IA.L2-3.5.1[a]: Identify Every System Account That Requires a Password

Mapped to NIST 800-171 Requirement: 3.5.1
CMMC Assessment Objective: IA.L2-3.5.1[a]

What This Objective Means
Before you can secure accounts, enforce complexity, or rotate credentials, you need to know which accounts rely on passwords in the first place.
This includes:
• Individual user accounts
• Shared administrative accounts
• Built-in system accounts
• Service accounts that log in automatically
You’re expected to catalog which of these accounts require password-based authentication and ensure that this inventory stays up to date.

Why It Matters
If password-based accounts are not identified:
• They may not be covered by complexity or rotation policies
• Compromised credentials may go undetected
• You risk failing audits due to incomplete authentication controls
• Insider threats or unused accounts may be left unmanaged
Inventory is the foundation of control—and unmanaged accounts are an open door.

How to Implement It
1. Perform a System Account Audit
• Use tools or scripts to enumerate user, service, and application accounts across all systems
• Identify which ones rely on password-based login (vs. key-based or MFA)
2. Review Authentication Methods
• For each system, determine how users or services authenticate
• Flag accounts using passwords
3. Maintain a Centralized Inventory
• Track password-based accounts in a secure, updated system (e.g., IAM system, SSP)
4. Review Access Privileges
• Align password-based accounts with least privilege principles
5. Automate Monitoring Where Possible
• Use identity and access management (IAM) tools or endpoint agents to flag new or changed accounts

Evidence the Assessor Will Look For
• Account inventories or exports identifying password-based accounts
• System logs showing how users and services authenticate
• Documentation that reflects account identification processes (SSP, access policies)
• Service account credential configuration reports (GPO, system settings)

Common Gaps
• Accounts relying on default passwords are not flagged
• Inventory includes users but excludes service accounts
• Privileged accounts using passwords are not documented
• Authentication methods are assumed, not verified

How Cuick Trac Helps
Cuick Trac supports this control by:
• Restricting access to a defined set of user and service accounts within the enclave
• Maintaining a pre-approved account inventory tied to password authentication
• Supporting regular account audits and flagging changes
• Helping customers document and track authentication methods for each account
• Enabling centralized account management through secure administrative policies
Cuick Trac ensures your password-dependent accounts are known, controlled, and secure.

Final CTA
You can’t protect what you haven’t identified.
Schedule a Cuick Trac demo to see how we help you maintain visibility and control over every password-based account.

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