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3.13.3 — Separate Admin from User

Separate user functionality from system management functionality.

Admin consoles, management interfaces, and configuration tools must be isolated from regular user access. Three levels of separation, from minimum to strongest:

Minimum: Logical access controls. Admin portals restricted by role — regular users get “Access Denied.” Conditional Access policies restrict admin console access to compliant devices.

Better: Separate management VLAN. Admin traffic on a dedicated network segment. Management interfaces only reachable from the management VLAN.

Best: Privileged Access Workstations (PAW). Dedicated hardware for admin tasks. The admin’s regular laptop handles email and browsing. The PAW handles server management. No cross-contamination.

The assessor will check: can a regular user’s browser reach the firewall management interface? Can an admin manage servers from the same session they use for email? If yes, separation is inadequate.


Your assessor needs a “yes” to every row:

#QuestionWhat “yes” looks like
1Is user functionality separated from system management functionality?Regular users can’t access admin consoles; admin traffic is isolated
2Are management interfaces restricted?Admin portals not reachable from the general user network

Documents they’ll review: System and communications protection policy; system security plan; system design documentation; network diagrams; system configuration settings showing management interface restrictions

People they’ll talk to: System or network administrators; personnel with information security responsibilities; system developers

Live demos they’ll ask for: Mechanisms implementing separation of user and management functionality


These are the actual questions. Have answers ready.

  • “Can a regular user access any admin console from their workstation?”
  • “Is admin traffic on a separate VLAN or subnet?”
  • “Do your admins use the same machine for email and server management?”
  • “Show me how admin console access is restricted.”
  • “What happens if a regular user tries to reach the firewall management interface?”

Admin consoles on user network. Anyone on the corporate network can reach the firewall management GUI. Restrict by IP or VLAN.

Same machine for everything. Admins browse the web, check email, AND manage servers from the same laptop. A PAW or at minimum separate browser profiles are needed.

No Conditional Access on admin portals. M365 admin center accessible from any device. Use Conditional Access to restrict to managed admin devices.

SSH/RDP open from user VLAN. Management protocols accessible from the general network. Restrict to management VLAN only.



RequirementWhy it matters here
3.1.6 — Two Hats, Two AccountsSeparate accounts supports separate management access
3.13.1 — Guard the BoundariesManagement VLAN is an internal boundary
3.1.5 — Minimum NecessaryLeast privilege restricts who reaches management interfaces

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CMMC Practice ID: SC.L2-3.13.3 | SPRS Weight: 1 point | POA&M Eligible: Yes