BSI C5:2020 IDM-02 — Granting and change of user accounts and access rights

What this control requires

Implements procedures for granting and modifying user accounts per IDM-01, ensuring compliance with role-based access and least privilege principles. Verifies approvals to prevent unauthorized access to cloud customer data or system components.

In plain English

Implements procedures for granting and modifying user accounts per IDM-01, ensuring compliance with role-based access and least privilege principles. In practice, this means you can prove you risk access rights-level controls on a defined cadence.

Why it matters

BSI C5 is the default cloud-security baseline German public-sector buyers and many DAX-listed enterprises expect; gaps here directly block procurement in the DACH region and frequently appear as must-have items in EU public-tender documents.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

What an auditor looks for

A C5 attesting auditor (under ISAE 3000 / IDW PS 860) tests both the design and — for a Type 2 — the operating effectiveness over the attestation period. For each criterion they look for both the Basic and any in-scope Additional objectives.

Within Identity & Access Management, the assessor will trace your implementation back to the catalogue reference (Criterion IDM-02) and look for objective evidence on the latest two assessment cycles.

How to implement

1. Write a short policy stating intent, scope and named owner.
2. Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
3. Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
4. Review on a documented cadence and capture the review in the risk register or compliance tracker.

Operational checklist

• Risk. Document the trigger, the owner and the cadence.
• Review. Document the trigger, the owner and the cadence.
• Data. Document the trigger, the owner and the cadence.
• Access. Document the trigger, the owner and the cadence.
• Approvals. Document the trigger, the owner and the cadence.
• Scope: access rights, cloud customer data, management.

Evidence to collect

• Identity Scan. IAM / IdP exports — Entra ID, Okta, IAM Identity Center, Workspace directory — showing accounts, roles, MFA state and last sign-in.
• Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.

Identity analytics (Okta, SailPoint, Access Analyzer) demonstrates least-privilege. Focus: Granting and change of user accounts and access rights.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• ISO/IEC 27001:2022 A.5.18 — Access rights
• CIS Controls v8 6.1 — Establish an Access Granting Process
• NIST SP 800-171 Rev. 3 3.1.22 — Publicly Accessible Content
• SOC 2 (2017 TSC) CC6.1 — Logical Access Controls
• GDPR Article 26 — Joint controllers

Related controls in BSI C5:2020

• Criterion IDM-01 — Policy for user accounts and access rights
• Criterion IDM-05 — Regular review of access rights
• Criterion IDM-04 — Withdraw or adjust access rights as the task area changes
• Criterion IDM-06 — Privileged access rights
• Criterion HR-05 — Responsibilities in the event of termination or change of employment
• Criterion IDM-03 — Locking and withdrawal of user accounts in the event of inactivity or multiple failed logins

References

• Bundesamt für Sicherheit in der Informationstechnik (BSI) — BSI C5:2020
• Catalogue identifier: Criterion IDM-02

Topics: governance riskidentity accessidentity managementaccess reviewprivileged accesschange management