CIS Control 5.1: Establish and Maintain an Inventory of Accounts

What this means

Control 5.1 mandates that your organization document and actively manage every account with system access. This includes regular employees, contractors, service accounts, and administrators. Your inventory must capture essential metadata: real name, username, start and stop dates, and department assignment. Critically, you must validate on at least a quarterly schedule that every active account belongs to an authorized user who still requires access—this recurring review catches accounts that should have been deprovisioned.

How to comply

1. 1.Identify all systems and applications where accounts exist (directories, cloud platforms, databases, applications)
2. 2.Create a centralized inventory document or tool that captures user name, username, start date, stop date, department, and account type (user vs. administrator)
3. 3.Conduct an initial comprehensive account audit across all systems to populate your baseline inventory
4. 4.Establish a quarterly review schedule where department managers or system owners validate that all active accounts are still authorized
5. 5.Document and investigate any orphaned accounts (accounts with no owner or end date), then disable or remove them
6. 6.Maintain a change log that tracks new accounts created, accounts terminated, and access level changes
7. 7.Automate account discovery where possible to catch accounts created outside formal provisioning processes
8. 8.Define and enforce account lifecycle policies (provisioning, access reviews, deprovisioning)

Evidence auditors look for

• Current account inventory spreadsheet or database with at least 95% coverage across all systems
• Quarterly access review sign-off emails from department managers confirming active accounts are authorized
• Evidence of account deprovisioning actions taken in response to quarterly reviews
• System access logs or reports showing all active user and admin accounts at date of review
• Documentation of the quarterly review process, schedule, and ownership
• Change log showing new account approvals and termination dates for removed accounts
• Proof of investigation and remediation for any orphaned or suspicious accounts found during reviews

Frequently asked questions

GRCWatch automatically discovers accounts across your infrastructure, maintains a unified inventory, and triggers quarterly validation workflows—so you spend minutes confirming authorization instead of hours hunting accounts across disconnected systems.

See how GRCWatch handles this control automatically

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