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Requirements / Access Control (AC)

AC.L2-3.1.7

Privileged Functions

Official Source Material

Prevent non-privileged users from executing privileged functions and capture the execution of such functions in audit logs.

Determine if:

  1. [a] privileged functions are defined;
  2. [b] non-privileged users are defined;
  3. [c] non-privileged users are prevented from executing privileged functions; and
  4. [d] the execution of privileged functions is captured in audit logs.

Source: CMMC Assessment Guide - Level 2, Version 2.13, September 2024

Practitioner Guidance

How to meet it

Define privileged functions as categories, not a command inventory.

Objective [a] is satisfied by categories: establishing accounts, configuring access authorizations, setting events to be audited, patching, administering security tooling, and managing cryptographic keys. Enumerating every individual command produces an unmaintainable list and no additional compliance.

Objective [b] is one sentence, and [c] is your standard user build.

Define non-privileged users as everyone not on the privileged account list from AC.L2-3.1.5. Prevention under [c] is what a correctly configured standard account already does: no administrator rights, elevation prompts the user cannot satisfy, installs blocked. The evidence is the central configuration that builds those accounts, a group policy or a mobile device management profile, plus a demonstration that a standard user cannot execute an administrative action.

Objective [d] asks for capture, not review.

Configure logging so privileged operations land in the audit log, and be ready to say which events you capture and why. There is no mandated list of event IDs. A reasoned selection with a recorded rationale is sufficient. Keep the specific event IDs in your configuration baselines, not in policy, so the policy states the expectation and the baseline carries the detail. Reviewing what you captured belongs to the Audit and Accountability requirements, not here.

Log privileged use even where prevention is airtight.

Objective [d] covers the privileged users themselves, not just blocked attempts by everyone else. The guide's own example is an accidental privilege grant that surfaced only because privileged activity was being logged and an unexpected actor appeared in it.

What falls short

  • A circular definition such as privileged functions are whatever requires elevation. It restates the mechanism without defining the functions, so [a] is not answered.
  • An application whose administrative actions cannot be logged, kept in scope with no mitigation. Objective [d] is unmet, so close the gap or replace the application.

Edge cases

  • A developer workstation that stores, processes, and transmits no CUI, controlled unclassified information, sits outside the boundary this requirement is assessed against. Solve privileged function control on the in-scope assets first, and do not let an out-of-scope lab complicate the answer.
  • An application with a privileged web interface and no useful logging has three fixes. Have it sign users in through your directory so access is logged there, restrict the interface to named administrative hosts, or front it with an authenticating proxy that records who did what.

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