IA-12(3): Identity Evidence Validation and Verification

IA-12(3): identity evidence validation and verification requirement means you must validate and verify the identity documents (or other evidence) a person presents during identity proofing, using defined methods your program selects and documents. To operationalize it fast, define acceptable evidence, specify validation/verification checks, integrate them into onboarding workflows, and retain auditable proof the checks ran. ¹

Key takeaways:

• Define “identity evidence” and harden your evidence acceptance rules, including exceptions and who can approve them.
• Implement two layers of checks: evidence validity (authenticity) and evidence-to-person verification (right person).
• Keep audit-ready artifacts: procedures, system configs, transaction logs, and sampled proofing packets. ¹

IA-12(3) sits inside NIST SP 800-53’s Identity and Authentication family and focuses on a specific operational point that often fails in practice: you can’t claim identity proofing unless you can show that the identity evidence presented was validated and verified using defined methods. The control enhancement is short, but it drives real implementation decisions: what evidence you accept, what checks you perform, what you do when checks fail, and what you retain for assessors.

For a CCO, Compliance Officer, or GRC lead, the fastest path is to treat IA-12(3) as a “proofing transaction control.” Every onboarding or identity proofing event should produce a consistent proofing packet: evidence types, checks performed, results, reviewer actions (if manual), and system logs tying the outcome to an issued identity credential or account. Where teams get stuck is ambiguity around the control’s parameter (“through {{ insert: param, ia-12.03_odp }}”), which you must define in your organization’s control implementation statement and procedures. ^{1 2}

What IA-12(3) requires (plain English)

You must require that any identity evidence presented during identity proofing is (1) validated and (2) verified using organization-defined methods.

• Validated: checks that the evidence itself is legitimate and unaltered (for example, document authenticity checks).
• Verified: checks that the evidence actually corresponds to the person being proofed (for example, matching biographic data and/or confirming the presenter is the rightful subject of the evidence).

The control text is explicit that your organization defines the method(s) via a parameter (“ia-12.03_odp”). Assessors will look for a documented, repeatable approach and proof that it is followed. ¹

Regulatory text

“Require that the presented identity evidence be validated and verified through {{ insert: param, ia-12.03_odp }}.” ¹

Operator translation (what you must do):

1. Define the “through …” methods in your control implementation (the parameter): which validation and verification checks you will use, for which populations, and under what conditions.
2. Make the checks mandatory in workflows that issue accounts/credentials after identity proofing.
3. Produce evidence that the checks occurred (logs, proofing packets, workflow records) and that exceptions are controlled.

Who it applies to

Entity scope

• Federal information systems.
• Contractor systems handling federal data. ¹

Operational scope (where the control shows up)

• New hire/contractor onboarding where an enterprise account is issued.
• Privileged access provisioning (admins, cloud console users, break-glass accounts).
• External user identity proofing for citizen/customer portals where stronger identity assurance is required.
• Third-party workforce (staff augmentation, BPO) where identities are proofed outside your HR process but still receive access.

Systems/processes typically in scope

• IAM/IdP enrollment workflows
• HRIS-driven identity lifecycle (joiner/mover/leaver)
• Identity proofing services (internal or third party)
• Help desk processes that “upgrade” identity strength or reset proofing factors

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

Step 1: Define your evidence policy (what is acceptable)

Create an “Identity Evidence Acceptance Standard” that specifies:

• Accepted evidence types (documents, authoritative records, digital identity evidence).
• Minimum evidence combinations by population (employee vs contractor vs external user) and by risk tier (standard vs privileged).
• Unacceptable evidence (expired documents, screenshots, photocopies if not allowed).
• Exception process (who can approve, required compensating checks, documentation required).

This is where you fill in the control parameter in a way your organization can execute and audit. ¹

Step 2: Separate “validation” checks from “verification” checks

Build a simple control matrix so engineering and operations teams implement the right checks:

Control objective	What it means	Examples of checks (your org defines)	Where performed
Evidence validation	Evidence is authentic and unaltered	Document authenticity checks; tamper detection; expiry checks	Proofing tool, manual review, or third party
Evidence verification	Evidence belongs to the applicant	Data consistency checks; linkage to person record; reviewer confirmation	Proofing workflow, HR/IAM reconciliation

Assessors commonly ask you to show both objectives are met, not just “we collected a scan.” ¹

Step 3: Embed checks into issuance workflows (make it hard to bypass)

Update workflows so accounts/credentials cannot be issued unless:

• Evidence artifacts are captured (or authoritative pointers are recorded).
• Validation/verification checks run and return “pass” (or “pass with exception” via approvals).
• The proofing transaction is linked to the unique identity record in IAM (person ID) and the resulting account.

Practical pattern: add a “Proofing Status” gate in the joiner workflow, and require “Verified” before group membership for privileged roles is granted.

Step 4: Define failure handling and escalation

Document operational handling for:

• Failed validation (suspected fraudulent/altered evidence): stop onboarding, route to security/HR, record outcome.
• Failed verification (evidence doesn’t match applicant): require re-submission, secondary review, or alternative proofing path.
• Inconclusive checks (system outage, unreadable evidence): use a controlled exception with compensating measures and time-bound follow-up.

Make sure exceptions are logged and reviewable, because exceptions become the de facto process under pressure.

Step 5: Clarify third-party responsibilities (if you outsource proofing)

If a third party performs evidence checks:

• Contractually require the third party to perform the validation/verification methods you define.
• Obtain right-to-audit language or standardized reports plus transaction-level evidence on request.
• Ensure your IAM team receives proofing outcomes in a tamper-evident way (API events, signed assertions, or immutable logs).

This is where many programs fail: the third party says “verified,” but you can’t show the underlying checks or retain proof.

Step 6: Instrument logs and build an audit-ready sampling approach

Set up:

• Event logging for proofing steps (who/what/when/outcome).
• Storage controls for evidence artifacts (encryption, access controls, retention rules).
• A sampling method for periodic QA: select proofing transactions, confirm artifacts exist, confirm the checks match policy, confirm exceptions are approved.

Step 7: Map ownership and recurring evidence

Assign:

• Control owner (policy + audit response)
• Process owner (onboarding/proofing operations)
• System owner (IAM/proofing platform)
• Evidence owner (records management / security operations)

Then publish what evidence is produced monthly/quarterly so audits don’t become a scramble. ¹

Required evidence and artifacts to retain (audit-ready)

Maintain a tight evidence list that matches the control language:

Governance artifacts

• IA-12(3) control implementation statement that defines the parameterized methods (“through …”) ¹
• Identity Evidence Acceptance Standard (accepted evidence, exceptions, approvals)
• Proofing procedure / runbook (manual + automated steps)
• Roles and responsibilities (RACI) for proofing reviewers and approvers

Operational artifacts

• Proofing workflow configuration screenshots/exports (gates, required fields, decision points)
• Proofing transaction logs ¹
• Exception tickets/approvals with rationale and compensating controls
• QA sampling results and remediation tickets

Third-party artifacts (if applicable)

• Contract/SOW clauses requiring evidence validation and verification methods
• Third-party proofing reports or transaction attestations, plus escalation SLAs
• Integration logs showing proofing outcome ingested into IAM

Common exam/audit questions and hangups

Expect questions like:

• “Show me where you define the ‘through …’ methods for IA-12(3).” ¹
• “Demonstrate that an account cannot be issued before evidence is validated and verified.”
• “Provide a sample of proofing transactions and show evidence checks and outcomes.”
• “How do you control and review exceptions?”
• “If a third party performs proofing, how do you validate their controls and retain evidence?”

Hangups that trigger findings:

• Policy exists, but workflow allows issuance without proofing status.
• Logs exist, but they don’t show what checks ran (only “approved”).
• Exceptions are handled in chat/email with no formal record.

Frequent implementation mistakes (and how to avoid them)

1. Collecting evidence without validating it. Fix: document specific validation checks and require recorded outcomes per check.
2. Treating verification as “HR said so.” Fix: define what verification means in your context and require evidence-to-person linkage in the proofing packet.
3. No parameter definition. Fix: write the organization-defined methods into the control implementation statement and supporting standards. ¹
4. Over-reliance on third-party “black box” proofing. Fix: contract for auditable outputs and maintain transaction-level traceability.
5. Retention chaos. Fix: establish where artifacts live, who can access them, and how long you keep them based on internal policy.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. The risk is still practical and immediate: weak evidence validation/verification creates account issuance errors, raises the chance of fraudulent enrollment, and undermines downstream access controls because all access decisions depend on the identity record. ²

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

Use phases rather than fixed-duration claims tied to outcomes.

First 30 days (Immediate): define and gate

• Name the control owner and process owner.
• Write the “through …” methods for IA-12(3) in your control implementation statement. ¹
• Publish the Identity Evidence Acceptance Standard and exception path.
• Add a hard gate in onboarding/provisioning: no issuance without proofing status.

Next 60 days (Near-term): implement evidence and logging

• Implement validation and verification checks in tooling (internal or third party) and document them.
• Standardize proofing packet fields and required artifacts.
• Turn on logging, route to your SIEM or audit log store, and test retrieval.
• Run a QA sampling cycle and remediate workflow gaps.

Next 90 days (Stabilize): operationalize and assess

• Train help desk, HR onboarding, and IAM admins on failure handling and exception approvals.
• Add periodic exception review and QA sampling to your compliance calendar.
• Perform an internal readiness review: pull a sample of proofing transactions and walk them end-to-end like an assessor.

Where Daydream fits naturally: Daydream helps you map IA-12(3) to a control owner, a documented procedure, and recurring evidence artifacts so you can answer assessor requests with a consistent packet instead of rebuilding proof every audit cycle. ¹

Frequently Asked Questions

What counts as “identity evidence” for IA-12(3)?

Your program defines it, but it generally means documents or records presented to prove someone’s identity during proofing. Document the accepted types and the required checks in your “through …” methods. ¹

Do we need both validation and verification, or is one enough?

IA-12(3) requires both. Validation addresses evidence authenticity; verification addresses whether the evidence corresponds to the applicant. ¹

Can a third party perform evidence validation and verification on our behalf?

Yes, but you still need to require the methods and retain auditable proof of outcomes. Put the requirements in the contract and ensure your IAM system stores the proofing result with traceability.

What evidence will auditors ask for first?

They usually start with your defined methods (“through …”), then ask for proofing workflow gates, then request a sample of proofing transactions with logs and exception approvals. ¹

How do we handle remote onboarding where we can’t physically inspect documents?

Treat it as a workflow design problem: define which remote evidence types you accept, what validation checks you require, and how you verify the presenter. Document the method and retain proofing packets for each transaction. ¹

We already do MFA. Does that satisfy IA-12(3)?

No. MFA strengthens authentication after an account exists; IA-12(3) focuses on validating and verifying identity evidence during proofing before or while issuing identity credentials. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5