BSI C5:2020 IDM-05 — Regular review of access rights

What this control requires

Annually reviews access rights by authorized personnel to ensure alignment with employee roles. Corrects deviations within seven days, maintaining least privilege and preventing unauthorized access to cloud customer data or systems.

In plain English

Annually reviews access rights by authorized personnel to ensure alignment with employee roles. In practice, this means you can prove you review 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-05) and look for objective evidence on the latest two assessment cycles.

How to implement

Cloud Posture

CSPM. Run Wiz / Prisma / Defender for Cloud / Security Command Center over every account; auto-ticket findings above your accepted-risk threshold.

Operational checklist

• Review. Document the trigger, the owner and the cadence.
• Data. Document the trigger, the owner and the cadence.
• Regular Review. Document the trigger, the owner and the cadence.
• Access. Document the trigger, the owner and the cadence.
• Roles. 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: Regular review of access rights.

Common pitfalls

• Treating CSPM findings as a backlog instead of a hot queue: findings older than the policy SLA accumulate until the auditor asks why.

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.8.2 — Privileged access rights
• SOC 2 (2017 TSC) CC6.1 — Logical Access Controls
• CIS Controls v8 3.3 — Configure Data Access Control Lists
• NIST SP 800-171 Rev. 3 3.13.4 — Information in Shared System Resources
• ISO/IEC 27701:2025 A.3.9 — Access rights

Related controls in BSI C5:2020

• Criterion IDM-01 — Policy for user accounts and access rights
• Criterion IDM-04 — Withdraw or adjust access rights as the task area changes
• Criterion IDM-03 — Locking and withdrawal of user accounts in the event of inactivity or multiple failed logins
• Criterion IDM-06 — Privileged access rights
• Criterion IDM-02 — Granting and change of user accounts and access rights
• Criterion IDM-07 — Access to cloud customer data

References

• Bundesamt für Sicherheit in der Informationstechnik (BSI) — BSI C5:2020
• Catalogue identifier: Criterion IDM-05

Topics: identity accessidentity managementaccess reviewprivileged accesscloud posture