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Federal agencies and their contractors

How Identity and Access Management Supports Federal Zero Trust

Federal zero trust guidance puts identity first. OMB Memorandum M-22-09, dated January 26, 2022, sets identity requirements in its Section A. The CISA Zero Trust Maturity Model Version 2.0 (April 2023) describes the Identity pillar across four maturity stages, and NIST 800-207 (SP 800-207, August 2020) sets out the zero trust tenets quoted in this matrix. CISA has since moved its Zero Trust Maturity Model web page into its archive, which CISA says may not reflect current policy. CISA has not published a later version, and OMB memoranda issued in 2026, including M-26-14 and M-26-15, still refer to the model.

This page quotes all three sources, shows each Identity pillar function at every maturity stage, and shows where identity and access management work commonly contributes. The stage filter lets readers see one maturity stage at a time.

Status: as of October 16, 2026, no OMB memorandum rescinding or replacing M-22-09 was found, and OMB Memorandum M-26-18 (August 31, 2026) refers agencies to M-22-09 as existing OMB policy. Confirm the status with OMB before you rely on it.

Mappings to NIST SP 800-53 Rev. 5 are GCA judgment, not statements from OMB, CISA or NIST.

For CIOs and compliance leaders

Information as of Last verified OMB Memorandum M-22-09 (January 26, 2022), Section A Identity; CISA Zero Trust Maturity Model Version 2.0 (April 2023), Identity pillar; NIST SP 800-207 (August 2020), Section 2.1 tenets 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 cited source texts control. Read the full notice.

The matrix

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

Federal Zero Trust: OMB M-22-09 Identity, CISA Zero Trust Maturity Model Identity Pillar and NIST SP 800-207 Tenets identity traceability matrix. OMB Memorandum M-22-09 (January 26, 2022), Section A Identity; CISA Zero Trust Maturity Model Version 2.0 (April 2023), Identity pillar; NIST SP 800-207 (August 2020), Section 2.1 tenets. Information as of October 16, 2026.
Requirement Requirement text ZTMM identity function / ZTMM maturity stage Identity relevance (GCA classification) GCA approach Platform families that commonly provide relevant capabilities Evidence commonly examined
M-22-09-A1 M2209: OMB M-22-09, Section A Identity

Agencies must employ centralized identity management systems for agency users that can be integrated into applications and common platforms.

In practice: Staff sign in to email, ticketing and HR apps through one central identity provider, and new applications are connected to it instead of keeping their own user lists.

  • ZTMM identity function Not applicable
  • ZTMM maturity stage Not applicable
Primary
  • Assess
  • Implement

A central identity provider and identity governance platform that applications integrate with commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
Evidence commonly examined
  • Identity provider and application integration inventory
M-22-09-A2 M2209: OMB M-22-09, Section A Identity

Agencies must use strong MFA throughout their enterprise.

In practice: Every employee signs in with a second factor, such as a security key or authenticator app, whether they use email, the VPN or an internal app, and exceptions are listed.

  • ZTMM identity function Not applicable
  • ZTMM maturity stage Not applicable
Primary
  • Implement

Enterprise-wide multi-factor enforcement through the identity provider 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
M-22-09-A2-1 M2209: OMB M-22-09, Section A Identity

MFA must be enforced at the application layer, instead of the network layer.

In practice: Each application checks the second factor at sign-in through the identity provider, so being on the office network does not skip the MFA prompt.

  • ZTMM identity function Not applicable
  • ZTMM maturity stage Not applicable
Primary
  • Implement

Per-application sign-in policy enforced by the identity provider, rather than network location, commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Per-application sign-in policy export
  • Network location exceptions list
M-22-09-A2-2 M2209: OMB M-22-09, Section A Identity

For agency staff, contractors, and partners, phishing-resistant MFA is required.

In practice: Employees, contractors and partners enroll a security key or certificate-based credential; a texted code is no longer accepted for routine access to agency systems.

  • ZTMM identity function Not applicable
  • ZTMM maturity stage Not applicable
Primary
  • Implement

FIDO2 security keys, certificate-based sign-in and PIV-style credentials, with enrollment for contractors and partners, commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Authentication method policy export
  • Phishing-resistant method registration report by user type
M-22-09-A2-4 M2209: OMB M-22-09, Section A Identity

Password policies must not require use of special characters or regular rotation.

In practice: The password policy drops forced special characters and scheduled resets; users change a password only when there is a reason to, and the setting lives on the identity provider.

  • ZTMM identity function Not applicable
  • ZTMM maturity stage Not applicable
Primary
  • Implement

Password policy settings on the identity provider commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Password policy configuration export
M-22-09-A2-N M2209: OMB M-22-09, Section A Identity

Agencies must require their users to use a phishing-resistant method to access agency-hosted accounts. For routine self-service access by agency staff, contractors, and partners, agency systems must discontinue support for authentication methods that fail to resist phishing, including protocols that register phone numbers for SMS or voice calls, supply one-time codes, or receive push notifications.

In practice: For routine self-service access, the identity team turns off SMS, voice call, one-time code and push approval for staff, contractors and partners, then moves them to security keys or certificates.

  • ZTMM identity function Not applicable
  • ZTMM maturity stage Not applicable
Primary
  • Assess
  • Implement

Retiring SMS, voice, one-time code and push methods for staff, contractors and partners, and moving them to phishing-resistant methods, commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Authentication method policy showing disabled methods
  • Method usage report before and after retirement
M-22-09-A3 M2209: OMB M-22-09, Section A Identity

When authorizing users to access resources, agencies must consider at least one device-level signal alongside identity information about the authenticated user.

In practice: An access policy checks whether the laptop is registered and healthy, as well as who the user is, before it opens a sensitive application.

  • ZTMM identity function Not applicable
  • ZTMM maturity stage Not applicable
Primary
  • Implement

Device state and registration signals used in access policy commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Access policy requiring a device state signal
  • Device registration report
SP800-207-T3 SP800207: NIST SP 800-207, Section 2.1 tenets

Access to individual enterprise resources is granted on a per-session basis. Trust in the requester is evaluated before the access is granted. Access should also be granted with the least privileges needed to complete the task. This could mean only “sometime recently” for this particular transaction and may not occur directly before initiating a session or performing a transaction with a resource. However, authentication and authorization to one resource will not automatically grant access to a different resource.

In practice: Access to a resource is decided for each session, with the least privilege the task needs, and an administrator's elevation ends when the task is done.

  • ZTMM identity function Not applicable
  • ZTMM maturity stage Not applicable
Primary
  • Assess
  • Implement
  • Manage

Per-session access decisions, least privilege and just-in-time elevation commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Session and reauthentication interval policy export
  • Privileged elevation approval records
SP800-207-T4 SP800207: NIST SP 800-207, Section 2.1 tenets

Access to resources is determined by dynamic policy—including the observable state of client identity, application/service, and the requesting asset—and may include other behavioral and environmental attributes. An organization protects resources by defining what resources it has, who its members are (or ability to authenticate users from a federated community), and what access to resources those members need. For zero trust, client identity can include the user account (or service identity) and any associated attributes assigned by the enterprise to that account or artifacts to authenticate automated tasks. Requesting asset state can include device characteristics such as software versions installed, network location, time/date of request, previously observed behavior, and installed credentials. Behavioral attributes include, but not limited to, automated subject analytics, device analytics, and measured deviations from observed usage patterns. Policy is the set of access rules based on attributes that an organization assigns to a subject, data asset, or application. Environmental attributes may include such factors as requestor network location, time, reported active attacks, etc. These rules and attributes are based on the needs of the business process and acceptable level of risk. Resource access and action permission policies can vary based on the sensitivity of the resource/data. Least privilege principles are applied to restrict both visibility and accessibility.

In practice: The access policy weighs who the user is, the state of the device and unusual behavior, all backed by a role model that owners have reviewed.

  • ZTMM identity function Not applicable
  • ZTMM maturity stage Not applicable
Primary
  • Assess
  • Implement
  • Manage

Access policy that weighs identity attributes, device state and behavior, with a reviewed role model behind it, commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Access policy configuration export
  • Identity attribute and group model documentation
SP800-207-T6 SP800207: NIST SP 800-207, Section 2.1 tenets

All resource authentication and authorization are dynamic and strictly enforced before access is allowed. This is a constant cycle of obtaining access, scanning and assessing threats, adapting, and continually reevaluating trust in ongoing communication. An enterprise implementing a ZTA would be expected to have Identity, Credential, and Access Management (ICAM) and asset management systems in place. This includes the use of multifactor authentication (MFA) for access to some or all enterprise resources. Continual monitoring with possible reauthentication and reauthorization occurs throughout user transactions, as defined and enforced by policy (e.g., time-based, new resource requested, resource modification, anomalous subject activity detected) that strives to achieve a balance of security, availability, usability, and cost-efficiency.

In practice: Users pass MFA before each resource opens, and the identity provider keeps re-evaluating the session, asking for re-authentication when risk goes up.

  • ZTMM identity function Not applicable
  • ZTMM maturity stage Not applicable
Primary
  • Assess
  • Implement
  • Manage

Multi-factor authentication, continuous session evaluation and policy-driven re-authentication commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • MFA and re-authentication policy export
  • Identity risk detection configuration
ZTMM-ACCESS-ADV ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Access Management

Agency authorizes need-based and session-based access, including for privileged access request, that is tailored to actions and resources.

In practice: An administrator asks for elevated rights for one task, a second person signs off, and the elevation lasts only for that session and that resource.

  • ZTMM identity function Access Management
  • ZTMM maturity stage Advanced
Primary
  • Assess
  • Implement
  • Manage

Session-based and approval-gated elevation for privileged roles commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Access assignment export showing expiry and approval settings
  • Certification campaign export with per-reviewer decisions
ZTMM-ACCESS-INIT ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Access Management

Agency authorizes access, including for privileged access requests, that expires with automated review.

In practice: Access is granted for a set period and expires on its own; an automated review campaign asks the owner whether to renew it.

  • ZTMM identity function Access Management
  • ZTMM maturity stage Initial
Primary
  • Assess
  • Implement
  • Manage

Time-limited assignments with automated review campaigns commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Access assignment export showing expiry and approval settings
  • Certification campaign export with per-reviewer decisions
ZTMM-ACCESS-OPT ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Access Management

Agency uses automation to authorize just-in-time and just-enough access tailored to individual actions and individual resource needs.

In practice: Automation grants just-in-time, just-enough access for a specific task, built on a role and entitlement model that owners have reviewed.

  • ZTMM identity function Access Management
  • ZTMM maturity stage Optimal
Primary
  • Assess
  • Implement
  • Manage

Automated just-in-time and just-enough access commonly contributes here, built on a reviewed role and entitlement model.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Access assignment export showing expiry and approval settings
  • Certification campaign export with per-reviewer decisions
ZTMM-ACCESS-TRAD ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Access Management

Agency authorizes permanent access with periodic review for both privileged and unprivileged accounts.

In practice: Managers and system owners review who holds standing access, including administrator accounts, in periodic access review campaigns.

  • ZTMM identity function Access Management
  • ZTMM maturity stage Traditional
Primary
  • Assess

Baseline stage. Access review campaigns commonly cover standing access, including privileged accounts.

Not mapped
Evidence commonly examined
  • Access assignment export showing expiry and approval settings
  • Certification campaign export with per-reviewer decisions
ZTMM-AUTH-ADV ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Authentication

Agency begins to authenticate all identity using phishing-resistant MFA and attributes, including initial implementation of password-less MFA via FIDO2 or PIV.

In practice: Staff begin signing in with security keys or smart cards, and passwordless sign-in is rolled out one group at a time, starting with administrators.

  • ZTMM identity function Authentication
  • ZTMM maturity stage Advanced
Primary
  • Assess
  • Implement
  • Manage

Phishing-resistant methods such as FIDO2 security keys and certificate-based sign-in commonly contribute here, along with passwordless rollout.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Authentication method and MFA policy export
  • MFA registration and exclusion report
ZTMM-AUTH-INIT ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Authentication

Agency authenticates identity using MFA, which may include passwords as one factor and requires validation of multiple entity attributes (e.g., locale or activity).

In practice: MFA is turned on through the identity provider for staff, and the short list of accounts excluded from it is written down and reviewed.

  • ZTMM identity function Authentication
  • ZTMM maturity stage Initial
Primary
  • Assess
  • Implement
  • Manage

MFA enrollment and enforcement through the identity provider, sign-in conditions that check attributes such as location or activity, and a documented list of exclusions commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Authentication method and MFA policy export
  • MFA registration and exclusion report
ZTMM-AUTH-OPT ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Authentication

Agency continuously validates identity with phishing-resistant MFA, not just when access is initially granted.

In practice: After the first sign-in, the identity provider keeps watching session signals and asks the user to re-authenticate with a security key when something changes.

  • ZTMM identity function Authentication
  • ZTMM maturity stage Optimal
Primary
  • Assess
  • Implement
  • Manage

Continuous evaluation of sign-in and session signals, with policy-driven re-authentication, commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Authentication method and MFA policy export
  • MFA registration and exclusion report
ZTMM-AUTH-TRAD ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Authentication

Agency authenticates identity using either passwords or multi-factor authentication (MFA) with static access for entity identity.

In practice: An assessment lists which accounts still sign in with a password alone and which applications have no MFA, giving the agency a baseline to work from.

  • ZTMM identity function Authentication
  • ZTMM maturity stage Traditional
Primary
  • Assess

Baseline stage. Assessment commonly inventories which accounts rely on passwords alone and where MFA is absent.

Not mapped
Evidence commonly examined
  • Authentication method and MFA policy export
  • MFA registration and exclusion report
ZTMM-AUTO-ADV ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Automation and Orchestration Capability

Agency manually orchestrates privileged user identities and automates orchestration of all identities with integration across all environments.

In practice: Joiner, mover and leaver processing runs across cloud and on-premises systems, while administrators' accounts stay under manual, sign-off based handling.

  • ZTMM identity function Automation and Orchestration
  • ZTMM maturity stage Advanced
Primary
  • Assess
  • Implement
  • Manage

Lifecycle automation across all environments, with privileged identities still handled manually, commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
Evidence commonly examined
  • Joiner, mover and leaver workflow configuration and sample event records
ZTMM-AUTO-INIT ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Automation and Orchestration Capability

Agency manually orchestrates privileged and external identities and automates orchestration of non-privileged users and of self-managed entities.

In practice: A new hire in the HR system triggers account creation, role changes update access, and leavers are disabled automatically; privileged accounts are still handled by hand.

  • ZTMM identity function Automation and Orchestration
  • ZTMM maturity stage Initial
Primary
  • Assess
  • Implement
  • Manage

Automating joiner, mover and leaver processing for non-privileged accounts commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
Evidence commonly examined
  • Joiner, mover and leaver workflow configuration and sample event records
ZTMM-AUTO-OPT ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Automation and Orchestration Capability

Agency automates orchestration of all identities with full integration across all environments based on behaviors, enrollments, and deployment needs.

In practice: The HR system and other authoritative sources drive the full account lifecycle for every identity, adjusting access as roles and behavior change.

  • ZTMM identity function Automation and Orchestration
  • ZTMM maturity stage Optimal
Primary
  • Assess
  • Implement
  • Manage

Fully automated lifecycle driven by authoritative sources and behavior signals commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
Evidence commonly examined
  • Joiner, mover and leaver workflow configuration and sample event records
ZTMM-AUTO-TRAD ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Automation and Orchestration Capability

Agency manually orchestrates (onboards, offboards, and disables) self-managed identities (users and entities), with little integration, and performs regular review.

In practice: HR tickets go to the help desk, whose staff create and disable accounts by hand, and a periodic review looks for accounts that were missed.

  • ZTMM identity function Automation and Orchestration
  • ZTMM maturity stage Traditional
Primary
  • Assess

Baseline stage. Assessment commonly maps manual onboarding, offboarding and disabling steps and the periodic review that looks for missed accounts.

Not mapped
Evidence commonly examined
  • Joiner, mover and leaver workflow configuration and sample event records
ZTMM-STORES-ADV ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Identity Stores

Agency begins to securely consolidate and integrate some self-managed and hosted identity stores.

In practice: Duplicate directories are merged where it makes sense, and identity correlation links each person's accounts across the remaining stores.

  • ZTMM identity function Identity Stores
  • ZTMM maturity stage Advanced
Primary
  • Assess
  • Implement
  • Manage

Directory consolidation and identity correlation across stores commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
Evidence commonly examined
  • Directory and identity store inventory with synchronization and federation configuration
ZTMM-STORES-INIT ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Identity Stores

Agency has a combination of self-managed identity stores and hosted identity store(s) (e.g., cloud or other agency) with minimal integration between the store(s) (e.g., Single Sign-on.).

In practice: Cloud applications use single sign-on, and an on-premises directory is synchronized to a cloud directory so staff keep one account across both.

  • ZTMM identity function Identity Stores
  • ZTMM maturity stage Initial
Primary
  • Assess
  • Implement
  • Manage

Single sign-on and hybrid identity synchronization between on-premises and cloud directories commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
Evidence commonly examined
  • Directory and identity store inventory with synchronization and federation configuration
ZTMM-STORES-OPT ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Identity Stores

Agency securely integrates their identity stores across all partners and environments as appropriate.

In practice: Partner agencies sign in through federation with their own identity providers, and identity data is unified across on-premises and cloud environments.

  • ZTMM identity function Identity Stores
  • ZTMM maturity stage Optimal
Primary
  • Assess
  • Implement
  • Manage

Federation with partner and agency identity providers, and unified identity data across environments, commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
Evidence commonly examined
  • Directory and identity store inventory with synchronization and federation configuration
ZTMM-STORES-TRAD ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Identity Stores

Agency only uses self-managed, on-premises (i.e., planned, deployed, and maintained by agency) identity stores.

In practice: The team inventories the on-premises directories the agency runs and the applications that depend on each one, which shows what would need to move later.

  • ZTMM identity function Identity Stores
  • ZTMM maturity stage Traditional
Primary
  • Assess

Baseline stage. Assessment commonly inventories on-premises directories and the applications that depend on them.

Not mapped
Evidence commonly examined
  • Directory and identity store inventory with synchronization and federation configuration
M-22-09-A2-3 M2209: OMB M-22-09, Section A Identity

For public users, phishing-resistant MFA must be an option.

In practice: The application owner runs the public-facing service; identity configures its customer sign-in to offer residents a passkey or security key as one option.

  • ZTMM identity function Not applicable
  • ZTMM maturity stage Not applicable
Supporting
Why this classification

Public-facing services are usually owned by the application owner; identity configures sign-in options.

  • Implement

Customer identity platform configuration that offers passkeys or security keys commonly contributes here, where an engagement covers public-facing applications. For in-scope public-facing agency websites, OMB M-26-18 (August 31, 2026) also requires agencies to offer Login.gov as a sign-on option.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Public-facing sign-in option configuration
SP800-207-T7 SP800207: NIST SP 800-207, Section 2.1 tenets

The enterprise collects as much information as possible about the current state of assets, network infrastructure and communications and uses it to improve its security posture. An enterprise should collect data about asset security posture, network traffic and access requests, process that data, and use any insight gained to improve policy creation and enforcement. This data can also be used to provide context for access requests from subjects (see Section 3.3.1).

In practice: The architecture team gathers data about assets and access requests; identity contributes request telemetry that is used to tune access policy.

  • ZTMM identity function Not applicable
  • ZTMM maturity stage Not applicable
Supporting
Why this classification

Enterprise telemetry collection is usually owned by security architecture and operations; identity supplies access-request data.

  • Assess
  • Implement
  • Manage

Identity and access request telemetry feeding policy tuning commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
Evidence commonly examined
  • Identity log source configuration
  • Access policy tuning records
ZTMM-GOV-ADV ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Governance Capability

Agency implements identity policies for enterprise-wide enforcement with automation and updates policies periodically.

In practice: Policy is written as configuration, enforced automatically by the identity platform, and updated on a regular cycle by the policy owner.

  • ZTMM identity function Governance
  • ZTMM maturity stage Advanced
Supporting
Why this classification

Identity policy is usually set by the security policy owner; identity platforms enforce it.

  • Assess
  • Implement
  • Manage

Policy expressed as configuration, with automated enforcement and periodic updates, commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
Evidence commonly examined
  • Identity policy documents cross-referenced to enforcing configuration
ZTMM-GOV-INIT ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Governance Capability

Agency defines and begins implementing identity policies for enterprise-wide enforcement with minimal automation and manual updates.

In practice: Leadership defines identity policy for the whole agency, and the identity team starts turning those rules into settings with some automation.

  • ZTMM identity function Governance
  • ZTMM maturity stage Initial
Supporting
Why this classification

Identity policy is usually set by the security policy owner; identity platforms enforce it.

  • Assess
  • Implement
  • Manage

Defining identity policy for enterprise-wide enforcement, with initial automation, commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
Evidence commonly examined
  • Identity policy documents cross-referenced to enforcing configuration
ZTMM-GOV-OPT ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Governance Capability

Agency implements and fully automates enterprise-wide identity policies for all users and entities across all systems with continuous enforcement and dynamic updates.

In practice: The policy owner sets identity rules once; tools enforce them across all systems continuously and flag any setting that drifts from the rule.

  • ZTMM identity function Governance
  • ZTMM maturity stage Optimal
Supporting
Why this classification

Identity policy is usually set by the security policy owner; identity platforms enforce it.

  • Assess
  • Implement
  • Manage

Continuous policy enforcement with drift detection across all systems commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
Evidence commonly examined
  • Identity policy documents cross-referenced to enforcing configuration
ZTMM-GOV-TRAD ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Governance Capability

Agency implements identity policies (authentication, credentials, access, lifecycle, etc.) with enforcement via static technical mechanisms and manual review.

In practice: A policy owner sets identity rules for passwords and access; identity teams apply them as static settings and review them by hand.

  • ZTMM identity function Governance
  • ZTMM maturity stage Traditional
Supporting
Why this classification

Identity policy is usually set by the security policy owner; identity platforms enforce it.

  • Assess

Baseline stage. Assessment commonly inventories identity policies, the settings that enforce each one and how each is reviewed today.

Not mapped
Evidence commonly examined
  • Identity policy documents cross-referenced to enforcing configuration
ZTMM-RISK-ADV ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Risk Assessments

Agency determines identity risk with some automated analysis and dynamic rules to inform access decisions and response activities.

In practice: The security team's tooling scores identity risk, and identity policy responds automatically, for example asking for a step-up MFA or blocking a sign-in.

  • ZTMM identity function Risk Assessments
  • ZTMM maturity stage Advanced
Supporting
Why this classification

Identity risk analytics are usually operated by security operations; identity supplies signals and enforces responses.

  • Assess
  • Implement
  • Manage

Identity risk scoring with automated policy responses such as step-up or block commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Identity risk detection configuration and alert records
ZTMM-RISK-INIT ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Risk Assessments

Agency determines identity risk using manual methods and static rules to support visibility.

In practice: The security team reads sign-in risk and account reports by hand and applies fixed rules, using identity data as the input.

  • ZTMM identity function Risk Assessments
  • ZTMM maturity stage Initial
Supporting
Why this classification

Identity risk analytics are usually operated by security operations; identity supplies signals and enforces responses.

  • Assess
  • Implement
  • Manage

Manual review of sign-in risk and account reports, with static rules, commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Identity risk detection configuration and alert records
ZTMM-RISK-OPT ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Risk Assessments

Agency determines identity risk in real time based on continuous analysis and dynamic rules to deliver ongoing protection.

In practice: A threat detection service run by the security team scores risk in real time, and the identity provider feeds it sign-in events and acts on its decisions.

  • ZTMM identity function Risk Assessments
  • ZTMM maturity stage Optimal
Supporting
Why this classification

Identity risk analytics are usually operated by security operations; identity supplies signals and enforces responses.

  • Assess
  • Implement
  • Manage

Real-time identity threat detection and response integrated with access policy commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • Okta / Ping
Evidence commonly examined
  • Identity risk detection configuration and alert records
ZTMM-RISK-TRAD ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Risk Assessments

Agency makes limited determinations for identity risk (i.e., likelihood that an identity is compromised).

In practice: Another team owns risk analytics; identity provides account and sign-in data, and a gap review notes where identity risk is not measured at all.

  • ZTMM identity function Risk Assessments
  • ZTMM maturity stage Traditional
Supporting
Why this classification

Identity risk analytics are usually operated by security operations; identity supplies signals and enforces responses.

  • Assess

Baseline stage. Assessment commonly identifies where identity risk is not measured at all.

Not mapped
Evidence commonly examined
  • Identity risk detection configuration and alert records
ZTMM-VIS-ADV ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Visibility and Analytics Capability

Agency performs automated analysis across some user and entity activity log types and augments collection to address gaps in visibility.

In practice: Analytics run by the security team span several log types, and identity adds missing log sources so that fewer activities go unseen.

  • ZTMM identity function Visibility and Analytics
  • ZTMM maturity stage Advanced
Supporting
Why this classification

Log analytics are usually operated by security operations; identity supplies identity logs.

  • Assess
  • Implement
  • Manage

Automated analytics across identity log types, and onboarding of missing log sources, commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Identity log source inventory with retention and forwarding settings
ZTMM-VIS-INIT ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Visibility and Analytics Capability

Agency collects user and entity activity logs and performs routine manual analysis and some automated analysis, with limited correlation between log types.

In practice: Security operations owns the central log platform; identity logs are routed there, though they are only loosely correlated with other log types.

  • ZTMM identity function Visibility and Analytics
  • ZTMM maturity stage Initial
Supporting
Why this classification

Log analytics are usually operated by security operations; identity supplies identity logs.

  • Assess
  • Implement
  • Manage

Routing identity logs to a central platform, with limited correlation, commonly contributes here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Identity log source inventory with retention and forwarding settings
ZTMM-VIS-OPT ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Visibility and Analytics Capability

Agency maintains comprehensive visibility and situational awareness across enterprise by performing automated analysis over user activity log types, including behavior-based analytics.

In practice: The security team's analytics correlate identity activity with other telemetry to spot unusual behavior, using identity logs as one important input.

  • ZTMM identity function Visibility and Analytics
  • ZTMM maturity stage Optimal
Supporting
Why this classification

Log analytics are usually operated by security operations; identity supplies identity logs.

  • Assess
  • Implement
  • Manage

Behavior-based analytics across identity activity, correlated with other telemetry, commonly contribute here.

Platform families that commonly provide relevant capabilities
  • Entra
  • SailPoint ISC
  • SailPoint IIQ
  • Netwrix IDM
  • Okta / Ping
  • CyberArk / BeyondTrust / Delinea
Evidence commonly examined
  • Identity log source inventory with retention and forwarding settings
ZTMM-VIS-TRAD ZTMM: CISA Zero Trust Maturity Model 2.0, Identity pillar

Visibility and Analytics Capability

Agency collects user and entity activity logs, especially for privileged credentials, and performs some routine manual analysis.

In practice: The logging team collects activity logs; identity supplies sign-in and administrator logs, especially for privileged accounts, for routine manual review.

  • ZTMM identity function Visibility and Analytics
  • ZTMM maturity stage Traditional
Supporting
Why this classification

Log analytics are usually operated by security operations; identity supplies identity logs.

  • Assess

Baseline stage. Identity log collection, especially for privileged credentials, commonly contributes here.

Not mapped
Evidence commonly examined
  • Identity log source inventory with retention and forwarding settings

Summary

Primary
26
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)
0
Listed for completeness, with a one-line note on what the requirement is.

How to read the matrix

ZTMM identity function
The function name used in Table 2, Identity Pillar, of the CISA Zero Trust Maturity Model Version 2.0. Applies to ZTMM rows only; other rows show Not applicable.
ZTMM maturity stage
The four maturity stages the model uses for each function: Traditional, Initial, Advanced and Optimal. Applies to ZTMM rows only; other rows show Not applicable. Each function appears once per stage.
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 Federal Zero Trust 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. OMB, CISA and NIST do 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

Is M-22-09 in effect as of October 16, 2026?

As of October 16, 2026, we found no OMB memorandum that rescinds or replaces M-22-09, and OMB Memorandum M-26-18, issued August 31, 2026, refers agencies to M-22-09 as existing OMB policy. Confirm the status with OMB before you rely on it.

What is the phishing-resistant MFA requirement?

For agency staff, contractors and partners, M-22-09 requires phishing-resistant MFA. For routine self-service access, agency systems must discontinue methods that fail to resist phishing, including SMS or voice registration, one-time codes and push notifications.

Which NIST SP 800-207 tenets are reproduced?

Tenets 3, 4, 6 and 7, which touch identity. Tenets 1, 2 and 5 are not reproduced on this page. The quoted text is from NIST SP 800-207, August 2020, Section 2.1.

Is GCA affiliated with OMB, CISA or NIST?

No. GCA is not affiliated with, and this page is not endorsed by, the Office of Management and Budget, CISA or NIST.