Access Control (AC) — 3.1.6

FutureFeed CMMC Education Series · Access Control

Access Control (AC): 3.1.6

The short version

If you’re responsible for CMMC compliance, here’s what this requirement comes down to. You need to:

  • Give anyone with admin rights a way to work without them: a separate regular account, or a role they elevate out of
  • Reserve the privileged account or role for actual admin and security tasks
  • Make elevating to admin a deliberate step, not the default way people work
  • Log privileged activity, so you know when elevated rights are used and by whom

If you already have those things and can prove them, you’re well on your way. Now let’s talk about what each one actually looks like.

Access Control (AC): CMMC requirement 3.1.6, use non-privileged accounts or roles when accessing nonsecurity functions

Applies to: Organizations pursuing CMMC Level 2 or 3 · Anyone who stores, processes, or transmits CUI · IT and security leads, virtual CISOs, and every administrator who holds privileged access.

Last reviewed: September 2026. Covers NIST SP 800-171 Rev 2 Access Control (3.1.6), which sits at CMMC Level 2.

01

In plain English

Even the people who need admin rights shouldn’t use them all day. Most of an administrator’s day is ordinary work: reading email, browsing the web, writing documents. None of that needs admin power. This control says to do that everyday work from a normal account, and switch to the privileged account or role only when you’re actually doing admin or security work.

Here’s why it matters. If an admin reads email while logged in as admin and clicks the wrong link, the attacker instantly has admin control over your environment. If that same click lands on a regular account, it’s a much smaller problem. Separating the two shrinks the blast radius of a bad day.

The “or roles” wording matters if you use role-based access: switching roles can do the same job as switching accounts, as long as the role change truly changes what the person, and their automated processes, can do.

So what counts as a nonsecurity function? That question is the heart of this requirement.

  • Nonsecurity functions: email, web browsing, document editing, collaboration tools, ordinary business applications, and routine ticket work.
  • Privileged or security functions: changing security configurations, administering accounts, modifying permissions, installing or configuring protected system components, managing security tooling, and any change that requires elevated rights.

The account or role you use should match the function you are performing. That is worth remembering more than “administrators need two accounts.”

Do everyday work from an everyday account. Save the powerful account for the powerful work.

Example

Your systems administrator has two logins: a regular account for email, browsing, and documents, and a separate admin account for managing servers and user accounts. She spends most of her day in the regular account. When she needs to add a user or change a setting, she signs into the admin account, does the task, and steps back out. If a phishing email catches her in the regular account, the attacker lands on a login that can’t run the environment. That’s the whole point.

02

What you need to have in place

To implement this effectively, each of those boxes needs to be real and repeatable:

  • A non-privileged working context for each person who holds admin access: a separate regular account, or a role that carries no privilege until they elevate.
  • Everyday work done from the regular account: email, web, and documents don’t touch the privileged account.
  • Privileged accounts used only for admin and security tasks, not routine activity.
  • Elevation as the exception, so people log in with normal access by default and step up only when a task requires it. Enforce it technically where you can.
  • Records of who holds privileged access and how they elevate, plus logs showing what privileged accounts are used for.

The idea is simple: the account that can run your environment should barely ever be logged in.

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03

How to implement it

Here is the order I would work through it in a real environment:

1

Identify your privileged users and roles.

Who administers endpoints, servers, networks, cloud environments, identity systems, security tools, and applications? You cannot limit privileged use until you know where privilege lives.

2

Give those people a non-privileged working context.

Their normal login should carry no administrative rights. Email, chat, browsing, documents, and ticket work all happen there.

3

Create a deliberate elevation path.

That can be a separate administrator account, role activation, sudo, Run as administrator, a privileged access management tool, or just-in-time elevation. Pick what fits your environment, and make it the only way privilege gets used.

4

Restrict what privileged identities can do.

Telling administrators not to browse the web from an admin account is weaker than preventing it. Block or constrain email and internet access from privileged sessions where the technology allows, and time-box privilege rather than leaving it standing.

5

Log and review privileged activity.

You want to know when elevated rights were used, by whom, and for what. Do this because the organization should know, not because someone will ask. Evidence then becomes a by-product of running the control.

04

What to document and monitor

Think in three buckets. Building your evidence across all three helps you show that the requirement is implemented, not just documented.

People

  • The IT or security lead who owns the account model
  • The admins who actually use two accounts, or role-based elevation
  • Whoever reviews how privileged accounts are used

Tools

  • An identity system that supports separate admin accounts or role elevation
  • Logging that shows what privileged accounts are used for
  • Somewhere the account model is documented

Documents

  • A policy requiring non-privileged accounts for everyday, nonsecurity work
  • A list of who has separate privileged and non-privileged accounts, or role-based elevation
  • Logs or records showing privileged accounts are used only for admin and security tasks
  • A note in your System Security Plan (SSP) describing the account model

You do not need heavy tooling. What matters is that administrators live in a regular account, step up only when the work requires it, and that you can see it happening.

05

When should I work on this

A note on the CMMC Phase II pause

CMMC implementation remains paused in Phase I, and the Department has suspended the transition to Phase II while it reviews the program. Phase I self-assessment requirements remain in place, including the NIST SP 800-171 Rev 2 requirements applicable to Level 2 self-assessments. Contractors also remain responsible for protecting covered defense information in accordance with DFARS 252.204-7012. So this is still work worth doing now.

Build this right after 3.1.5. Once you’ve decided privilege should be rare, this control makes sure even the people who have it don’t expose it during routine work. Set it up when you first create admin accounts, because getting an admin into the two-account habit from day one is far easier than breaking a single-account habit later. It also pairs with the next control, which keeps regular users from running privileged functions at all.

06

Common challenges

1

Admins do everything from the admin account.

Why it happens: One login is convenient, so email and browsing happen in the same session that manages the servers.

Recommendation: Give each admin a non-privileged working context, whether that is a second account or a role they elevate out of, and keep everyday work there.

2

The second account exists but nobody uses it.

Why it happens: Switching feels like friction, so people just stay signed in as admin.

Recommendation: Make the regular account the default and elevate only for admin tasks. Enforce it technically where you can.

3

You can’t tell what the admin account is used for.

Why it happens: Nothing separates routine activity from real admin actions in the logs.

Recommendation: Log privileged-account activity so you can show it’s used only for admin and security work.

07

What good looks like

An administrator signs into their workstation with normal user privileges. They read email, browse the web, work tickets, attend meetings, and create documents without administrative rights. When an administrative task comes up, they deliberately authenticate or elevate into a privileged context, perform the task, and return to their normal context. The privileged activity is logged and attributable to them.

That is what it looks like in practice. An organization implementing this requirement well can usually answer yes to all of these:

  • Does everyone with admin rights have a non-privileged way to do everyday work?
  • Is routine work (email, web, documents) done from the non-privileged account?
  • Are privileged accounts or roles used only for admin and security tasks?
  • Is privileged activity logged, attributable to a person, and reviewed?

If any answer is no, that’s your next place to start.

Watch out

This isn’t about having fewer admins; that’s the previous control. It’s about how the admins you do have spend their day. Even a perfectly justified admin account becomes a liability the moment it’s used to read email and browse the web. And if you rely on role switching instead of separate accounts, the role change has to truly change what the person and their processes can do, or it doesn’t count.

How this connects to other controls

This control doesn’t stand alone. A few close relationships:

  • Least privilege (3.1.5): that control keeps privilege rare; this one keeps even that privilege out of everyday use.
  • Privileged functions (3.1.7): the next control keeps non-privileged users from running privileged functions at all, and captures it when they try.
  • Audit & Accountability: logging is how you show a privileged account is used only for admin and security work.

The requirement, word for word

For your reference, here’s the exact language so you’re working from the source and not a paraphrase:

3.1.6

Use non-privileged accounts or roles when accessing nonsecurity functions.

Every organization implements these controls a little differently. If you’re not sure whether your approach actually satisfies the requirement, join one of our upcoming webinars or schedule a 15 Minutes with FutureFeed session. We’d rather help you work through the question now than discover a gap later.

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Sources

  • NIST SP 800-171 Rev 2, Access Control (3.1)
  • Related requirements: see also 3.1.5 (least privilege) and 3.1.7 (prevent non-privileged users from executing privileged functions) within NIST SP 800-171 Rev 2.