AC-6(6): Privileged Access by Non-organizational Users

AC-6(6) requires you to block privileged access (admin/root/superuser-equivalent rights) for anyone who is not an organizational user, including third-party vendor staff, contractors, and partner operators. To operationalize it quickly, define “non-organizational user,” identify privileged paths into each system, remove those accounts, and enforce technical guardrails so any remaining external access is non-privileged and tightly monitored. ¹

Key takeaways:

• “Non-organizational users” must not have privileged roles on your systems, even if they support operations. ¹
• Implementation is primarily technical: identity governance, role design, and access enforcement controls that prevent privileged assignment. ²
• Audit readiness depends on evidence: account inventories, role mappings, and recurring reviews proving no external privileged access exists. ¹

The ac-6(6): privileged access by non-organizational users requirement is a clean prohibition: external people should not hold privileged access to your system. That sounds simple until you map real operations: MSPs “helping” with emergency fixes, SaaS support engineers requesting admin consent, contractors managing cloud infrastructure, and acquired teams still using legacy admin accounts.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat this as an identity and architecture problem with a governance wrapper. You need a crisp definition of who counts as “non-organizational,” an inventory of where privileged access exists, and technical enforcement that blocks privileged role assignment to external identities. Then you need a repeatable, assessable process: onboarding/offboarding rules, exceptions handling, logging, and periodic verification.

This page gives requirement-level implementation guidance that you can hand to IAM, Security Operations, and system owners. It prioritizes what an assessor will test: whether privileged access by third parties is prohibited in design and prevented in operation, with evidence you can produce quickly. ¹

Regulatory text

Requirement (verbatim): “Prohibit privileged access to the system by non-organizational users.” ¹

What the operator must do:

1. Decide what “privileged access” means for each system (e.g., OS admin, database admin, cloud account admin, application super-admin, security admin, hypervisor admin).
2. Decide who is a “non-organizational user” (usually any identity not employed by your organization and not subject to your HR-led lifecycle controls).
3. Enforce a prohibition: non-organizational identities cannot be assigned to privileged roles, groups, or entitlements, and cannot access privileged interfaces through workarounds. ²

Plain-English interpretation

AC-6(6) is a hard line: third parties can support you, but they should not be administrators of your systems. If an external person needs to do administrative work, your design should route that work through organizational users, controlled automation, or tightly constrained support mechanisms that do not grant privileged standing access.

This is closely tied to least privilege (AC-6) because privileged accounts amplify blast radius: configuration changes, data exfiltration, disabling logging, creating new accounts, and modifying security controls. NIST expresses that risk by prohibiting privileged access for non-organizational users outright. ¹

Who it applies to (entity and operational context)

Entity scope (typical):

• Federal information systems and contractor systems that handle federal data. ¹

Operational scope (where this shows up in audits):

• Cloud console administration (AWS/GCP/Azure tenant admins).
• Endpoint management tools (MDM/RMM) with full device control.
• Identity platforms (IdP) where admins can grant themselves access.
• Core infrastructure (virtualization, network devices, firewalls).
• Databases and data platforms with admin roles.
• Business-critical SaaS where “super admin” can access all content.

Common third-party scenarios that trigger AC-6(6):

• Managed service providers with tenant-wide admin credentials.
• Vendor “support” accounts created for implementation and never removed.
• Contractors added to privileged groups for speed during a project.
• Partner operators with shared admin accounts (especially in joint ventures).

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

1) Define the policy boundary in operational terms

Create a short control statement your teams can apply consistently:

• Non-organizational user: an identity not owned and lifecycle-managed by your organization (not HR-managed, not covered by your standard joiner/mover/leaver controls).
• Privileged access: any role/group/entitlement that permits security administration, configuration administration, account administration, or unrestricted data access.
• Prohibition: non-organizational users cannot be granted privileged roles or equivalent effective privileges. ¹

Practical tip: write the definition so engineering can implement it as an identity attribute or directory flag (e.g., userType = external) that drives access controls.

2) Inventory privileged paths per system

You cannot prove prohibition without knowing where privilege exists.

• List each in-scope system.
• For each system, identify privileged roles/groups and privileged interfaces (admin portals, SSH, sudoers, Kubernetes cluster-admin, tenant owner).
• Export current role assignments and group memberships.

Deliverable: a Privileged Access Register that includes system, privileged role names, and current assignees.

3) Classify accounts as organizational vs non-organizational

For each privileged assignee:

• Determine if the identity is organizational (employee) or non-organizational (third party).
• Include service accounts and break-glass accounts, and document ownership. Some “service” identities are effectively third-party managed; treat them as high risk until proven otherwise.

Operational rule: if you cannot tie an account to an organizational owner and lifecycle process, treat it as non-organizational until remediated.

4) Remediate: remove external privileged access

Work system-by-system:

• Remove non-organizational users from privileged groups/roles.
• Disable or delete vendor/contractor admin accounts.
• Rotate credentials and tokens that a third party could still know.
• Replace shared admin accounts with named, organizational accounts where administrative work is required.

If you hit “but they need admin” resistance, force an architectural alternative:

• Vendor support via request-and-approve flows where an organizational admin executes privileged actions.
• Just-in-time privileged access for organizational users (time-bound elevation) so your team can perform the action quickly.
• Automation (runbooks, infrastructure-as-code pipelines) owned by organizational users.

AC-6(6) does not require you to stop third-party support; it requires you to stop third parties from being privileged users. ¹

5) Add preventive technical guardrails (so the problem doesn’t return)

Focus on controls that stop privileged assignment, not just detect it.

Identity governance / directory controls

• Tag external identities and sync that attribute to systems.
• Create policy that blocks external identities from being added to privileged groups.

PAM and role-based access controls

• Ensure privileged roles can only be assigned to organizational user populations.
• Prevent direct login to privileged accounts from external networks unless explicitly required for organizational admins.

SaaS admin constraints

• Restrict “super admin” roles to a small set of organizational identities.
• Turn off vendor-managed admin accounts where the platform allows it, and document any vendor access model that remains non-privileged.

6) Define an exceptions process (and keep it tight)

The requirement is “prohibit,” so exceptions should be rare and time-bound.

• Require written risk acceptance by the system owner and security leadership.
• Require compensating controls (increased monitoring, time-bounded access, session recording, strict scoping).
• Require an exit plan and a deadline to remove the exception.

If your environment truly cannot function without third-party privileged access, treat it as a control gap that must be tracked to closure with a concrete remediation design. ²

7) Operationalize ongoing verification

Make it recurring and automated where possible:

• Schedule privileged access reviews that explicitly check for external identities in privileged roles.
• Alert on changes to privileged groups that include external identities.
• Validate that offboarding of third-party personnel triggers immediate access removal.

Daydream can help you map AC-6(6) to a control owner, a clear procedure, and a recurring evidence set so you are not rebuilding proof for every assessment cycle. ¹

Required evidence and artifacts to retain

Auditors typically want to see both design and operating effectiveness. Keep these artifacts current:

Design evidence

• Access control policy section defining “privileged” and “non-organizational,” and the prohibition statement. ²
• Role/entitlement catalog for each system identifying privileged roles.
• Architecture decision record for third-party support model (how support occurs without privileged third-party accounts).

Operating evidence

• Privileged role membership exports showing no non-organizational users assigned.
• Third-party access roster (who has accounts, what level, what systems).
• Tickets or change records showing removal of vendor/contractor admin access.
• Exception register (if any), approvals, compensating controls, and closure proof.
• Logs or alerts demonstrating detection of attempted privileged assignment to external identities (where available).

Common exam/audit questions and hangups

• “Show me all privileged groups and who is in them, and identify which are third parties.”
• “How do you define non-organizational user, and how is that attribute enforced technically?”
• “Do any vendors/MSPs administer your cloud tenant? Prove they do not have admin roles.”
• “How do you prevent re-creation of vendor admin accounts during incidents or upgrades?”
• “Do you have any exceptions? Who approved them, and what is the end date?” ¹

Hangup to expect: system owners will argue that vendor admin access is “standard.” Your response should be to require a support model that keeps privilege with organizational identities.

Frequent implementation mistakes and how to avoid them

1. Mistake: Removing visible admin roles but leaving effective privilege. Example: a third party is not “Admin” but can modify IAM policies through an automation pipeline they control.
   Avoidance: map “privileged” to effective permissions and control the pipelines and credentials.

2. Mistake: Relying on contract language instead of technical prohibition.
   Avoidance: contracts help, but AC-6(6) is best satisfied with technical controls that prevent role assignment. ²

3. Mistake: Treating vendor support accounts as “service accounts.”
   Avoidance: require ownership, purpose, and lifecycle controls for every non-human account; remove third-party-managed admin credentials.

4. Mistake: No evidence package. Teams fix access, then cannot prove it later.
   Avoidance: define recurring exports, review records, and an exception register as part of the control procedure. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat enforcement risk as indirect: privileged third-party access commonly becomes a root cause or aggravating factor in incidents, and assessors frequently test privileged access controls because they correlate strongly with containment and accountability. Your most immediate risk is assessment failure due to inability to prove the prohibition is enforced and monitored. ¹

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

You asked for speed, so this plan emphasizes sequencing and proof generation rather than optimistic timelines.

First 30 days (stabilize and stop the bleed)

• Assign a control owner and name system owners for each in-scope system. ¹
• Publish the definitions (privileged, non-organizational) and the prohibition statement.
• Pull privileged role/group exports from priority systems (IdP, cloud tenant, endpoint tooling, core infrastructure).
• Disable or remove any obvious vendor/contractor admin accounts.
• Stand up an exceptions register and require approvals for any temporary deviation.

Days 31–60 (build preventive controls)

• Implement an “external identity” attribute and use it to block privileged group assignment.
• Re-architect vendor support paths: request-and-approve workflows, organizational-admin execution, and documented runbooks.
• Add monitoring: alerts on privileged group membership changes that include external identities.
• Start recurring access reviews focused specifically on privileged roles. ²

Days 61–90 (prove operation and close gaps)

• Expand inventory to remaining systems and confirm privileged role catalogs are complete.
• Run a full privileged access recertification and retain reviewer sign-off.
• Validate offboarding triggers for third-party personnel and test one offboarding event end-to-end.
• Prepare an assessor-ready evidence packet (policy excerpt, role catalogs, exports, review records, exception register). Daydream can keep this mapped to AC-6(6) so the packet is repeatable each cycle. ¹

Frequently Asked Questions

Does AC-6(6) mean third parties cannot access systems at all?

No. It prohibits privileged access by non-organizational users; non-privileged access can still be allowed if it fits your access model and is controlled. ¹

Are contractors ever considered “organizational users”?

Only if your organization treats them as organizational identities with full lifecycle governance and policy coverage. If they are managed outside your identity lifecycle controls, treat them as non-organizational for AC-6(6) purposes. ²

What counts as “privileged” in SaaS platforms?

Any role that can administer security settings, manage identities/roles, bypass controls, or access all customer content qualifies as privileged. Document which SaaS roles meet that threshold and restrict them to organizational users. ²

Our MSP needs admin to keep the lights on. What do we do?

Move administrative execution to organizational accounts and restrict the MSP to non-privileged operational access, documented procedures, and approved-change workflows. Track any temporary exception explicitly and set a removal plan. ¹

Do “break-glass” accounts violate AC-6(6)?

Break-glass accounts are acceptable if they are owned by your organization and not assigned to non-organizational users. Prove ownership, access restrictions, and monitoring around their use. ²

What’s the minimum evidence an auditor will accept?

A clear prohibition statement, a privileged role inventory, exports proving no external privileged assignments, and records of recurring review or monitoring. If you have exceptions, you need approvals and closure evidence. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5