What evidence do auditors commonly ask for on AC.L2-3.1.4 Separation of Duties?

Documented separation of duties matrix for security relevant tasks; Access assignments demonstrating conflicting duties are held by different people; Records of conflict analysis and any approved compensating controls.

What is the most common gap auditors find on AC.L2-3.1.4?

Single administrator holds all privileged roles

CMMC 2.0 · Access Control

`AC.L2-3.1.4` Separation of Duties

Divide security relevant duties among different individuals so no single person can both carry out and conceal a harmful action without collusion.

Source: CMMC 2.0, AC.L2-3.1.4. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open CMMC 2.0 in the compliance library.

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Records of conflict analysis and any approved compensating controls · Identity provider / directory

governing documentDocuments that govern the control

Documented separation of duties matrix for security relevant tasks · Policy repository / GRC workspace
Access assignments demonstrating conflicting duties are held by different people · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Single administrator holds all privileged roles
Separation defined but not tested against actual entitlements
Small team treated as automatic exemption with no compensating control

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

AC.L2-3.1.3 Control CUI Flow · AC.L2-3.1.5 Least Privilege