IA-5(6): Protection of Authenticators

IA-5(6) requires you to protect every authenticator (passwords, private keys, MFA seeds/tokens, API keys, recovery codes) at a level that matches the impact of the data and systems it can access. Operationally, you do this by classifying authenticator risk by system, locking down storage and handling paths, and retaining evidence that controls work in production. 1

Key takeaways:

  • Treat authenticators as high-value secrets; protect them based on what they unlock, not what they are.
  • Control the full lifecycle: issuance, storage, transmission, use, rotation, revocation, and destruction.
  • Keep assessor-ready evidence: configuration exports, key vault policies, access logs, and procedures mapped to owners. 2

Footnotes

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

  2. NIST SP 800-53 Rev. 5

The ia-5(6): protection of authenticators requirement is simple to read and easy to fail in practice: “protect authenticators commensurate with the security category of the information to which use of the authenticator permits access.” 1 If an authenticator can access a high-impact system, that authenticator must be protected like a high-impact asset, even if it “looks small” (an API key in a CI/CD variable, a break-glass password in a wiki, a private key in a home directory).

CCOs and GRC leads typically get pulled into IA-5(6) during ATO work, FedRAMP-aligned audits, or customer due diligence for federal data handling. The fastest path to operationalization is to (1) inventory authenticators and their storage locations, (2) tie each to the highest-impact system it can reach, (3) enforce technical controls for storage/handling, and (4) produce durable evidence that those controls are consistently applied.

This page translates IA-5(6) into an implementable checklist, evidence plan, and audit script you can run with IAM, Security Engineering, and Platform teams.

Regulatory text

Requirement (verbatim): “Protect authenticators commensurate with the security category of the information to which use of the authenticator permits access.” 1

Operator translation:
You must protect each authenticator according to the highest sensitivity/impact of the systems and data it can access. If an API token can read federal data, you protect that token as though it is the data path itself: strong storage controls, tight access, secure distribution, monitored use, and fast revocation. 2

Plain-English interpretation (what assessors mean by “protect”)

Assessors usually test “protection” across the authenticator lifecycle:

  • Creation/issuance: Who can mint credentials, keys, tokens, or MFA factors, and under what approvals.
  • Storage: Where the secret lives (vault, HSM, password manager, device secure enclave) and who can retrieve it.
  • Transmission/distribution: How it is delivered to a user, admin, service, or third party without exposing it.
  • Use: Whether it is used only by intended identities and only from approved contexts.
  • Rotation and revocation: Whether you can rotate quickly, invalidate immediately, and prove it happened.
  • Disposal: Whether old authenticators are destroyed or rendered unusable.

“Commensurate with the security category” means your controls cannot be “one size fits all.” A developer token for a low-impact sandbox does not need the same handling as a privileged credential for production systems with regulated data, but you must show you made that distinction intentionally and implemented it. 1

Who it applies to

Entities: Federal information systems and contractor systems handling federal data. 1

Operational contexts where IA-5(6) shows up:

  • Privileged access management: admin passwords, break-glass accounts, SSH keys, PIV/CAC-derived credentials.
  • Workforce IAM: MFA secrets, password hashes, recovery codes, device-bound credentials.
  • Machine identities: service accounts, workload identity tokens, API keys, signing keys, TLS private keys.
  • CI/CD and automation: pipeline secrets, deploy keys, IaC credentials, artifact signing keys.
  • Third party access: support portals, SSO/SAML/OIDC integrations, shared admin consoles, contractor credentials.

If your environment touches federal data, IA-5(6) becomes a practical requirement for secret management, PAM, and audit logging across both human and machine identity.

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

Use this as an execution runbook you can assign to control owners.

Step 1: Define “authenticator” for your environment

Create a scoped list that includes at minimum:

  • Passwords (including break-glass and shared accounts where they still exist)
  • Private keys (SSH, TLS, code signing)
  • API keys and access tokens (including long-lived tokens)
  • MFA seeds, hardware tokens, and recovery codes
  • Secrets used by automation (CI/CD variables, config files, container secrets)

Your policy should explicitly state that these items are authenticators subject to IA-5(6). 2

Step 2: Map authenticators to the highest-impact system they can access

Build a simple mapping table:

Authenticator type Where it’s stored What it can access Highest impact category of that target Required protection level

You do not need a perfect model on day one. You need a defensible mapping that shows you tied protection to the risk of what the authenticator unlocks. 1

Step 3: Set minimum protection standards by “protection level”

Define protection tiers aligned to your system categorization. Common implementation pattern:

  • High-impact access authenticators: must be in an enterprise secret store (vault/HSM-backed where appropriate), encrypted at rest, access controlled via least privilege, protected by MFA for retrieval where feasible, and fully logged.
  • Moderate-impact access authenticators: same pattern, with controlled exceptions where risk is demonstrably lower.
  • Low-impact access authenticators: still protected, but with lighter operational burden.

IA-5(6) does not tell you which tool to buy; it requires that the protection matches the security category. Your job is to make that mapping explicit and enforceable. 1

Step 4: Lock down storage and handling paths (technical controls)

Implement controls that auditors can verify:

  1. Centralize secrets in approved systems (vault, password manager, HSM-backed key management) and prohibit storage in wikis, tickets, chat, repo files, or “temporary” notes.
  2. Encrypt at rest and in transit for secret storage and retrieval paths (your evidence will be configs and architecture diagrams, not promises).
  3. Restrict access by role: separate “can read secret” from “can administer vault,” and enforce approvals for high-impact secret access.
  4. Require strong authentication to retrieve secrets (MFA for humans; workload identity for machines).
  5. Log and monitor secret access: who accessed what, when, from where; alert on anomalous access patterns.
  6. Prevent secret exfiltration in SDLC: scanning for committed secrets and blocking merges when secrets are detected.
  7. Harden endpoints that store authenticators (admin workstations, build agents) since local storage can become a bypass.

Step 5: Make rotation and revocation real (and provable)

Document and implement:

  • Triggers for rotation (compromise suspicion, role change, third party offboarding, periodic hygiene)
  • Emergency revocation path for privileged and high-impact authenticators
  • Ownership and on-call routing for after-hours credential invalidation

Assessors will ask how fast you can revoke and whether you have exercised the process. Keep at least one completed rotation/revocation record as evidence. 2

Step 6: Address third party authenticators explicitly

Third parties introduce hard-to-see authenticator sprawl: shared admin console credentials, API tokens issued to integrators, and support access accounts.

Minimum expectations:

  • Issue third party credentials as unique, attributable identities (no shared logins where avoidable).
  • Put third party tokens and credentials under the same storage/monitoring standards as internal ones.
  • Revoke promptly on contract end and when personnel change is reported.

Step 7: Map to an owner, procedure, and recurring evidence

Turn IA-5(6) into an owned control with a measurable operating rhythm:

  • Control owner: IAM lead or Security Engineering (with Platform as implementer)
  • Procedure: “Authenticator Protection Standard” plus “Secrets Handling SOP”
  • Evidence cadence: configuration exports and access logs on a recurring schedule

This is the fastest way to reduce the most common risk factor: missing implementation evidence. 1

Where Daydream fits naturally: Daydream helps you assign IA-5(6) ownership, document the implementation procedure at requirement level, and collect recurring evidence artifacts so audits stop depending on tribal knowledge.

Required evidence and artifacts to retain

Keep evidence that proves both design and operation:

Design evidence

  • Authenticator Protection Standard (policy/standard) mapped to system impact categories 1
  • Secrets management architecture diagram (vault/HSM/IDP flows)
  • Dataflow notes for secret distribution (CI/CD, runtime, admin access)

Operating evidence

  • Vault or secret store configuration exports (encryption settings, access policies, auth methods)
  • Access logs for secret retrieval and administrative changes
  • Samples of rotation and revocation tickets/records (redacted)
  • CI/CD configuration showing secrets are injected at runtime rather than stored in code
  • Exception register for any authenticators not meeting the target protection level, with compensating controls and expiry

Common exam/audit questions and hangups

Expect these questions, and prepare answers plus artifacts:

  1. “Show me where high-impact authenticators are stored.”
    Have a system list and vault inventory ready.

  2. “How do you prevent credentials in source control and tickets?”
    Provide SDLC controls, scanning output, and developer SOPs.

  3. “Who can access break-glass credentials, and how is it logged?”
    Provide PAM/vault policy and example access log entries.

  4. “How do you protect machine-to-machine secrets in production?”
    Show workload identity patterns, short-lived tokens where applicable, and runtime secret injection.

  5. “How do you handle third party access and offboarding?”
    Provide third party access procedure, revocation evidence, and identity attribution.

A recurring hangup: teams show a policy but cannot produce logs, configs, or completed rotation records. IA-5(6) is assessed as an operational control, not a document-only control. 2

Frequent implementation mistakes (and how to avoid them)

Mistake 1: Treating “password policy” as coverage for all authenticators.
Fix: explicitly include tokens, keys, MFA seeds, and automation secrets in scope, then show storage and logging for each category.

Mistake 2: Protecting the vault but ignoring endpoints.
Fix: harden admin workstations and build agents, and prohibit local long-term storage of production credentials.

Mistake 3: Shared credentials for third parties and support.
Fix: require unique accounts, time-bound access, and auditable actions tied to individuals.

Mistake 4: No exception process.
Fix: build an exception register with risk acceptance, compensating controls, and an expiry date so deviations do not become permanent.

Mistake 5: Evidence gaps.
Fix: schedule recurring evidence capture (configs + access logs). Daydream can automate the mapping and evidence requests so collection is consistent.

Risk implications (why IA-5(6) fails become incidents)

Authenticators are often the shortest path to privilege escalation and data access. If a high-impact token is stored in a repo, a ticket, or a shared drive, you create an unmonitored backdoor into regulated systems. The control reduces the probability that one compromised workstation, one over-permissioned admin, or one third party breach turns into broad system access. 1

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

First 30 days (Immediate stabilization)

  • Assign a control owner and publish an Authenticator Protection Standard mapped to system impact categories. 1
  • Inventory authenticators and storage locations for your highest-impact systems first (PAM, production cloud accounts, CI/CD deploy credentials).
  • Freeze unsafe patterns: block secrets in repos/tickets/chat through policy and SDLC guardrails.

Next 60 days (Implement and prove)

  • Centralize high-impact authenticators into approved storage (vault/password manager/HSM-backed as appropriate).
  • Enforce least privilege and strong authentication to retrieve secrets; enable logging and monitoring for access.
  • Run at least one rotation/revocation exercise for a privileged credential path and retain the record.

By 90 days (Operationalize and audit-ready)

  • Expand coverage to moderate-impact systems and machine identity sprawl (service accounts, integration tokens).
  • Stand up an exception register with approvals and expirations.
  • Build an assessor packet: mappings, configs, sample logs, and rotation evidence. Use Daydream to keep ownership, procedures, and recurring evidence aligned so the control stays in an “always ready” state.

Frequently Asked Questions

Does IA-5(6) apply to API keys and service account tokens, or only user passwords?

It applies to authenticators broadly, including machine credentials, because the requirement is tied to “use of the authenticator” permitting access to information. Protect tokens and keys based on the impact of the systems and data they can reach. 1

What does “commensurate with the security category” mean in practice?

Classify the systems/data the authenticator can access, then set protection tiers so higher-impact access authenticators get stronger storage, tighter access control, and better monitoring. Document the mapping so an assessor can follow your logic. 2

Is storing secrets in a CI/CD tool acceptable under IA-5(6)?

It can be, if the CI/CD secret storage meets your protection tier for the target systems (encryption, access control, strong authentication, and logging). Keep configuration evidence showing those protections are enabled. 1

How should we handle break-glass credentials?

Treat them as high-impact authenticators: store them in an approved system with strict access controls, require documented approval for retrieval, and retain access logs. Test the emergency access path so you can prove it works and is monitored. 2

What evidence is most persuasive to auditors for IA-5(6)?

Configuration exports from the system that stores authenticators, access logs showing retrieval events, and a completed rotation or revocation record. Pair that with a written standard that maps protection levels to system impact. 1

We have legacy apps with hardcoded credentials. What’s the least-bad approach?

Put the issue into a tracked exception with compensating controls (segmentation, limited scope credentials, enhanced monitoring) and a migration plan to move secrets into approved storage. Auditors react better to controlled exceptions than to hidden drift. 2

Footnotes

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

  2. NIST SP 800-53 Rev. 5

Frequently Asked Questions

Does IA-5(6) apply to API keys and service account tokens, or only user passwords?

It applies to authenticators broadly, including machine credentials, because the requirement is tied to “use of the authenticator” permitting access to information. Protect tokens and keys based on the impact of the systems and data they can reach. (Source: NIST SP 800-53 Rev. 5 OSCAL JSON)

What does “commensurate with the security category” mean in practice?

Classify the systems/data the authenticator can access, then set protection tiers so higher-impact access authenticators get stronger storage, tighter access control, and better monitoring. Document the mapping so an assessor can follow your logic. (Source: NIST SP 800-53 Rev. 5)

Is storing secrets in a CI/CD tool acceptable under IA-5(6)?

It can be, if the CI/CD secret storage meets your protection tier for the target systems (encryption, access control, strong authentication, and logging). Keep configuration evidence showing those protections are enabled. (Source: NIST SP 800-53 Rev. 5 OSCAL JSON)

How should we handle break-glass credentials?

Treat them as high-impact authenticators: store them in an approved system with strict access controls, require documented approval for retrieval, and retain access logs. Test the emergency access path so you can prove it works and is monitored. (Source: NIST SP 800-53 Rev. 5)

What evidence is most persuasive to auditors for IA-5(6)?

Configuration exports from the system that stores authenticators, access logs showing retrieval events, and a completed rotation or revocation record. Pair that with a written standard that maps protection levels to system impact. (Source: NIST SP 800-53 Rev. 5 OSCAL JSON)

We have legacy apps with hardcoded credentials. What’s the least-bad approach?

Put the issue into a tracked exception with compensating controls (segmentation, limited scope credentials, enhanced monitoring) and a migration plan to move secrets into approved storage. Auditors react better to controlled exceptions than to hidden drift. (Source: NIST SP 800-53 Rev. 5)

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