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Level 2 IA.L2-3.5.9

Allow temporary password use for system logons with an immediate change to a permanent password

📖 What This Means

This control requires that when a new user account is created or a password is reset, the system must issue a temporary password that expires after the first use. The user must immediately change it to a permanent password of their choice. This ensures that only the intended user knows the final password, reducing the risk of unauthorized access. For example, when onboarding a new employee, IT might provide a temporary password like 'Welcome123' that forces a change at first login. Another example is a password reset link that generates a one-time temporary password sent to the user's email.

🎯 Why It Matters

Temporary passwords left unchanged create significant security risks. Attackers can exploit default or shared temporary credentials to gain access, as seen in the 2020 SolarWinds breach where attackers used default passwords to move laterally. The DoD requires this control because 34% of breaches involve credential theft (Verizon DBIR). Without forced password changes, temporary credentials could remain active indefinitely, exposing systems to compromise. This control ensures only authorized users retain access after initial setup.

How to Implement

  1. 1. In Azure AD: Configure 'Force password change on next login' in user properties (Azure Portal > Users > select user > Reset password)
  2. 2. In AWS IAM: Use CLI command `aws iam update-login-profile --user-name <user> --password-reset-required`
  3. 3. For GCP: Set `changePasswordOnNextLogin` flag via Admin SDK API or Google Workspace Admin Console
  4. 4. Enable audit logging for password reset events in cloud monitoring tools
  5. 5. Configure Conditional Access policies to block logins until password change
⏱️
Estimated Effort
2-4 hours for basic implementation (mid-level admin), 1-2 days for full documentation and testing

📋 Evidence Examples

Password policy document

Format: PDF/Word
Frequency: Annual review
Contents: Explicit requirement for temporary passwords with forced change
Collection: Export from policy management system

Screenshot of AD user properties

Format: PNG/JPG
Frequency: Per assessment
Contents: 'User must change password' checkbox enabled
Collection: Manual screenshot during audit

Password reset logs

Format: CSV/EVTX
Frequency: Monthly
Contents: Timestamp, admin ID, target user, forced change flag
Collection: Export from SIEM/event logs

Test case results

Format: Excel
Frequency: Quarterly
Contents: Verification that temporary passwords can't be reused
Collection: Manual testing log

📝 SSP Guidance

Use this guidance when writing the System Security Plan (SSP) narrative for this control.

How to Write the SSP Narrative

For IA.L2-3.5.9 ("Allow temporary password use for system logons with an immediate change to a permanent password"), your SSP narrative should specifically describe: (1) the tools and technologies you use to implement this control, (2) the configuration or process that enforces it, (3) who is responsible for maintaining it, and (4) what evidence proves it's working. Describe how users, devices, and processes are identified and authenticated, including your IAM platform, password policies, MFA implementation, certificate management, and service account controls. Be specific -- name your actual products, settings, and responsible personnel.

Example SSP Narratives

Cloud (Azure/AWS)

"IA.L2-3.5.9 is implemented using cloud-native controls. [Organization] uses [specific cloud service/feature] to allow temporary password use for system logons with an immediate change to a per.... The configuration is managed through [Azure Policy/AWS Config/Terraform] and monitored via [SIEM tool]. Responsible party: [IT Security Manager]. Evidence: [specific artifact, e.g., 'Azure AD Conditional Access policy screenshot, CloudTrail logs']."

On-Premise

"IA.L2-3.5.9 is implemented through on-premise infrastructure controls. [Organization] uses [Active Directory/Group Policy/specific tool] to allow temporary password use for system logons with an immediate change to a per.... Configuration is documented in [location] and audited [frequency]. Responsible party: [System Administrator]. Evidence: [specific artifact, e.g., 'Group Policy export, Windows Event logs']."

Hybrid

"IA.L2-3.5.9 is implemented across both cloud and on-premise environments. [Organization] uses [Azure AD Connect/hybrid tool] to ensure consistent enforcement. Cloud resources are managed via [cloud tool] and on-premise systems via [on-prem tool]. Both environments report to [centralized SIEM]. Responsible party: [IT Director]. Evidence: [artifacts from both environments]."

System Boundary Considerations

  • Identify all authentication entry points (local login, VPN, cloud, API)
  • Document the identity provider(s) and authentication flow
  • Specify MFA methods and coverage
  • Ensure this control covers all systems within your defined CUI boundary where allow temporary password use for system logons with an immediate change to a permanent password applies
  • Document any systems where this control is not applicable and explain why

Key Documentation to Reference in SSP

  • 📄 Identification and Authentication Policy
  • 📄 Password policy configuration
  • 📄 MFA enrollment records
  • 📄 Service account registry
  • 📄 Evidence artifacts specific to IA.L2-3.5.9
  • 📄 POA&M entry if control is not fully implemented

What the Assessor Looks For

The assessor will test authentication mechanisms, verify MFA is enforced for required access paths, check password policy configuration, and review service account documentation.

💬 Self-Assessment Questions

Use these questions to assess your compliance. Each "NO" answer provides specific remediation guidance.

Question 1: Does your password policy require temporary passwords to expire after first use?

✅ YES → Proceed to Q2
❌ NO → GAP: Update password policy document to mandate temporary password expiration. Remediate within 14 days.
Remediation:
Template available at NIST SP 800-63B Section 5.1.1.2

Question 2: Can users log in more than once with a temporary password?

✅ YES → GAP: Configure system to enforce password change at first login. Critical - remediate within 7 days.
❌ NO → Proceed to Q3
Remediation:
For AD: Verify 'User must change password' flag propagation

Question 3: Are password reset events logged with timestamps and admin IDs?

✅ YES → Proceed to Q4
❌ NO → GAP: Enable auditing for Event ID 4724 (password reset) in Windows. Remediate within 21 days.
Remediation:
Use PowerShell: Auditpol /set /subcategory:'User Account Management' /success:enable

Question 4: Is there documented evidence of testing this control within the last 90 days?

✅ YES → Compliance confirmed
❌ NO → GAP: Conduct test by creating test account with temp password. Document results immediately.
Remediation:
Use this test script: https://github.com/CMMC-guides/IA-tests

⚠️ Common Mistakes (What Auditors Flag)

1. Allowing password resets without forcing change

Why this happens: AD 'Password never expires' flag accidentally checked
How to avoid: Run quarterly PowerShell script to find accounts with this flag: Get-ADUser -Filter * -Properties PasswordNeverExpires | Where {$_.PasswordNeverExpires -eq $true}

2. No logging of who issued temporary passwords

Why this happens: Account management auditing not enabled
How to avoid: Enable Windows Security Event Log auditing for Account Management category

3. Temporary passwords don't meet complexity requirements

Why this happens: Mistaken belief temp passwords are exempt
How to avoid: Configure same complexity rules for temp passwords via Group Policy

4. Documentation doesn't match actual implementation

Why this happens: Policy updates not synchronized with technical changes
How to avoid: Use change management process that updates both systems and documents

📚 Parent Policy

This practice is governed by the Identification and Authentication Policy

View IA Policy →

📚 Related Controls