What is the most common gap auditors find on IA-8(2)?

External authenticators are accepted without confirming they are NIST-compliant, contrary to (a)

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

`IA-8(2)` Identification and Authentication (Non-organizational Users) | Acceptance of External Authenticators

Q: What evidence do auditors commonly ask for on IA-8(2) Identification and Authentication (Non-organizational Users) | Acceptance of External Authenticators?

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.

(a) Accept only external authenticators that are NIST-compliant; and (b) Document and maintain a list of accepted external authenticators.

Source: NIST SP 800-53 Rev 5, IA-8(2). 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

Test of Mechanisms supporting and/or implementing identification and authentication capabilities; mechanisms that accept external credentials · Identity provider / directory

periodic reviewEvidence produced at each review

System audit records · Identity provider / directory
Third-party credential verification records · Identity provider / directory
Evidence of third-party 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
List of third-party credentialing products, components, or services procured and implemented by organization · 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

External authenticators are accepted without confirming they are NIST-compliant, contrary to (a)
No documented and maintained list of accepted external authenticators exists, per (b)

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-8(1) Identification and Authentication (Non-organizational Users) | Acceptance of PIV Credentials from Other… · IA-8(4) Identification and Authentication (Non-organizational Users) | Use of Defined Profiles