Requirements / Access Control (AC)
AC.L2-3.1.5
Least Privilege
Official Source Material
Employ the principle of least privilege, including for specific security functions and privileged accounts.
Determine if:
- [a] privileged accounts are identified;
- [b] access to privileged accounts is authorized in accordance with the principle of least privilege;
- [c] security functions are identified; and
- [d] access to security functions is authorized in accordance with the principle of least privilege.
Source: CMMC Assessment Guide - Level 2, Version 2.13, September 2024
Practitioner Guidance
How to meet it
Identify your privileged accounts before anything else.
Objective [a] is a list, and every environment has entries for it because somebody runs the IT. Claiming there are no privileged accounts earns a Not Met. You may define the category narrowly, domain admins and global administrators for example, but the list must exist, be written down, and match reality.
Give every administrator two accounts.
A daily account with no elevation and a separate admin account used only for administrative work is the pattern that answers [b] at any size. In a three-person company, two accounts per administrator is enough. A third tier adds ceremony without adding compliance.
Objective [c] wants your security functions named.
Establishing accounts, configuring access authorizations, setting events to be logged, and tuning intrusion detection are the guide's examples. List which of these exist in your environment and which roles reach them. Objective [d] then follows: restrict each function to the few people whose job requires it, and record that authorization.
Stop using the highest privilege for everything.
Running routine endpoint work with a domain admin account is the principle of most privilege, and one piece of malware in that session reaches everything the account reaches. Scope the credential to the task. Use a local admin credential for endpoint installs and narrow Microsoft Entra ID roles instead of Global Administrator. Where the platform offers it, use Privileged Identity Management, which grants admin rights just in time and takes them back after.
What falls short
- A system security plan asserting the organization has no privileged accounts. Objective [a] cannot be met by denial, because somebody administers the system.
- Domain admin credentials used for day-to-day tasks that do not require them. Access is not authorized in accordance with least privilege, so [b] fails even though the accounts are identified.
Edge cases
- Outsourced IT does not remove the requirement. Identify the elevated accounts your provider holds in your environment, document how they were authorized, and treat their administrators as yours for [a] and [b].
- Accounts on government systems such as DISS are not privileged accounts in your scope, because the test for [a] is whether the account enforces security policy on your systems. Your own tenant's global administrators qualify, and a certificate-based PKI logon to a government portal does not.