MA-3(5): Execution with Privilege
MA-3(5): Execution with Privilege requires you to monitor any maintenance tool activity that runs with elevated privileges (admin/root/SYSTEM), so you can detect misuse, validate authorization, and investigate quickly. Operationalize it by inventorying privileged maintenance tools, defining “privileged execution” events, logging them centrally, and reviewing alerts and exceptions on a defined cadence. 1
Key takeaways:
- Scope the control to “maintenance tools” that can run elevated (remote support, patching, RMM, scripting, imaging, diagnostics).
- Collect and review privileged execution telemetry (who/what/where/when, approvals, target systems, outcomes).
- Prove it in an audit with repeatable evidence: tool inventory, log sources, alert rules, review records, and exception handling.
MA-3(5): execution with privilege requirement is one of those controls auditors read literally: if a maintenance tool can run with increased privilege, you must monitor its use. This is not a “have a policy” requirement. It’s an operational requirement that depends on telemetry and review discipline.
For most environments, the hard part is scoping. Maintenance tooling spans internal IT operations (endpoint management, patching, imaging), security operations (EDR response tooling), and third-party access (remote support utilities, managed service provider tools). Many of these tools run as agents with SYSTEM/root privileges or can execute privileged scripts remotely. That capability is exactly why they are high-risk: if compromised or misused, they can bypass normal user controls and deploy code broadly.
This page gives you requirement-level implementation guidance you can execute fast: define what counts as a “maintenance tool,” decide which privileged actions must generate logs, centralize the right events, and set up review and escalation so you can show ongoing monitoring with retained evidence. The goal is simple: make privileged maintenance execution observable, attributable, and reviewable. 2
Regulatory text
Requirement excerpt: “Monitor the use of maintenance tools that execute with increased privilege.” 1
Operator interpretation (what you must do):
- Identify maintenance tools in your environment that can run elevated (directly or via agents/services).
- Instrument monitoring so you can see and reconstruct privileged activity initiated by those tools.
- Review and respond to the monitoring output (alerts, reports, exceptions) as an ongoing control, not a one-time setup.
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Plain-English interpretation
If a tool can perform maintenance actions as admin/root/SYSTEM (install software, change configs, run scripts, create accounts, disable security controls, access protected files), you need visibility into when it is used, by whom, on which systems, and with what result. Monitoring should be strong enough to spot unauthorized use and to support an investigation without guesswork. 1
Who it applies to
Entity scope
- Federal information systems implementing NIST SP 800-53 controls.
- Contractor systems handling federal data where NIST SP 800-53 is a contractual or program requirement.
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Operational context (where it shows up in real life)
This control usually lands with a shared set of owners:
- IT Operations / Endpoint Engineering: patching tools, endpoint management, software distribution, imaging.
- Infrastructure / Cloud Ops: automation pipelines, configuration management, privileged orchestration.
- Security Operations: EDR response actions, remote containment scripts, forensic tooling.
- Third-party access management: MSP/RMM tools, remote support sessions, break-glass maintenance.
A practical scoping rule: if the tool can push changes at scale or runs as a privileged service, assume it is in scope until you can justify otherwise.
What you actually need to do (step-by-step)
Step 1: Build the “privileged maintenance tool” inventory
Create a single list with, at minimum:
- Tool name and purpose (e.g., endpoint patching, remote support)
- Deployment model (agent, SaaS, on-prem, script)
- How it gets privilege (local SYSTEM service, sudo, domain admin creds, cloud role)
- Who can operate it (roles/groups, third party accounts)
- Systems in scope (servers, endpoints, network devices, cloud resources)
- Primary log sources available (tool audit log, OS logs, EDR telemetry, cloud audit logs)
Include third party tooling explicitly. A common audit failure is treating MSP tooling as “their problem” while it operates inside your environment.
Step 2: Define what “execution with increased privilege” means for your environment
Write a short, testable definition you can hand to engineers and auditors. Examples of privileged execution events to monitor:
- Remote commands/scripts run as admin/root/SYSTEM
- Package installs/uninstalls initiated by the tool
- Configuration changes to security settings (firewall, logging, EDR policy)
- Credential-related actions (creating accounts, changing group membership)
- Service creation/modification
- Tool-side actions that grant access (adding technicians/operators)
Your definition should map to concrete event types you can collect.
Step 3: Turn on logging at the tool and at the target system
You want two perspectives:
- Tool audit logs (who initiated the action in the tool console/API, what action was requested, and which targets were selected)
- Target system telemetry (what actually executed, under what account, with what outcome)
Minimum fields to capture:
- Initiating identity (user/service account/API token)
- Target asset(s)
- Timestamp (with time sync)
- Privileged context (admin/root/SYSTEM, role assumed)
- Action details (command/script/package/config changed)
- Result status (success/fail) and error output when available
Route logs to a central repository (SIEM/log platform) with retention aligned to your broader logging standard. The control does not prescribe retention length, but auditors will expect you to retain enough to support investigations and show ongoing operation.
Step 4: Create detections and “reviewable” reports
Monitoring must be actionable. Build a small set of detections and reviews that map to real abuse cases:
- Privileged maintenance action outside approved change windows (where applicable)
- Privileged tool use by unexpected identities (new operator, dormant account, non-privileged group)
- High-risk actions (disable security tool, mass deployment, new privileged account)
- Use from unusual source locations (new IP ranges, third party network not allowlisted)
- Failed privileged actions followed by success (possible trial-and-error)
Pair alerts with a routine report:
- Weekly or periodic summary of privileged maintenance executions by tool, operator, and target scope
- Exception list (approved emergency actions, break-glass)
Step 5: Establish authorization and exception handling
MA-3(5) says “monitor,” but audits typically test whether monitoring ties back to authorization:
- Link privileged maintenance executions to approved changes (tickets) where your change management requires it.
- Define “emergency maintenance” rules: who can approve, how it’s documented after the fact, and how it is reviewed.
Keep this lightweight. The goal is traceability, not bureaucracy.
Step 6: Run the control as a recurring operational process
Assign a control owner and make reviews routine:
- A named team reviews alerts and the periodic report.
- Escalation paths exist for suspected misuse (SOC, IT leadership, incident response).
- Metrics are optional, but a reviewer sign-off record is not. Auditors want proof that humans looked.
Daydream fit (where it earns its place): Daydream is useful as the system of record to map MA-3(5) to a control owner, a written procedure, and the exact recurring evidence artifacts you collect each cycle, so you can answer audits without rebuilding the story from log screenshots every time.
Required evidence and artifacts to retain
Use an evidence list that mirrors your steps:
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Scope & ownership
- Control statement for MA-3(5)
- Control owner assignment (RACI or equivalent)
- In-scope privileged maintenance tool inventory (dated)
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Configuration proof
- Tool logging configuration screenshots/exports
- SIEM/log pipeline configuration references (data sources enabled)
- Time sync/clock source reference (if part of your broader logging controls)
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Monitoring operation
- Alert rule definitions (queries, thresholds, severities)
- Sample alerts/incidents showing triage and closure
- Periodic review reports and reviewer attestations (date, name, findings)
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Authorization linkage
- Example change tickets mapped to privileged maintenance actions
- Exception approvals (break-glass records, emergency change logs)
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Third party coverage
- Third party access list for maintenance tools
- Contractual/security addendum language summary (if available internally)
- Evidence that third party activity is logged and reviewed the same way
Common exam/audit questions and hangups
Auditors tend to ask variations of these:
- “Show me all maintenance tools that run as SYSTEM/root.” If you can’t produce a complete inventory, you lose on scope before you start.
- “How do you know the tool wasn’t used to deploy malware?” They want detections for mass changes and suspicious execution patterns.
- “Can you attribute actions to a person?” Shared accounts and generic “tech1” logins are a common failure.
- “Do you monitor third party maintenance sessions?” “We trust our MSP” is not an answer; the tool activity still occurs in your environment.
- “Show ongoing operation.” A one-time screenshot of logging enabled is weak without recurring review records.
Frequent implementation mistakes (and how to avoid them)
| Mistake | Why it fails | Avoid it by |
|---|---|---|
| Inventory stops at “IT-managed tools” | Privileged maintenance often happens via security tools and third parties | Include RMM, remote support, EDR response actions, cloud automation |
| Only collecting tool console logs | Console logs can miss what ran on the host | Pair tool logs with endpoint/server audit telemetry |
| Shared operator accounts | Breaks attribution | Require named accounts + MFA; restrict and monitor service accounts |
| Alerts without review | “Monitoring” becomes theoretical | Create a scheduled review with sign-offs and ticketing linkage |
| No exception path | Teams bypass process under pressure | Define emergency maintenance workflow and after-action review |
Enforcement context and risk implications
No public enforcement cases were provided for this specific requirement in the source data. Practically, MA-3(5) is assessed as part of overall privileged activity governance. Failures increase blast radius risk: a compromised maintenance tool account can enable widespread, privileged execution across many endpoints or servers, and weak logging slows containment and root-cause analysis. 2
Practical 30/60/90-day execution plan
First 30 days (stabilize scope + telemetry)
- Assign a control owner and name engineering counterparts for each tool family.
- Produce the first complete inventory of privileged maintenance tools (include third party tools).
- Enable or validate audit logging in each tool and route logs to your central logging platform.
- Write the operational definition of “privileged maintenance execution events” and map it to log fields.
By 60 days (monitoring that an auditor can test)
- Implement high-signal detections for privileged maintenance actions (mass changes, security control disablement, new operators, unusual access paths).
- Stand up a recurring review (alerts + summary report) with documented sign-off.
- Create an exception workflow for emergency maintenance, with a clear approval and documentation path.
By 90 days (make it durable)
- Run at least one end-to-end tabletop: pick a sample privileged maintenance event and prove you can trace who initiated it, what executed, and what changed.
- Close gaps in attribution (remove shared accounts, tighten roles, add MFA where applicable).
- Package evidence in your GRC system (for example, Daydream) so each review cycle produces consistent artifacts without manual chasing.
Frequently Asked Questions
What counts as a “maintenance tool” under MA-3(5)?
Treat any tool used to administer, patch, troubleshoot, or modify systems as a maintenance tool, especially if it can execute code or changes as admin/root/SYSTEM. If it can push scripts, install software, or change configs remotely, include it.
Do we have to monitor actions performed by a third party (like an MSP)?
Yes, if the third party uses maintenance tooling that runs with increased privilege in your environment, you still need monitoring and review. Make sure the logging and attribution show the individual operator or a controlled, traceable account.
Is enabling logging enough to satisfy the requirement?
Logging is necessary but usually insufficient by itself. Auditors look for evidence of monitoring in operation, such as alerting, periodic reviews, and incident follow-up tied to privileged maintenance events.
How do we handle tools that run as privileged agents all the time?
Focus on monitoring the agent’s privileged actions and the initiating identity that instructed the agent (console user, API token, job runner). Pair agent activity on the host with tool-side audit logs so you can attribute actions.
What evidence should we keep to pass an assessment?
Keep the tool inventory, logging configurations, SIEM ingestion proof, alert/rule definitions, and recurring review records with sign-offs. Add sample investigations that trace a privileged action from request to execution.
How do we operationalize MA-3(5) in a GRC workflow?
Map the requirement to a control owner, a written procedure, and a recurring evidence schedule, then attach artifacts each cycle. Daydream helps keep that mapping and evidence collection consistent so audits don’t turn into log-screenshot drills.
Footnotes
Frequently Asked Questions
What counts as a “maintenance tool” under MA-3(5)?
Treat any tool used to administer, patch, troubleshoot, or modify systems as a maintenance tool, especially if it can execute code or changes as admin/root/SYSTEM. If it can push scripts, install software, or change configs remotely, include it.
Do we have to monitor actions performed by a third party (like an MSP)?
Yes, if the third party uses maintenance tooling that runs with increased privilege in your environment, you still need monitoring and review. Make sure the logging and attribution show the individual operator or a controlled, traceable account.
Is enabling logging enough to satisfy the requirement?
Logging is necessary but usually insufficient by itself. Auditors look for evidence of monitoring in operation, such as alerting, periodic reviews, and incident follow-up tied to privileged maintenance events.
How do we handle tools that run as privileged agents all the time?
Focus on monitoring the agent’s privileged actions and the initiating identity that instructed the agent (console user, API token, job runner). Pair agent activity on the host with tool-side audit logs so you can attribute actions.
What evidence should we keep to pass an assessment?
Keep the tool inventory, logging configurations, SIEM ingestion proof, alert/rule definitions, and recurring review records with sign-offs. Add sample investigations that trace a privileged action from request to execution.
How do we operationalize MA-3(5) in a GRC workflow?
Map the requirement to a control owner, a written procedure, and a recurring evidence schedule, then attach artifacts each cycle. Daydream helps keep that mapping and evidence collection consistent so audits don’t turn into log-screenshot drills.
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Map requirement text to controls, owners, evidence, and review workflows inside Daydream.
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