3.1.1·high·Component: Access ControlWhat this control requires
This control defines the management of system accounts, including the creation, modification, enabling, disabling, and removal of accounts. It specifies the required account types (e.g., individual, group, service) and outlines the process for granting and revoking access based on authorization and intended usage. It also mandates the monitoring of account use, disabling inactive or expired accounts, and notifying relevant personnel when access is no longer needed. This control supports the Account Management System capability within the Access Control (3.1) family.
In plain English
This control defines the management of system accounts, including the creation, modification, enabling, disabling, and removal of accounts. In practice, this means you can prove you account management-level controls on a defined cadence.
Why it matters
DoD contractors and their subcontractors must implement all 100 SP 800-171 requirements to keep CUI handling contracts. Gaps are scored against the SPRS scoring methodology; below a 110-point starting score, each unmet requirement deducts points and a below-threshold score can disqualify a bid.
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 C3PAO conducting a CMMC Level 2 assessment uses NIST SP 800-171A objectives. They expect a System Security Plan (SSP), Plan of Action & Milestones (POA&M) for any gaps, and objective evidence (configurations, ticket records, training records) for every requirement.
Within Access Control, the assessor will trace your implementation back to the catalogue reference (Requirement 3.1.1) and look for objective evidence on the latest two assessment cycles.
How to implement
- Write a short policy stating intent, scope and named owner.
- Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
- Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
- Review on a documented cadence and capture the review in the risk register or compliance tracker.
Operational checklist
- Account. Document the trigger, the owner and the cadence.
- Access. Document the trigger, the owner and the cadence.
- Access Control. Document the trigger, the owner and the cadence.
- System. Document the trigger, the owner and the cadence.
- Personnel. Document the trigger, the owner and the cadence.
- Scope: management, creation, modification, account, personnel, access control, authorization.
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.
- Policy Document. A signed and version-controlled policy / standard / procedure document.
Identity analytics (Okta, SailPoint, Access Analyzer) demonstrates least-privilege. Signed policy or standard documents the safeguard. Focus: Account Management.
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.
- NIST SP 800-53 Rev. 5 AC-2(4) — Automated Audit Actions
- CIS Controls v8 6.8 — Define and Maintain Role-Based Access Control
- ISO/IEC 27001:2022 A.5.16 — Identity management
- BSI C5:2020 PS-04 — Physical site access control
- SOC 2 (2017 TSC) CC6.3 — Access Modification
Related controls in NIST SP 800-171 Rev. 3
- Requirement 3.1.6 — Least Privilege - Privileged Accounts
- Requirement 3.1.4 — Separation of Duties
- Requirement 3.1.22 — Publicly Accessible Content
- Requirement 3.1.8 — Unsuccessful Logon Attempts
- Requirement 3.1.7 — Least Privilege - Privileged Functions
- Requirement 3.1.11 — Session Termination
References
- NIST Computer Security Resource Center — NIST SP 800-171 Rev. 3
- Catalogue identifier:
Requirement 3.1.1
Topics: governance riskidentity accessidentity managementaccess reviewprivileged accesscontinuous monitoring