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Criminal justice agencies and their vendors

How Identity and Access Management Supports the CJIS Security Policy

This page maps identity-relevant requirements in the CJIS Security Policy, Version 6.1, dated June 25, 2026. It covers the Access Control, Identification and Authentication, Audit and Accountability, and Personnel Security families, plus section 5.20.7.2 on mobile devices. Requirement text is quoted verbatim, and omitted text is marked in brackets.

Section 1.5 of the policy states that version 6.0 and later is a publicly available document. The mappings to NIST SP 800-53 Rev. 5 are GCA judgment, because the policy does not state which revision it aligns to and cites Revision 4 in its appendices. The relevance classifications and descriptions are GCA practice opinion.

Audit status is shown as of October 16, 2026. Under Section 1.4, requirements that existed before modernization and Priority 1 requirements have been sanctionable since October 1, 2024. Priority 2, 3 and 4 modernized requirements are in zero-cycle status from October 1, 2024 through September 30, 2027. Confirm local audit baselines with the agency that administers CJI access in your jurisdiction.

Search note: the phrase advanced authentication appears in this matrix as the title of section 5.20.7.2, which covers CJI access from authorized mobile devices. The general multifactor requirements are IA-2(1) for privileged accounts and IA-2(2) for non-privileged accounts.

For CIOs and compliance leaders

Information as of Last verified CJIS Security Policy (CJISSECPOL) Version 6.1, dated 06/25/2026 Version 1

Reference material, not a compliance determination. This matrix reflects GCA's practice view as of . It does not certify, warrant or predict the outcome of any assessment, audit or examination. The CJIS Security Policy, Version 6.1, controls. Read the full notice.

The matrix

  • Primary
  • Supporting
  • Outside identity scope (GCA classification)

CJIS Security Policy identity traceability matrix. CJIS Security Policy (CJISSECPOL) Version 6.1, dated 06/25/2026. Information as of October 16, 2026.
Requirement Requirement text Priority marking / Audit and sanction status Identity relevance (GCA classification) GCA approach Platform families that commonly provide relevant capabilities Evidence commonly examined
AC-2 AC: Access Control

Account Management

a. Define and document the types of accounts allowed and specifically prohibited for use within the system;

b. Assign account managers;

c. Require conditions for group and role membership;

d. Specify:

1. Authorized users of the system;

2. Group and role membership; and

3. Access authorizations (i.e., privileges) and attributes listed for each account; [attribute table omitted]

e. Require approvals by organizational personnel with account management responsibilities for requests to create accounts;

f. Create, enable, modify, disable, and remove accounts in accordance with agency policy;

g. Monitor the use of accounts;

h. Notify account managers and system/network administrators within:

1. One day when accounts are no longer required;

2. One day when users are terminated or transferred; and

3. One day when system usage or need-to-know changes for an individual;

i. Authorize access to the system based on:

1. A valid access authorization;

2. Intended system usage; and

3. Attributes as listed in AC-2(d)(3);

j. Review accounts for compliance with account management requirements at least annually;

k. Establish and implement a process for changing shared or group account authenticators (if deployed) when individuals are removed from the group; and

l. Align account management processes with personnel termination and transfer processes.

In practice: Each account type is defined and owned, group and role requests go through an approval workflow, and staff access is reviewed at least once a year. The identity platform automates the account lifecycle in between.

  • Priority marking P1
  • Existing from v5.9The section heading marks this control Existing, but the List of Priorities shows no asterisk. The policy is inconsistent on this point and this row follows the section heading. Sanction status is unaffected because the control is Priority 1.
  • Audit and sanction status Sanctionable
Primary
  • Assess
  • Implement
  • Manage

Identity governance work commonly contributes here: account types and approvals, group and role membership, automated lifecycle and the annual account review.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
Evidence commonly examined
  • Account type and approval procedure
  • Account inventory export with owner and role membership
  • Annual account review record
AC-2(1) AC: Access Control

Account Management | Automated System Account Management

Support the management of system accounts using automated mechanisms including email, phone, and text notifications.

In practice: Joiner, mover and leaver events trigger account changes automatically, and email, phone or text notices go to the account owner and the security team when an account changes.

  • Priority marking P1
  • Audit and sanction status Sanctionable
Primary
  • Implement

Automated provisioning and notification workflows commonly contribute to automated account management.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
Evidence commonly examined
  • Lifecycle workflow configuration export
  • Account change notification samples
AC-2(2) AC: Access Control

Account Management | Automated Temporary and Emergency Account Management

Automatically remove temporary and emergency accounts within 72 hours.

In practice: A temporary or emergency account is created with an expiry, and the platform removes it within 72 hours, so a short-term fix does not turn into a standing account.

  • Priority marking P1
  • Audit and sanction status Sanctionable
Primary
  • Implement

Time-boxed access and expiry-driven removal for temporary and emergency accounts commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Temporary account expiry policy
  • Removal log for expired temporary accounts
AC-2(3) AC: Access Control

Account Management | Disable Accounts

Disable accounts within one (1) week when the accounts:

a. Have expired;

b. Are no longer associated with a user or individual;

c. Are in violation of organizational policy; or

d. Have been inactive for 90 calendar days.

In practice: A routine report lists expired, orphaned and 90-day inactive accounts, and the help desk disables each one within a week of it showing up on the list.

  • Priority marking P1
  • Audit and sanction status Sanctionable
Primary
  • Assess
  • Implement
  • Manage

Dormant-account detection, orphan correlation and disable workflows commonly contribute to the disable conditions listed.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
Evidence commonly examined
  • Inactive account report
  • Disable workflow run history
  • Orphan account reconciliation report
AC-2(4) AC: Access Control

Account Management | Automated Audit Actions

Automatically audit account creation, modification, enabling, disabling, and removal actions.

In practice: Account creation, changes, disabling and removal are logged automatically, so an analyst can trace any change on an account without asking an administrator.

  • Priority marking P1
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Primary
  • Implement

Identity platform audit logging of account lifecycle events commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
Evidence commonly examined
  • Audit log extract of account create, modify, disable and remove events
AC-2(13) AC: Access Control

Account Management | Disable Accounts for High-Risk Individuals

Disable accounts of individuals within 30 minutes of discovery of direct threats to the confidentiality, integrity, or availability of CJI.

In practice: When the security team finds a direct threat to criminal justice information, a runbook lets the help desk disable the person's accounts within 30 minutes through the identity platform.

  • Priority marking P1
  • Audit and sanction status Sanctionable
Primary
  • Implement
  • Manage

Rapid-disable runbooks tied to identity threat detection commonly contribute to the 30-minute disable requirement.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
  • SailPoint ISC
  • SailPoint IIQ
Evidence commonly examined
  • Emergency disable runbook
  • Disable event log with timestamps
AC-3 AC: Access Control

Access Enforcement

Enforce approved authorizations for logical access to information and system resources in accordance with applicable access control policies.

In practice: People receive access to criminal justice systems through roles that were requested and signed off. The sign-in service refuses applications the person is not assigned to, and each application enforces the role inside it.

  • Priority marking P1
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Primary
  • Assess
  • Implement

Role and entitlement models and policy-based access decisions commonly contribute to enforcing approved authorizations.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
Evidence commonly examined
  • Role and entitlement catalog export
  • Access policy configuration export
AC-5 AC: Access Control

Separation of Duties

a. Identify and document separation of duties based on specific duties, operations, or information systems, as necessary, to mitigate risk to CJI; and

b. Define system access authorizations to support separation of duties.

In practice: Request rules keep one person from holding conflicting duties, and a report lists any overlaps so a manager can correct them before they cause risk to criminal justice information.

  • Priority marking P1
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Primary
  • Assess
  • Implement

Separation-of-duties policy design and violation reporting commonly contribute here.

Platform families that commonly provide relevant capabilities
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
Evidence commonly examined
  • Separation-of-duties policy document
  • Violation and exception report
AC-6 AC: Access Control

Least Privilege

Employ the principle of least privilege, allowing only authorized accesses for users (or processes acting on behalf of users) that are necessary to accomplish assigned organizational tasks.

In practice: Staff get roles that match their work, and managers confirm those roles are still needed. Administrator rights are granted only when required, and shared administrator credentials are checked out from a privileged access vault.

  • Priority marking P1
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Primary
  • Assess
  • Implement
  • Manage
  • Role Mining Engine

Role design, access review and privileged access controls commonly contribute to least privilege.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Role mining or entitlement analysis output
  • Access review results
AC-6(1) AC: Access Control

Least Privilege | Authorize Access to Security Functions

Authorize access for personnel including security administrators, system and network administrators, and other privileged users with access to system control, monitoring, or administration functions (e.g., system administrators, information security personnel, maintainers, system programmers, etc.) to:

a. Established system accounts, configured access authorizations (i.e., permissions, privileges), set events to be audited, set intrusion detection parameters, and other security functions; and

b. Security-relevant information in hardware, software, and firmware.

In practice: Access for administrators of security and network tools is its own role, granted only after a documented request and sign-off, and removed when the duty ends.

  • Priority marking P1
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Primary
  • Implement

Privileged role definition and approval-gated elevation commonly contribute to controlling access to security functions.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Privileged role assignment export
  • Elevation approval records
AC-6(2) AC: Access Control

Least Privilege | Non-Privileged Access for Nonsecurity Functions

Require that users of system accounts (or roles) with access to privileged security functions or security-relevant information (e.g., audit logs), use non-privileged accounts or roles, when accessing non-security functions.

In practice: People who administer security tools use a separate everyday account for email and ordinary work, so a mistake in the everyday account does not expose administrator rights.

  • Priority marking P1
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Primary
  • Implement

Separate administrative and everyday accounts commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Administrator account inventory showing separate daily-use accounts
AC-6(5) AC: Access Control

Least Privilege | Privileged Accounts

Restrict privileged accounts on the system to privileged users.

In practice: A privileged account inventory lists each account with a named holder, and only people with an authorized administrator role can have one. Extras get removed.

  • Priority marking P1
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Primary
  • Assess
  • Implement

Privileged account inventory and restriction to named privileged users commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Privileged account inventory
  • Privileged group membership export
AC-6(7) AC: Access Control

Least Privilege | Review of User Privileges

a. Review annually the privileges assigned to non-privileged and privileged users to validate the need for such privileges; and

b. Reassign or remove privileges, if necessary, to correctly reflect organizational mission and business needs.

In practice: Each year, managers and system owners confirm whether each person's regular and privileged access is still needed. Removals are carried out and the decisions are saved in a campaign record.

  • Priority marking P1
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Primary
  • Implement
  • Manage

Privileged and non-privileged access review campaigns with recorded decisions commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
Evidence commonly examined
  • Certification campaign export with reviewer decisions
  • Revocation records
AC-6(9) AC: Access Control

Least Privilege | Log Use of Privileged Functions

Log the execution of privileged functions.

In practice: Privileged sessions are recorded or logged, showing who ran administrator functions, on which system and at what time, so the security team can review that history.

  • Priority marking P1
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Primary
Why this classification

Capture of privileged function use is delivered by the privileged access tooling that identity teams run. Alerting, retention and review sit with security operations and are supporting rows in this series.

  • Implement

Privileged session and activity logging commonly contributes to logging the execution of privileged functions.

Platform families that commonly provide relevant capabilities
  • Entra
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Privileged activity log extract
  • Privileged session recording policy
AC-7 AC: Access Control

Unsuccessful Logon Attempts

a. Enforce a limit of five (5) consecutive invalid logon attempts by a user during a 15-minute time period; and

b. Automatically lock the account or node until released by an administrator when the maximum number of unsuccessful attempts is exceeded.

In practice: The directory locks an account after five failed sign-ins in 15 minutes and keeps it locked until an administrator releases it, usually after the help desk verifies the caller.

  • Priority marking P3
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Primary
  • Implement

Directory and identity provider lockout settings commonly contribute here. Where cloud identity provider lockout is time-based, the directory that supports administrator release commonly contributes to that requirement, and the gap is documented.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Lockout policy configuration export
AC-17 AC: Access Control

Remote Access

a. Establish and document usage restrictions, configuration/connection requirements, and implementation guidance for each type of remote access allowed; and

b. Authorize each type of remote access to the system prior to allowing such connections.

In practice: Each type of remote access is written down and authorized before use. The sign-in service applies those rules and requires MFA for remote sign-ins.

  • Priority marking P1
  • Existing from v5.9The section heading marks this control Existing, but the List of Priorities shows no asterisk. The policy is inconsistent on this point and this row follows the section heading. Sanction status is unaffected because the control is Priority 1.
  • Audit and sanction status Sanctionable
Primary
  • Implement

Policy-based remote access decisions with MFA commonly contribute to authorizing each type of remote access.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Remote access policy configuration export
IA-2 IA: Identification and Authentication

Identification and Authentication (Organizational Users)

Uniquely identify and authenticate organizational users and associate that unique identification with processes acting on behalf of those users.

In practice: Each employee signs in with their own named account through a single sign-on service, so every action in an application can be traced to one person.

  • Priority marking P1
  • Existing from v5.9The section heading marks this control Existing, but the List of Priorities shows no asterisk. The policy is inconsistent on this point and this row follows the section heading. Sanction status is unaffected because the control is Priority 1.
  • Audit and sanction status Sanctionable
Primary
  • Implement

A central identity provider with unique user identities and single sign-on commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Identity provider configuration export
  • Evidence of unique identifiers for organizational users
IA-2(1) IA: Identification and Authentication

Identification and Authentication (Organizational Users) | Multi-Factor Authentication to Privileged Accounts

Implement multi-factor authentication for access to privileged accounts.

In practice: Administrators and other privileged users add a second sign-in step, like a security key or authenticator prompt, each time they open a privileged account.

  • Priority marking P1
  • Audit and sanction status Sanctionable
Primary
  • Implement

Multi-factor authentication for administrators and other privileged accounts commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Authentication method policy export
  • MFA registration report for privileged accounts
IA-2(2) IA: Identification and Authentication

Identification and Authentication (Organizational Users) | Multi-Factor Authentication to Non-Privileged Accounts

Implement multi-factor authentication for access to non-privileged accounts.

In practice: Ordinary users also get a second sign-in step, such as a phone prompt, when they reach systems with criminal justice information. The identity team enrolls users and keeps the rule turned on.

  • Priority marking P1
  • Audit and sanction status Sanctionable
Primary
  • Implement

Multi-factor authentication for non-privileged accounts commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • MFA enforcement policy export
  • MFA registration and exclusion report
IA-2(8) IA: Identification and Authentication

Identification and Authentication (Organizational Users) | Access to Accounts, Replay Resistant

Implement replay-resistant authentication mechanisms for access to privileged and non-privileged accounts.

In practice: Sign-in uses replay-resistant methods, such as one-time passcodes or, more strongly, hardware keys and other phishing-resistant authenticators, for both administrators and regular users.

  • Priority marking P1
  • Audit and sanction status Sanctionable
Primary
  • Implement

Replay-resistant sign-in methods, including phishing-resistant authenticators, commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Authentication method or authenticator policy export
IA-4 IA: Identification and Authentication

Identifier Management

Manage system identifiers by:

a. Receiving authorization from organizational personnel with identifier management responsibilities to assign an individual, group, role, service, or device identifier;

b. Selecting an identifier that identifies an individual, group, role, service, or device;

c. Assigning the identifier to the intended individual, group, role, service, or device; and

d. Preventing reuse of identifiers for one (1) year.

In practice: HR-driven onboarding assigns each person a unique ID after authorized sign-off. The ID is not reused for at least one year, and each service account or device gets its own identifier.

  • Priority marking P2
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Primary
  • Assess
  • Implement

Unique identifier standards and non-reuse rules in lifecycle and correlation workflows commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
Evidence commonly examined
  • Identifier naming and reuse rule
  • Account correlation report
IA-5 IA: Identification and Authentication

Authenticator Management

Manage system authenticators by:

a. Verifying, as part of the initial authenticator distribution, the identity of the individual, group, role, service, or device receiving the authenticator;

b. Establishing initial authenticator content for any authenticators issued by the organization;

c. Ensuring that authenticators have sufficient strength of mechanism for their intended use;

d. Establishing and implementing administrative procedures for initial authenticator distribution, for lost or compromised or damaged authenticators, and for revoking authenticators;

e. Changing default authenticators prior to first use;

f. Changing or refreshing memorized secret authenticators annually or when there is evidence of authenticator compromise; changing or refreshing all other authenticator types as they expire or when there is evidence of authenticator compromise;

g. Protecting authenticator content from unauthorized disclosure and modification;

h. Requiring individuals to take, and having devices implement, specific controls to protect authenticators; and

i. Changing authenticators for group or role accounts when membership to those accounts changes. [items j through o omitted: AAL2 specific requirements, privacy requirements, general AAL2 requirements, biometric requirements, authenticator binding and session management]

In practice: Credentials are issued only after the person's identity is checked. Passwords and keys for services are stored in a vault, rotated on a schedule, and phishing-resistant methods are encouraged.

  • Priority marking P1
  • Audit and sanction status Sanctionable
Primary
  • Implement

Authenticator lifecycle settings, credential vaulting and phishing-resistant methods commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Password and authenticator policy export
  • Vault rotation policy for privileged credentials
IA-5(2) IA: Identification and Authentication

Authenticator Management | Public Key Based Authentication

(a) For public key-based authentication:

1. Enforce authorized access to the corresponding private key; and

2. Map the authenticated identity to the account of the individual or group; and

(b) When public key infrastructure (PKI) is used:

1. Validate certificates by constructing and verifying a certification path to an accepted trust anchor, including checking certificate status information; and

2. Implement a local cache of revocation data to support path discovery and validation.

In practice: Where staff or servers sign in with certificates or keys, each key pair is tied to one named person or service, and the private key's access is limited to that owner.

  • Priority marking P1
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Primary
  • Implement

Certificate and key-based authentication mapped to named identities commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Certificate to account mapping configuration
IA-8 IA: Identification and Authentication

Identification and Authentication (Non-Organizational Users)

Uniquely identify and authenticate non-organizational users or processes acting on behalf of non-organizational users.

In practice: Staff of partner agencies and other non-organizational users sign in with their own identities through federation, so each outside user is individually identified and nobody shares a login.

  • Priority marking P2
  • Audit and sanction status Zero-cycle
Primary
  • Implement

Identity federation and external identity configuration commonly contribute to identifying and authenticating non-organizational users.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • External identity and guest account configuration export
IA-8(2) IA: Identification and Authentication

Identification and Authentication (Non-Organizational Users) | Acceptance of External Authenticators

(a) Accept only external authenticators that are NIST-compliant; and

(b) Document and maintain a list of accepted external authenticators.

In practice: For a public-facing system, a written list records which outside authenticators the agency accepts, and the identity team updates it when the accepted list changes.

  • Priority marking P2
  • Audit and sanction status Zero-cycle
Primary
  • Assess
  • Implement

A documented list of accepted external identity providers and authenticators commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Accepted external identity provider register
IA-8(4) IA: Identification and Authentication

Identification and Authentication (Non-Organizational Users) | Use of Defined Profiles

Conform to the following profiles for identity management: Security Assertion Markup Language (SAML) or OpenID Connect.

In practice: Applications connect to outside partners using SAML or OpenID Connect, the two profiles the requirement names, and the integration team records which application uses which.

  • Priority marking P2
  • Audit and sanction status Zero-cycle
Primary
Why this classification

Class differs from the NIST SP 800-53 r5 page: CJIS v6.1 IA-8(4) itself names the required profiles (SAML or OpenID Connect), so federation integration is the direct identity work here, whereas the 800-53 page rates the IA-8(4) enhancement as supporting because it leaves the profiles to the sponsoring program.

  • Implement

SAML and OpenID Connect application integration commonly contributes to conforming to the named profiles.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Application federation protocol inventory
IA-11 IA: Identification and Authentication

Re-Authentication

Require users to re-authenticate when: roles, authenticators, or credentials change, security categories of systems change, the execution of privileged functions occur, or every 12 hours.

In practice: Users must sign in again when they change roles, switch to a privileged function, or have been signed in for 12 hours, and the sign-in service applies those timers.

  • Priority marking P2
  • Audit and sanction status Zero-cycle
Primary
  • Implement

Reauthentication interval and step-up policy commonly contribute to re-authentication triggers.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Reauthentication interval policy export
  • Step-up authentication rule for privileged functions
IA-12 IA: Identification and Authentication

Identity Proofing

a. Identity proof users that require accounts for logical access to systems based on appropriate identity assurance level requirements as specified in applicable standards and guidelines;

b. Resolve user identities to a unique individual; and

c. Collect, validate, and verify identity evidence.

In practice: HR checks a new hire's identity. The onboarding workflow then ties the new account to that one verified person and flags any duplicate or unmatched account.

  • Priority marking P2
  • Audit and sanction status Zero-cycle
Primary
  • Assess
  • Implement

Onboarding workflows that resolve each account to one verified person commonly contribute, alongside HR identity proofing.

Platform families that commonly provide relevant capabilities
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Entra
Evidence commonly examined
  • Onboarding procedure with identity proofing step
PS-4 PS: Personnel Security

Personnel Termination

Upon termination of individual employment:

a. Disable system access within twenty-four (24) hours;

b. Terminate or revoke any authenticators and credentials associated with the individual;

c. Conduct exit interviews that include a discussion of non-disclosure of CJI and PII;

d. Retrieve all security-related organizational system-related property; and

e. Retain access to organizational information and systems formerly controlled by terminated individual.

In practice: When HR records a termination, the leaver workflow disables the person's accounts within 24 hours and revokes their credentials, with a log entry for each step.

  • Priority marking P2
  • Audit and sanction status Zero-cycle
Primary
  • Assess
  • Implement
  • Manage

HR-driven leaver workflows commonly contribute to disabling access within 24 hours and revoking authenticators.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
Evidence commonly examined
  • Termination to disable time report
  • Credential revocation records
PS-5 PS: Personnel Security

Personnel Transfer

a. Review and confirm ongoing operational need for current logical and physical access authorizations to systems and facilities when individuals are reassigned or transferred to other positions within the organization;

b. Initiate appropriate actions such as closing and establishing accounts and changing system access authorizations within twenty-four (24) hours;

c. Modify access authorization as needed to correspond with any changes in operational need due to reassignment or transfer; and

d. Notify organizational personnel with information security responsibilities, organizational personnel with personnel security responsibilities, system/network administrators, and organizational personnel with account management responsibilities prior to personnel transfer.

In practice: When someone moves to a new role, the new manager gets a task to confirm which existing access still applies, and anything no longer needed is removed.

  • Priority marking P3
  • Existing from v5.9The Priority List in the policy marks this control with an asterisk (existing from version 5.9), but the section heading carries only its priority marking. The policy is inconsistent on this point and this row follows the Priority List. Confirm the treatment with your CJIS Systems Agency.
  • Audit and sanction status Sanctionable
Primary
  • Implement
  • Manage

Mover workflows and recertification on role change commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
Evidence commonly examined
  • Transfer event workflow run history
  • Access review triggered by role change
5.20.7.2 MOB: Mobile Devices (Policy Area 5.20)

Advanced Authentication

When accessing CJI from an authorized mobile device, advanced authentication shall be used by the authorized user unless the access to CJI is indirect as described in Identification and Authentication (IA). If access is indirect, then AA is not required.

In practice: The mobile device team owns the device setup. Identity contributes by requiring a strong second sign-in factor when staff open criminal justice information from an authorized phone or tablet.

  • Priority marking Unmarked
  • Existing from v5.9Section 5.20 is a non-modernized section with no marking. Section 1.4 treats unmarked non-modernized sections as existing requirements.
  • Audit and sanction status Sanctionable
Supporting
Why this classification

Device and mobile device management ownership usually dominate under Section 5.20; identity contributes the authentication step.

  • Implement

Strong authentication enforcement on mobile access to CJI commonly contributes here, alongside device registration. Section 5.20.7.2.1 allows CSO-approved compensating controls on agency-issued limited-feature devices.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Mobile access authentication policy export
  • Device registration report
AC-12 AC: Access Control

Session Termination

Automatically terminate a user session after a user has been logged out.

In practice: The security team owns session behavior. Identity contributes by configuring single logout on the single sign-on service, so signing out also ends the session in connected applications that support it.

  • Priority marking P3
  • Audit and sanction status Zero-cycle
Supporting
Why this classification

Application and platform session handling is usually the primary implementation point. The requirement text is quoted exactly as published in version 6.1.

  • Implement

Session lifetime and sign-out configuration on the identity provider commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Session policy configuration export
AC-20 AC: Access Control

Use of External Systems

a. Establish agency-level policies governing the use of external systems consistent with the trust relationships established with other organizations owning, operating, and/or maintaining external systems, allowing authorized individuals to:

1. Access the system from external systems; and

2. Process, store, or transmit organization-controlled information using external systems; or

b. Prohibit the use of personally-owned information systems including mobile devices (i.e., bring your own device [BYOD]) and publicly accessible systems for accessing, processing, storing, or transmitting CJI.

In practice: The agency sets the rules for outside systems and personal devices. Identity adds device-aware sign-in rules that allow or block access depending on whether the device is registered and managed.

  • Priority marking P1
  • Existing from v5.9The section heading marks this control Existing, but the List of Priorities shows no asterisk. The policy is inconsistent on this point and this row follows the section heading. Sanction status is unaffected because the control is Priority 1.
  • Audit and sanction status Sanctionable
Supporting
Why this classification

Agreements and technical limits on external systems extend beyond identity.

  • Implement

Device-aware access policy commonly contributes to governing access from external systems and personally owned devices.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Sign-in policy export for unmanaged and personally owned devices
AU-2 AU: Audit and Accountability

Event Logging

a. Identify the types of events that the system is capable of logging in support of the audit function: authentication, file use, user/group management, events sufficient to establish what occurred, the sources of events, outcomes of events, and operational transactions (e.g., NCIC, III);

b. Coordinate the event logging function with other organizational entities requiring audit-related information to guide and inform the selection criteria for events to be logged;

c. Specify the following event types for logging within the system:

All successful and unsuccessful:

1. System log-on attempts

2. Attempts to use:

a. Access permission on a user account, file, directory, or other system resource;

b. Create permission on a user account, file, directory, or other system resource;

c. Write permission on a user account, file, directory, or other system resource;

d. Delete permission on a user account, file, directory, or other system resource;

e. Change permission on a user account, file, directory, or other system resource.

3. Attempts to change account passwords

4. Actions by privileged accounts (i.e., root, Oracle, DBA, admin, etc.)

5. Attempts for users to:

a. Access the audit log file;

b. Modify the audit log file;

c. Destroy the audit log file.

d. Provide a rationale for why the event types selected for logging are deemed to be adequate to support after-the-fact investigations of incidents; and

e. Review and update the event types selected for logging annually.

In practice: The security team chooses which events to log. Identity contributes by turning on logging for sign-ins, group changes and privileged actions on the identity platform.

  • Priority marking P2
  • Existing from v5.9The Priority List in the policy marks this control with an asterisk (existing from version 5.9), but the section heading carries only its priority marking. The policy is inconsistent on this point and this row follows the Priority List. Confirm the treatment with your CJIS Systems Agency.
  • Audit and sanction status Sanctionable
Supporting
Why this classification

Audit event selection is usually owned by security monitoring.

  • Assess
  • Implement

Identity platform event selection for sign-in, permission changes and privileged actions commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
Evidence commonly examined
  • Logged event type list
  • Identity log source configuration
AU-3 AU: Audit and Accountability

Content of Audit Records

Ensure that audit records contain information that establishes the following:

a. What type of event occurred;

b. When the event occurred;

c. Where the event occurred;

d. Source of the event;

e. Outcome of the event; and

f. Identity of any individuals, subjects, or objects/entities associated with the event.

In practice: System owners decide what audit records contain; each identity log entry adds what happened, when, where, the source, the result and which named account was involved.

  • Priority marking P2
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Supporting
Why this classification

Record content is determined by each log source.

  • Implement

Identity audit records that carry the acting identity commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
Evidence commonly examined
  • Sample identity audit records showing event, time, source, outcome and identity
AU-6 AU: Audit and Accountability

Audit Record Review, Analysis, and Reporting

a. Review and analyze system audit records weekly for indications of inappropriate or unusual activity and the potential impact of the inappropriate or unusual activity;

b. Report findings to organizational personnel with audit review, analysis, and reporting responsibilities and organizational personnel with information security and privacy responsibilities; and

c. Adjust the level of audit record review, analysis, and reporting within the system when there is a change in risk based on law enforcement information, intelligence information, or other credible sources of information.

In practice: The security team reviews logs weekly and reports findings. Identity logs supply sign-in and permission-change records, and alerts point reviewers to unusual account activity.

  • Priority marking P2
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Supporting
Why this classification

Review and reporting processes are usually owned by security operations.

  • Implement
  • Manage

Identity log review and alerting commonly contribute to identifying unusual account activity.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
  • SailPoint ISC
Evidence commonly examined
  • Weekly review record
  • Alert rule configuration for anomalous sign-in
AU-12 AU: Audit and Accountability

Audit Record Generation

a. Provide audit record generation capability for the event types the system is capable of auditing as defined in AU-2a on all systems generating required audit logs;

b. Allow organizational personnel with audit record generation responsibilities, organizational personnel with information security and privacy responsibilities, and system/network administrators to select the event types that are to be logged by specific components of the system; and

c. Generate audit records for the event types defined in AU-2c that include the audit record content defined in AU-3.

In practice: System owners enable audit logging on their systems; identity contributes by switching on log generation across the identity systems so account and sign-in events are captured.

  • Priority marking P2
  • Audit and sanction status Zero-cycle
Supporting
Why this classification

Generation capability is usually a feature of each system.

  • Implement

Enabling identity audit generation on identity systems commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
Evidence commonly examined
  • Audit settings export for identity systems
IA-1 IA: Identification and Authentication

Policy and Procedures

a. Develop, document, and disseminate to authorized personnel:

1. Agency/Entity identification and authentication policy that:

(a) Addresses purpose, scope, roles, responsibilities, management commitment, coordination among organizational entities, and compliance; and

(b) Is consistent with applicable laws, executive orders, directives, regulations, policies, standards, and guidelines; and

2. Procedures to facilitate the implementation of the identification and authentication policy and the associated identification and authentication controls;

b. Designate organizational personnel with information security responsibilities to manage the development, documentation, and dissemination of the identification and authentication policy and procedures; and

c. Review and update the current identification and authentication:

1. Policy annually and following any security incidents involving unauthorized access to CJI or systems used to process, store, or transmit CJI; and

2. Procedures annually and following any security incidents involving unauthorized access to CJI or systems used to process, store, or transmit CJI.

In practice: The agency keeps a written sign-in policy with an owner and a review cycle. An assessment of the current identity setup gives the policy writers an accurate picture of what exists.

  • Priority marking P2
  • Audit and sanction status Zero-cycle
Supporting
Why this classification

Policy documentation is usually owned by the security governance function.

  • Assess

Assessment work commonly contributes to documenting the identification and authentication policy and procedures.

Not mapped
Evidence commonly examined
  • Identification and authentication policy
  • Annual policy review record
IA-2(12) IA: Identification and Authentication

Identification and Authentication (Organizational Users) | Acceptance of PIV Credentials

Accept and electronically verify Personal Identity Verification-compliant credentials.

In practice: The security team decides which smart cards are accepted; the sign-in service checks each card's certificate electronically and links it to the holder's named account.

  • Priority marking P1
  • Audit and sanction status Sanctionable
Supporting
Why this classification

The policy describes Personal Identity Verification credentials as credentials issued by federal agencies that conform to FIPS 201. In GCA's classification this is supporting: accepting those credentials is an identity configuration choice, while whether a CJIS Systems Agency requires them is the agency's decision. Confirm how your CJIS Systems Agency applies this requirement.

  • Implement

Certificate-based and PIV credential sign-in commonly contributes to accepting and verifying PIV credentials.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Certificate-based authentication configuration export
  • Trust store and revocation checking settings
IA-3 IA: Identification and Authentication

Device Identification and Authentication

Uniquely identify and authenticate agency-managed devices before establishing network connections. In the instance of local connection, the device must be approved by the agency and the device must be identified and authenticated prior to connection to an agency asset.

In practice: Agency laptops and other managed devices are registered and hold a certificate, and the network checks that certificate before it lets the device connect. The network team owns that check.

  • Priority marking P2
  • Audit and sanction status Zero-cycle
Supporting
Why this classification

Network-layer device authentication is usually owned by network engineering.

  • Implement

Device registration and certificate-based device authentication commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Device registration or compliance-state policy export
IA-5(6) IA: Identification and Authentication

Authenticator Management | Protection of Authenticators

Protect authenticators commensurate with the security category of the information to which use of the authenticator permits access.

In practice: System owners set protection levels by data category; identity contributes a vault with limited access for privileged and service account passwords, keys and tokens.

  • Priority marking P1
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Supporting
Why this classification

Protection levels depend on the system storing the authenticator.

  • Implement

Credential vaulting and protection of service and privileged secrets commonly contributes here.

Platform families that commonly provide relevant capabilities
  • CyberArk / BeyondTrust / Delinea
  • Entra
Evidence commonly examined
  • Vault access policy export
IA-8(1) IA: Identification and Authentication

Identification and Authentication (Non-Organizational Users) | Acceptance of PIV Credentials From Other Agencies

Accept and electronically verify Personal Identity Verification-compliant credentials from other federal, state, local, tribal, or territorial (SLTT) agencies.

In practice: Another agency's staff can use their own smart card to reach shared systems. The security team sets up the federation trust, and the sign-in service verifies the credential.

  • Priority marking P2
  • Audit and sanction status Zero-cycle
Supporting
Why this classification

Which other agencies' credentials are trusted is an agency policy decision; identity configures how they are verified.

  • Implement

Federation trust configuration commonly contributes to accepting PIV credentials from other agencies.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Federation trust and certificate acceptance settings
PS-3 PS: Personnel Security

Personnel Screening

a. Screen individuals prior to authorizing access to the information system; [items a.1 through a.7 and b omitted: record check, access approval and access list requirements, and rescreening]

In practice: HR owns background screening. The onboarding workflow does not grant access to systems with criminal justice information until HR marks the person's screening as done.

  • Priority marking P2
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Supporting
Why this classification

Screening itself is usually performed by human resources and security.

  • Implement

Screening-complete gates in onboarding workflows commonly contribute to authorizing access only after screening.

Platform families that commonly provide relevant capabilities
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Entra
Evidence commonly examined
  • Onboarding workflow showing screening approval step
PS-7 PS: Personnel Security

External Personnel Security

a. Establish personnel security requirements, including security roles and responsibilities for external providers;

b. Require external providers to comply with personnel security policies and procedures established by the organization;

c. Document personnel security requirements;

d. Require external providers to notify organizational personnel with information security responsibilities, organizational personnel with personnel security responsibilities, system/network administrators, or organizational personnel with account management responsibilities of any personnel transfers or terminations of external personnel who possess organizational credentials and/or badges, or who have system privileges within twenty-four (24) hours; and

e. Monitor provider compliance with personnel security requirements.

In practice: The agency sets security rules for providers; identity gives contractors and vendors sponsored accounts with an end date, re-confirmed by the sponsor and closed when the contract ends.

  • Priority marking P2
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Supporting
Why this classification

Contract terms and security requirements are usually owned by procurement and security.

  • Implement
  • Manage

Contractor and external identity lifecycle, sponsorship and expiry commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
Evidence commonly examined
  • External user sponsor and expiry report
AC-8 AC: Access Control

System Use Notification

a. Display a system use notification message to users before granting access to the system that provides privacy and security notices consistent with applicable laws, executive orders, directives, regulations, policies, standards, and guidelines and state that:

1. Users are accessing a restricted information system;

2. System usage may be monitored, recorded, and subject to audit;

3. Unauthorized use of the system is prohibited and subject to criminal and civil penalties; and

4. Use of the system indicates consent to monitoring and recording.

b. Retain the notification message or banner on the screen until users acknowledge the usage conditions and take explicit actions to log on to or further access the system; and

c. For publicly accessible systems:

1. Display system use information consistent with applicable laws, executive orders, directives, regulations, policies, standards, and guidelines, before granting further access to the publicly accessible system;

2. Display references, if any, to monitoring, recording, or auditing that are consistent with privacy accommodations for such systems that generally prohibit those activities; and

3. Include a description of the authorized uses of the system.

  • Priority marking P2
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Outside identity scope (GCA classification)
Why this classification

Display of a system use notification before access. Primary ownership usually sits with application, endpoint and operating system teams.

Not applicable Not applicable Not applicable
AC-11 AC: Access Control

Device Lock

a. Prevent further access to the system by initiating a device lock after a maximum of 30 minutes of inactivity and requiring the user to initiate a device lock before leaving the system unattended.

NOTE: In the interest of safety, devices that are: (1) part of a criminal justice conveyance; or (2) used to perform dispatch functions and located within a physically secure location; or (3) terminals designated solely for the purpose of receiving alert notifications (i.e., receive only terminals or ROT) used within physically secure location facilities that remain staffed when in operation, are exempt from this requirement.

b. Retain the device lock until the user reestablishes access using established identification and authentication procedures.

  • Priority marking P4
  • Existing from v5.9
  • Audit and sanction status Sanctionable
Outside identity scope (GCA classification)
Why this classification

Device lock after inactivity. Primary ownership usually sits with endpoint management and operating system configuration.

Not applicable Not applicable Not applicable

Summary

Primary
30
Identity platforms or processes are typically the principal means of implementing the requirement.
Supporting
14
Another discipline owns the requirement. Identity configuration or evidence contributes.
Outside identity scope (GCA classification)
2
Listed for completeness, with a one-line note on what the requirement is.

How to read the matrix

Priority marking
The priority the policy assigns to the requirement in its List of Priorities and section headings. Unmarked means the section carries no priority marking.
Existing from v5.9
True when the policy marks the requirement as existing from version 5.9, either by an asterisk in the List of Priorities or an Existing marking on the section, or, for a non-modernized section with no marking, because Section 1.4 treats it as existing.
Audit and sanction status
Under section 1.4 of the policy, beginning October 1, 2024, requirements that existed before modernization and Priority 1 requirements are the sanctionable set. Priority 2, 3 and 4 modernized requirements are in zero-cycle status from October 1, 2024 through September 30, 2027. This column applies that rule to each row as of the date shown on the page.
Identity relevance

Identity relevance is a GCA classification of whether identity capabilities are typically the principal means of implementing a requirement (Primary), contribute to a requirement owned by another discipline (Supporting), or usually sit outside identity work (Outside identity scope (GCA classification)).

It describes where primary implementation ownership usually sits. It is not a statement about whether identity configuration could be relevant to a particular incident, finding or environment. Every "Outside identity scope (GCA classification)" classification carries a rationale, and other classifications show one where GCA has recorded it, under "Why this classification" beside the label.

Platform families
Product families that commonly provide capabilities relevant to a requirement. A blank cell means GCA has not mapped a platform family to the requirement. It does not mean a product lacks a capability.
Evidence
Examples of artifacts commonly examined. The list is not complete, and it is not a statement that any artifact is sufficient. Assessors determine sufficiency.

Important notice

Purpose. This CJIS Security Policy identity traceability matrix is general educational reference material, written by Robert Ivey and published by GCA Technology Services ("GCA") to help organizations plan identity and access management work. It is not legal, audit, accounting or compliance advice, and it is not a substitute for advice from qualified professionals who know your environment.

No compliance determination. Whether an organization meets a requirement is decided by the applicable assessor, auditor, certifying body or regulator, applying the governing requirements to that organization's actual systems, policies and evidence. Nothing in this matrix states or implies that any organization, product, service or configuration meets or complies with any requirement, or that any assessment, audit, examination or certification will have any particular outcome.

Classifications are practice opinion. Relevance classifications, offering mappings, platform mappings and evidence examples are the author's professional judgment as of the date shown. They are not regulatory classifications and are not statements of the standard of care. Other qualified practitioners may reasonably classify requirements differently, and the right answer for a given environment depends on its facts.

Evidence examples are illustrative. Evidence listed is an example of artifacts commonly examined. It is not a complete list, and it is not a statement that any artifact is sufficient. Assessors determine sufficiency.

Source text controls. Requirement text and references come from the sources listed on this page. Where this matrix differs from a source, the source controls. Regulations, guidance and assessment methods change, so confirm current requirements with the issuing authority before relying on them.

Products and services. Platform names identify product families that commonly provide capabilities relevant to a requirement. A blank cell means GCA has not mapped that platform family to the requirement. It does not mean the product lacks a capability. GCA makes no representation about any third party's products, features, roadmaps or government authorization status, including FedRAMP, DoD Impact Levels and similar programs. Confirm capabilities with the vendor and authorization status with the authorizing program.

GCA services. Offering descriptions identify the type of GCA service that addresses an area. The scope, deliverables, terms and outcomes of any GCA engagement are defined only by a signed agreement and Statement of Work, and this page does not change those terms.

No relationship; no reliance. Reading or using this matrix does not create a client, advisory or other relationship with GCA or the author. To the fullest extent permitted by law, this material is provided "as is," without warranties of any kind, express or implied, including accuracy, completeness, merchantability and fitness for a particular purpose, and GCA is not liable for any decision made or action taken in reliance on it.

No client data. This matrix contains no client data. Any example organization is fictitious.

Version 1 · Prepared · Last reviewed · Reviewed every 90 days · View changelog

Microsoft and Microsoft Entra are trademarks of the Microsoft group of companies. SailPoint, IdentityIQ and Identity Security Cloud are trademarks or product names of SailPoint Technologies, Inc. or its affiliates. Netwrix is a trademark of Netwrix Corporation. Okta is a trademark of Okta, Inc. Ping Identity is a trademark of Ping Identity Corporation. CyberArk is a trademark of Palo Alto Networks, Inc. or its affiliates. BeyondTrust is a trademark of BeyondTrust Corporation. Delinea is a trademark of Delinea Inc. CJIS is a division of the Federal Bureau of Investigation, which does not endorse this page. All other trademarks belong to their respective owners. These names identify products and programs only and do not imply endorsement by, sponsorship by or affiliation with any of these companies or programs, except where a GCA partnership is expressly stated elsewhere on gca.net.

Changelog

  1. Version 1: First publication.

Frequently Asked Questions

What does advanced authentication mean in CJIS version 6.1?

Section 5.20.7.2 is titled Advanced Authentication and covers CJI access from an authorized mobile device. For account-level multifactor questions, use IA-2(1) and IA-2(2) in version 6.1, which set the general requirement.

Which CJIS requirements are sanctionable as of October 16, 2026?

Under Section 1.4, requirements that existed before modernization and Priority 1 requirements are sanctionable. In this matrix, 35 rows are sanctionable and 11 are zero-cycle. Two of the sanctionable rows, AU-2 and PS-5, depend on the asterisk in the policy's List of Priorities, because their section headings carry no Existing marking. Confirm local audit baselines with the agency that administers CJI access.

Are the NIST mappings official?

No. The policy does not state which NIST SP 800-53 revision it aligns to, so each mapping to Rev. 5 is GCA judgment. The policy text is quoted, and the mappings are GCA's practice opinion.

Is GCA affiliated with the FBI?

No. GCA is not affiliated with, and this page is not endorsed by, the Federal Bureau of Investigation or the CJIS Division.