What is the most common gap auditors find on IA-2(12)?

System cannot accept Personal Identity Verification credentials for user authentication

NIST SP 800-53 Rev 5 · IA - Identification and Authentication

`IA-2(12)` Identification and Authentication (Organizational Users) | Acceptance of PIV Credentials

Q: What evidence do auditors commonly ask for on IA-2(12) Identification and Authentication (Organizational Users) | Acceptance of PIV Credentials?

Identification and authentication policy; System security plan; Procedures addressing user identification and authentication; System design documentation; System configuration settings and associated documentation; System audit records.

Accept and electronically verify Personal Identity Verification-compliant credentials.

Source: NIST SP 800-53 Rev 5, IA-2(12). 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 NIST SP 800-53 Rev 5 in the compliance library.

Base controls and their enhancements. Which apply follows the baseline you are assessed against (for example FedRAMP Moderate or High, or the low, moderate and high baselines of SP 800-53B). Text in square brackets is a parameter your organisation sets.

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

System audit records · Identity provider / directory
PIV verification records · Identity provider / directory
Evidence of PIV credentials · Identity provider / directory
Test of Mechanisms supporting and/or implementing acceptance and verification of PIV credentials · Identity provider / directory

governing documentDocuments that govern the control

Identification and authentication policy · Policy repository / GRC workspace
System security plan · Policy repository / GRC workspace
Procedures addressing user identification and authentication · Policy repository / GRC workspace
System design documentation · Policy repository / GRC workspace
System configuration settings and associated documentation · Policy repository / GRC workspace
PIV credential authorizations · 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

System cannot accept Personal Identity Verification credentials for user authentication
PIV credentials are accepted but not electronically verified, including certificate path and revocation checks

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

IA-2(10) Identification and Authentication (Organizational Users) | Single Sign-on · IA-2(13) Identification and Authentication (Organizational Users) | Out-of-band Authentication