IAC-10.1: Privileged Account Inventories
Mechanisms exist to inventory all privileged accounts and validate that each person with elevated privileges is authorized by the appropriate level of organizational management.
Renumbered: Formerly IAC-16.1 in SCF 2025.4.
Code reused: In SCF 2025.4 and earlier, IAC-10.1 was Password-Based Authentication. That control is now IAC-15.
Control Question: Does the organization inventory all privileged accounts and validate that each person with elevated privileges is authorized by the appropriate level of organizational management?
General (15)
| Framework | Mapping Values |
|---|---|
| CIS CSC 8.1 | 5.1 5.5 |
| CIS CSC 8.1 IG1 | 5.1 |
| CIS CSC 8.1 IG2 | 5.1 5.5 |
| CIS CSC 8.1 IG3 | 5.1 5.5 |
| CSA CCM 4.1.0 | IAM-03 IAM-10 IAM-11 |
| ISO 27002 2022 | 5.18 8.2 |
| ISO 27017 2015 | 9.2.3 |
| ISO 27018 2025 | 5.18 8.2 |
| NIST 800-171 R2 (source) | 3.1.5 |
| OWASP Top 10 2025 | A01:2025 |
| PCI DSS 4.0.1 (source) | 7.2.4 |
| PCI DSS 4.0.1 SAQ A-EP (source) | 7.2.4 |
| PCI DSS 4.0.1 SAQ C (source) | 7.2.4 |
| PCI DSS 4.0.1 SAQ D Merchant (source) | 7.2.4 |
| PCI DSS 4.0.1 SAQ D Service Provider (source) | 7.2.4 |
US (3)
| Framework | Mapping Values |
|---|---|
| USA Federal DHS CISA TIC 3.0 | 3.PEP.ID.EINVE |
| USA Federal CMMC 2.0 Level 2 | ACL2.-3.1.5 |
| USA New York DFS 23 NYCRR500 2023 Amd 2 | 500.7(a)(4) |
EMEA (5)
| Framework | Mapping Values |
|---|---|
| EMEA Germany C5 2026 | IAM-01.02B.7 IAM-05.01AC IAM-06.01AC |
| EMEA Spain CCN-STIC 825 | op.acc.4 op.acc.5 |
| EMEA UK DEFSTAN 05-138 2024 | 2424 |
| EMEA UK DEFSTAN 05-138 - L2 2024 | 2424 |
| EMEA UK DEFSTAN 05-138 - L3 2024 | 2424 |
APAC (2)
| Framework | Mapping Values |
|---|---|
| APAC New Zealand NZISM 3.9 | 16.4.40.C.01 |
| APAC Singapore CCOP CII 2026 | 5.3.1(c) |
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 inventory all privileged accounts and validate that each person with elevated privileges is authorized by the appropriate level of organizational management.
Level 4 — Quantitatively Controlled
Identification & Authentication (IAC) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational. ▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs). ▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs). ▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties. ▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review). ▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes. ▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.
Level 5 — Continuously Improving
Identification & Authentication (IAC) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational. ▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes. ▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions via Artificial Intelligence (AI) or Machine Learning (ML) technologies.
Assessment Objectives
- IAC-10.1_A01 all privileged accounts are inventoried.
- IAC-10.1_A02 each person with elevated privileges is validated as authorized by the level of organizational management designated to approve privileged access.
Evidence Requirements
- E-IAC-03 Privileged User Inventory
-
Documented evidence of an inventory of privileged users across Technology Assets, Applications and/or Services (TAAS) (internal and external).
Identity & Access Management
Technology Recommendations
Micro/Small
- Microsoft Active Directory (https://microsoft.com)
- Microsoft Entra (https://microsoft.com)
- AWS IAM (https://aws.amazon.com)
Small
- Microsoft Active Directory (https://microsoft.com)
- Microsoft Entra (https://microsoft.com)
- AWS IAM (https://aws.amazon.com)
Medium
- Microsoft Active Directory (https://microsoft.com)
- Microsoft Entra (https://microsoft.com)
- AWS IAM (https://aws.amazon.com)
Large
- Microsoft Active Directory (https://microsoft.com)
- Microsoft Entra (https://microsoft.com)
- AWS IAM (https://aws.amazon.com)
Enterprise
- Microsoft Active Directory (https://microsoft.com)
- Microsoft Entra (https://microsoft.com)
- AWS IAM (https://aws.amazon.com)