What is the most common gap auditors find on IA-2(6)?

Multi-factor authentication does not use a factor provided by a device separate from the accessing system

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

`IA-2(6)` Identification and Authentication (Organizational Users) | Access to Accounts: separate Device

Q: What evidence do auditors commonly ask for on IA-2(6) Identification and Authentication (Organizational Users) | Access to Accounts: separate Device?

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.

Implement multi-factor authentication for Selection (one or more): local; network; remote access to Selection (one or more): privileged accounts; non-privileged accounts such that: (a) One of the factors is provided by a device separate from the system gaining access; and (b) The device meets organization-defined strength of mechanism requirements.

Source: NIST SP 800-53 Rev 5, IA-2(6). 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

moderate

to go live

Identity provider / directory

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

List of system accounts · Identity provider / directory
Test of Mechanisms supporting and/or implementing multi-factor authentication capability · Identity provider / directory

periodic reviewEvidence produced at each review

System audit records · 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

First move

Start with the 2 of 8 artefacts that already live in a system (Identity provider / directory); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Multi-factor authentication does not use a factor provided by a device separate from the accessing system
The separate device does not meet the organization-defined strength of mechanism requirements

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(5) Identification and Authentication (Organizational Users) | Individual Authentication with Group Authentication · IA-2(8) Identification and Authentication (Organizational Users) | Access to Accounts: Replay Resistant