IAC-09: Management Approval For New or Changed Accounts
Mechanisms exist to ensure management approvals are required for new accounts or changes in permissions to existing accounts.
Renumbered: Formerly IAC-28.1 in SCF 2025.4.
Code reused: In SCF 2025.4 and earlier, IAC-09 was Identifier Management (User Names). That control is now IAC-13.1.
Control Question: Does the organization ensure management approvals are required for new accounts or changes in permissions to existing accounts?
General (15)
| Framework | Mapping Values |
|---|---|
| AICPA TSC 2017:2022 (used for SOC 2) (source) | CC6.2-POF1 CC6.3-POF1 |
| NIST 800-53 R4 | AC-24 IA-4(2) |
| NIST 800-53 R5.2 | AC-24 IA-12(01) |
| NIST SP 800-66 R2 | 164.308(a)(3) |
| NIST 800-82 R3 | AC-24 IA-12(01) |
| NIST 800-82 R3 HIGH OT Overlay | IA-12(01) |
| NIST 800-161 R1 | AC-24 |
| NIST 800-161 R1 Flow Down | AC-24 |
| NIST 800-161 R1 Level 1 | AC-24 |
| NIST 800-161 R1 Level 2 | AC-24 |
| NIST 800-161 R1 Level 3 | AC-24 |
| NIST 800-171 R3 (source) | 03.01.01.b 03.05.05.a |
| NIST 800-171A R3 (source) | A.03.01.01.b[02] A.03.05.05.a |
| SCF DPMP 2026 | 7.1 |
| TISAX ISA 6.0.3 | 4.2.1 |
US (6)
| Framework | Mapping Values |
|---|---|
| USA Federal C2M2 2.1 | ACCESS-2f ACCESS-2g |
| USA Federal IRS 1075 2021 | IA-12(CE-1) |
| USA Federal HIPAA Security Rule NIST SP 800-66 R2 | § 164.308(a)(3)(ii)(A) |
| USA Federal HIPAA Administrative Simplification 2013 | § 164.308(a)(3)(ii)(A) |
| USA Federal NERC CIP 2024 | CIP-004-7 6.1 |
| USA California CCPA 2025 | 7123(c)(3)(C) |
EMEA (2)
| Framework | Mapping Values |
|---|---|
| EMEA EU NIS2 Annex 2024 | 11.2.2(c) |
| EMEA LUX CCSF 20/750 2020 | 3.4.2-31.e |
APAC (4)
| Framework | Mapping Values |
|---|---|
| APAC Australia Essential 8 2024 | ISM-1507 |
| APAC Australia ISM June 2026 | ISM-0405 ISM-1507 |
| APAC Japan ISMAP | 9.2.2.1 |
| APAC Singapore CCOP CII 2026 | 5.1.3(a) |
Americas (3)
| Framework | Mapping Values |
|---|---|
| Americas Argentina Reg 132 2018 | B.2.3-5 |
| Americas Bermuda BMACCC 2020 | 6.6 |
| Americas Canada ITSP-10-171 2025 | 03.01.01.B 03.05.05.A |
Capability Maturity Model
Level 0 — Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 — Performed Informally
SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.
Level 2 — Planned & Tracked
Identification & Authentication (IAC) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with IAC domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with IAC domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with IAC domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Identity & Access Management (IAM)-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines) to enforce Logical Access Control (LAC). ▪ IAM may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel to implement Role Based Access Control (RBAC) practices for the management of user, group and system accounts, including privileged accounts. ▪ A directory services technology is used to centrally manage identities and permissions with RBAC. Due to technical or business limitations, asset/process owners are empowered to operate a decentralized access control program for their specific Technology Assets, Applications and/or Services (TAAS) that cannot be integrated into directory services. ▪ Configuration management and IAM functions collaborate to ensure Secure Baseline Configurations (SBC) enforce “least privileges” on TAAS.
Level 3 — Well Defined
Identification & Authentication (IAC) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with IAC domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with IAC domain capabilities are well-documented and kept current by process owners. ▪ An Identity & Access Management (IAM) team, or similar function, is appropriately staffed and supported to implement and maintain IAC domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of IAM operations (e.g., directory services, Authenticate, Authorize and Audit (AAA) solution). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with IAC domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to ensure management approvals are required for new accounts or changes in permissions to existing accounts.
Level 4 — Quantitatively Controlled
Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.
Level 5 — Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
Assessment Objectives
- IAC-09_A01 the registration process to receive an account for logical access includes supervisor or sponsor authorization.
- IAC-09_A02 access control decisions applied to each access request prior to access enforcement are defined.
- IAC-09_A03 organization-defined criteria are taken into account to ensure that access control decisions are applied to each access request prior to access enforcement.
Evidence Requirements
- E-IAC-09 Access Authorization Records
-
Documented evidence of access authorization records.
Identity & Access Management
Technology Recommendations
Micro/Small
- Require manager approval before creating new user accounts
Small
- Management approval process for new/changed accounts
Medium
- Formal account management approval policy
- Approval workflow for all account changes
Large
- Enterprise IAM with management approval workflows for account creation
Enterprise
- Enterprise IGA platform with approval workflow automation (e.g., SailPoint, Saviynt)
- Role-based approval routing