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NIST SP 800-172 Enhanced CUI Protection Center

03.01.01E — Dual Authorization

Read the official CUI requirement and assessment content, then use the separately labeled Bare Metal Cyber perspective to connect it to implementation, evidence, and sustained operation.

1Parameters
1Source controls
1Assessment objectives
3Assessment methods

03.01 — Access Control · NIST SP 800-172 Revision 3

Active
Official NIST requirement content

Security requirement

Enforce dual authorization for [Organization-defined: privileged commands and/or other actions].

Official NIST discussion

Discussion

Dual authorization is also known as two-person control. Dual authorization reduces risk related to insider threats, including adversaries who have obtained credentials. Dual authorization requires the approval of two authorized individuals to execute privileged commands and/or other organizational actions that may affect the protection of CUI. To reduce the risk of collusion, organizations consider rotating dual authorization duties to other individuals. Organizations also consider the risk associated with implementing dual authorization when immediate responses are necessary to ensure public and environmental safety. This requirement enhances SP 800-171 requirement 03.01.02.

Official organization-defined parameters

Tailoring decisions required

Resolve these values through the governing organization’s approved tailoring and risk-management process before declaring the requirement implemented.

privileged commands and/or other actionsorganization-defined privileged commands and/or other organization-defined actionsprivileged commands and/or other actions requiring dual authorization are defined.
Official protection strategy classifications

Protection strategies supported

These classifications are carried from the official SP 800-172 OSCAL record and help explain the enhanced requirement’s defensive purpose.

PS-DLODamage-Limiting Operations
PS-PRAPenetration-Resistant Architecture
Bare Metal Cyber interpretation

Implementation perspective

Treat Dual Authorization as an enhanced CUI protection outcome for elevated threat conditions that must be reflected in the system boundary, documented implementation, operational behavior, and assessment evidence. Pay particular attention to approved identities, least privilege, remote access, information flow, and the full account lifecycle.

  1. Confirm the federal agency selected this enhanced requirement for the critical program or high-value asset and identify the CUI system components, services, users, and external connections in scope.
  2. Resolve every organization-defined parameter through an approved governance and tailoring process.
  3. Map each clause of the requirement to an accountable owner, implementation mechanism, and evidence source.
  4. Verify that inherited and shared implementations are supported by current provider evidence and responsibility boundaries.
  5. Collect evidence during normal operation and review changes, exceptions, and deficiencies on a risk-based cadence.

Questions to ask

  • Which critical-program or high-value-asset CUI, data flows, users, and services are protected by this enhanced requirement?
  • Which portions are implemented locally, inherited, shared, or not applicable, and what evidence supports that determination?
  • Do the system security plan, deployed configuration, operating process, and assessment evidence tell the same story?
  • What change, incident, or threshold should trigger reassessment?

Evidence and validation

  • access authorization and approval records
  • account inventories and entitlement exports
  • access review results
  • authentication and authorization logs

Common failure patterns

  • CUI access that exceeds mission need
  • shared or orphaned accounts
  • remote access paths outside the approved boundary
  • access reviews that cannot be reconciled to deployed permissions
Official NIST SP 800-172A content

Assessment objectives and methods

Assessment objectives (1)

  1. dual authorization is enforced for [Organization-defined: privileged commands and/or other actions].

Examine

  • Access control policy
  • procedures addressing access enforcement and dual authorization
  • system design documentation
  • system configuration settings and associated documentation
  • list of actions requiring dual authorization
  • list of privileged commands requiring dual authorization
  • list of approved authorizations (user privileges)
  • system security plan
  • other relevant documents or records

Interview

  • Personnel with access enforcement responsibilities
  • system/network administrators
  • system developers
  • personnel with information security responsibilities

Test

  • Dual authorization mechanisms implementing access control policy
Official source-control relationships

Source NIST SP 800-53 controls

These controls are referenced by the official SP 800-172 Rev. 3 OSCAL record. Open the corresponding control pages for complete control text, enhancements, D3FEND mappings, and related learning.

Source controlAC-3(2)Open SP 800-53 control →
Source record

Authoritative sources

Bare Metal Cyber is an independent educational publisher and is not affiliated with or endorsed by NIST. The official publications, the responsible federal agency, and the governing contract or agreement determine applicability, tailoring, assessment depth, and required implementation.