impossible?

Use compensating controls: tightly control physical and out-of-band access, store console credentials in a vault, rotate after use, and centralize logs or retain tamper-evident access records. Document the exception with an expiry and a plan. ²

What evidence is most persuasive in an audit?

A complete inventory, enforced configuration baselines, vault check-out and rotation logs for privileged local credentials, and SIEM evidence showing detection and follow-up on privileged local logons. Package it per period so sampling is fast. ²

Who should own IA-2(3): IAM, endpoint/server teams, or GRC?

Put technical ownership in IAM or Security Engineering, with endpoint/server teams responsible for implementation on their platforms and GRC responsible for testing and evidence. One accountable owner prevents “everyone and no one” ownership. ²

Footnotes

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

2. NIST SP 800-53 Rev. 5