AC-6(5): Privileged Accounts

The fastest way to fail AC-6(5) is to treat “admin access” as a vague concept. Assessors look for a crisp definition of “privileged account,” a clear restriction rule, and evidence that the rule is enforced consistently across platforms. AC-6(5) is an enhancement to least privilege focused specifically on privileged accounts: the accounts that can change configurations, manage identities, access security tooling, or bypass normal controls.

The control text is short, but operationalizing it is not. You need an organizational decision (your restriction criteria), technical enforcement (IAM, PAM, endpoint controls, cloud policies), and governance (approvals, periodic reviews, exceptions). This page translates the ac-6(5): privileged accounts requirement into concrete steps you can assign to IT, Security, and system owners, with an evidence package that stands up in audits.

This requirement commonly intersects with incident response and third-party access. If a third party administers any part of your environment, their privileged access must follow the same restriction rule and evidence standards as employees. AC-6(5) is also a documentation test: if you cannot produce an inventory and restriction rationale quickly, you will spend the audit window reconstructing history.

Regulatory text

Control excerpt: “Restrict privileged accounts on the system to {{ insert: param, ac-06.05_odp }}.” (NIST SP 800-53 Rev. 5 OSCAL JSON)

What the operator must do: define the organization-defined parameter (ODP) that states exactly how privileged accounts are restricted, then implement and maintain those restrictions across the system. Your ODP is the rule assessors will test, so it must be specific enough to measure (who, what systems, what methods, what approvals, what exceptions). (NIST SP 800-53 Rev. 5)

Plain-English interpretation

You are required to minimize and control privileged accounts. That includes:

• limiting the number of privileged accounts,
• limiting who can be assigned privileged access,
• limiting where privileged access can be used (specific systems, management planes, admin consoles),
• limiting how privileged access is granted and exercised (approval, time-bound access, MFA, PAM),
• and limiting persistent privilege by using separate admin accounts or just-in-time elevation where practical.

AC-6(5) is not satisfied by a generic “least privilege policy.” It expects you to restrict privileged accounts to your documented rule and show evidence that the rule is operating.

Who it applies to

Entity types and environments

• Federal information systems and contractor systems handling federal data (NIST SP 800-53 Rev. 5)

Operational scope

• Identity systems (IdP, directory services, SSO, privileged groups)
• Server and endpoint administration (domain admins, local admin, sudoers)
• Network and security tooling (firewalls, SIEM admins, EDR tenant admins)
• Cloud control planes (AWS/GCP/Azure subscription/org admins, Kubernetes cluster-admin)
• Databases and data platforms (DBA, data warehouse admin)
• DevOps administration (CI/CD admins, artifact repository admins)
• Third-party administration (MSPs, cloud consultants, SaaS support access)

If your system boundary includes a managed service, your restriction rule must cover the third party’s privileged access path (named accounts, federated roles, break-glass, support portals).

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

Step 1: Define your “privileged account” standard and the ODP restriction rule

Create a one-page standard that answers:

• What counts as privileged: any account/role that can administer identities, change security settings, manage infrastructure, or access sensitive data at scale.
• Where privilege is allowed: list management planes and administrative interfaces that are in-scope.
• How privilege is restricted (your ODP): the measurable rule you will enforce.

A practical ODP structure you can audit against:

• Privileged access is only granted to named, individually assigned accounts (no shared admins except controlled break-glass).
• Privileged access is only granted after ticketed approval from the system owner and security.
• Privileged access requires strong authentication and is limited to approved admin endpoints or jump hosts where applicable.
• Privileged access is time-bounded for elevated roles where feasible; long-lived privileged assignments require explicit re-approval on a defined cadence.
• Privileged access from third parties is restricted to contract-scoped personnel, logged, and removed promptly when work ends.

Write the rule in a way that your tools can enforce and your auditors can test. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Step 2: Build a privileged account inventory (authoritative list)

Create an inventory that includes, at minimum:

• Account/role name
• Human owner (or service owner for service accounts)
• Privilege type (directory admin, cloud org admin, DB admin)
• System(s) and environment(s) (prod/non-prod)
• Approval reference (ticket/change record)
• Justification (job function / operational need)
• Authentication method (MFA, hardware key, federated role)
• Last review date and reviewer

Exam reality: if you cannot produce this inventory quickly, auditors assume privileged access is uncontrolled, even if controls exist.

Step 3: Reduce and rationalize privileged accounts

Work through the inventory and do three actions:

1. Remove: disable stale admin accounts, eliminate duplicate admin roles, delete shared accounts that are not break-glass.
2. Separate: require separate admin accounts from day-to-day user accounts for staff who administer systems.
3. Constrain: scope roles to the smallest administrative domain ¹ rather than global admin.

Document each change with a ticket and link it back to the inventory.

Step 4: Enforce restrictions in IAM/PAM and system configurations

Implement your ODP in technical controls:

• IAM guardrails: privileged groups require approval workflows; restrict who can grant privilege; block self-assignment.
• PAM controls (if available): time-bound elevation, checkout, session recording for high-risk systems.
• Endpoint/server controls: block local admin where not required; control sudoers; enforce privileged access via jump hosts for sensitive zones.
• Cloud policies: limit who can assume admin roles; restrict access to management APIs; require MFA and conditional access for admin portals.

You do not need perfect tooling everywhere on day one. You do need a consistent restriction rule and evidence that the highest-risk admin paths follow it. (NIST SP 800-53 Rev. 5)

Step 5: Establish recurring reviews and exception handling

Create a governance rhythm:

• Privileged access review: re-validate privileged assignments against job role and current need; remove anything not justified.
• Exception process: document break-glass and emergency access with compensating controls (strong auth, monitoring, rapid rotation, post-event review).
• Third-party offboarding: ensure privileged access is removed when contracts end or personnel change.

Make the review outputs auditable: a dated export, review sign-off, and a remediation log.

Step 6: Centralize evidence so audits are cheap

Most teams lose time collecting screenshots. Instead, store evidence in a control record:

• the ODP statement,
• current privileged inventory,
• last review package,
• sample approvals,
• logs or reports showing enforcement.

Daydream can help by mapping AC-6(5) to a single control owner, a repeatable procedure, and a recurring evidence checklist so you stop rebuilding the same proof each audit cycle. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Required evidence and artifacts to retain

Keep artifacts that demonstrate design and operation:

Design evidence

• Privileged access standard (definition + ODP restriction rule) (NIST SP 800-53 Rev. 5 OSCAL JSON)
• PAM/IAM configuration standard (how approvals, MFA, and role assignments work)
• Break-glass procedure and compensating controls

Operational evidence

• Privileged account inventory export with owners, systems, justification
• Access approval records (tickets/changes) for a sample of privileged grants
• Privileged access review package (export, sign-off, remediation actions)
• Termination/offboarding evidence for privileged users (including third parties)
• System configurations or policy exports demonstrating restrictions (group membership rules, conditional access, role assignment policies)
• Privileged activity logs (or pointers to where logs are retained) showing administrative actions are recorded

Common exam/audit questions and hangups

Expect these questions:

• “Show me your definition of a privileged account and the restriction rule you apply.” (NIST SP 800-53 Rev. 5 OSCAL JSON)
• “Produce a complete list of privileged accounts and roles for the system boundary.”
• “Who can grant privileged access, and how do you prevent self-approval?”
• “How do you restrict privileged access for third-party administrators?”
• “What is your process for emergency access, and how is it reviewed after use?”
• “Show evidence of your last privileged access review and resulting removals.”

Hangups that stall audits:

• No authoritative inventory (multiple partial lists across teams).
• Overreliance on policy statements without IAM/PAM enforcement artifacts.
• Confusion between privileged accounts and privileged permissions (assessors care about both).

Frequent implementation mistakes and how to avoid them

1. Shared admin accounts as normal operations.
   Fix: limit shared accounts to break-glass only; require named admins for routine work.

2. Admin access granted through informal channels (Slack/email).
   Fix: require ticketed approval and capture approver identity, scope, and duration.

3. Privilege sprawl in cloud.
   Fix: reduce global admin roles; use scoped roles; monitor role assignment changes.

4. Third-party admin access treated as “out of band.”
   Fix: bring third-party privileged access into the same inventory, approval, and review cycle.

5. Evidence stored as screenshots with no repeatability.
   Fix: standardize exports and reports; store them in a single control evidence folder tied to AC-6(5). (NIST SP 800-53 Rev. 5)

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat AC-6(5) primarily as an assessment and breach-risk amplifier: privileged accounts are the fastest path to full-system compromise, and assessors routinely focus on whether you can prove restriction, not whether you intended it. (NIST SP 800-53 Rev. 5)

Practical 30/60/90-day execution plan

First 30 days (Immediate stabilization)

• Assign a control owner and name system owners responsible for privileged access decisions. (NIST SP 800-53 Rev. 5)
• Publish the privileged account definition and your ODP restriction rule. (NIST SP 800-53 Rev. 5 OSCAL JSON)
• Generate an initial privileged account inventory from IAM, cloud, and key platforms.
• Freeze new privileged grants to “break-fix only” unless they follow the approval workflow.

Next 60 days (Enforcement and cleanup)

• Eliminate obvious excess: stale accounts, duplicate roles, unnecessary global admins.
• Implement or tighten MFA/conditional access for admin paths.
• Put approvals behind a ticketing workflow; require system owner + security approval for high-risk roles.
• Stand up a repeatable evidence pack (inventory export, approval samples, configuration exports).

By 90 days (Operational maturity)

• Run a full privileged access review cycle; document removals and exceptions.
• Formalize break-glass controls and post-use review.
• Bring third-party privileged access into the same lifecycle management.
• Move evidence collection to an automated cadence where possible, tracked in Daydream as recurring artifacts mapped to AC-6(5). (NIST SP 800-53 Rev. 5)

Frequently Asked Questions

What counts as a “privileged account” for AC-6(5)?

Any account or role that can administer the system, manage identities, change security settings, or access sensitive data broadly should be treated as privileged. Define this in writing and apply it consistently across on-prem, cloud, and SaaS admin planes. (NIST SP 800-53 Rev. 5)

Does AC-6(5) require a PAM tool?

The control requires restriction to your organization-defined rule (ODP), not a specific product. A PAM tool can make time-bounding, approvals, and session controls easier to prove, but you can meet the requirement with strong IAM controls plus documented processes and evidence. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Are shared administrator accounts always prohibited?

The requirement is to restrict privileged accounts to your ODP. If you keep shared accounts (for example, break-glass), document the exception, add compensating controls, and show strict monitoring and limited use consistent with your restriction rule. (NIST SP 800-53 Rev. 5 OSCAL JSON)

How do we handle third-party administrators under AC-6(5)?

Treat third-party personnel as in-scope privileged users: named access, contract- and task-scoped privileges, ticketed approvals, and removal when work ends. Add their privileged accounts to your inventory and review cycle. (NIST SP 800-53 Rev. 5)

What evidence is the fastest “win” for audit readiness?

A clean privileged account inventory tied to approvals and a completed access review package. Those artifacts prove both restriction intent (the rule) and ongoing operation (the review and removals). (NIST SP 800-53 Rev. 5)

Our cloud platform has many built-in admin roles. What will auditors expect?

They will expect you to identify which built-in roles are privileged, restrict assignment to a small set of approved admins, and show role assignment governance and review evidence. Your ODP should explicitly cover cloud control-plane privileges. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Footnotes

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