EvidenceSheet
FedRAMP Moderate (NIST SP 800-53 Rev 5 baseline) · AC - Access Control

AC-5 Separation of Duties

Identify and document duties requiring separation; define access authorizations to support.

Source: FedRAMP Moderate (NIST SP 800-53 Rev 5 baseline), AC-5. 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 FedRAMP Moderate (NIST SP 800-53 Rev 5 baseline) in the compliance library.

A FedRAMP baseline is a subset of NIST SP 800-53 Rev 5, enhancements included.

6
artefacts
1
held by a system
2
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

  • Account provisioning and deprovisioning workflow tickets with manager approvals · Identity provider / directory

periodic reviewEvidence produced at each review

  • Quarterly privileged access review attestations · Identity provider / directory
  • Joiner mover leaver workflow evidence integrated with HR · Identity provider / directory

governing documentDocuments that govern the control

  • SSP AC-5 statement listing the duties separated (development versus production deploy, key custodian versus key user, request versus approval) · Policy repository / GRC workspace
  • Separation of duties matrix with the conflicting role pairs and IAM evidence that no user holds both · Policy repository / GRC workspace
  • System access request forms with business justification · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Identity provider / directory on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.

Common gaps auditors find

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.

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AC-4(21) Physical or Logical Separation of Information Flows · AC-6 Least Privilege