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MFA and Authentication Standard Template

A fill-in authentication standard built on NIST SP 800-63B-4: assurance tiers per user population, which factors are allowed at each tier, phishing-resistant requirements, reauthentication timeouts, password rules and account recovery.

An authentication standard turns the policy line "MFA is required" into decisions an engineer can configure: which factors are allowed for which users, which must be phishing-resistant, how long a session lasts, and how someone gets back in after losing a device. This template uses the authenticator assurance levels (AAL1 to AAL3) of NIST SP 800-63B-4 as its spine, because they are public, specific and widely accepted by auditors. Requirements quoted from NIST are marked (NIST); everything else is a recommended default you should adjust.

How to use this template

  1. Assign every user population to a tier in section 2. Start with privileged users, because that tier has the least room for exceptions.
  2. Mark each factor in section 3 as allowed or not for each tier in your environment. Check which factors your applications actually support: the Phishing-Resistant MFA Support Matrix shows that many SaaS apps support passkeys but few let an admin require them.
  3. Set session values in section 4 and configure them in your IdP and in each app's own session settings.
  4. Write the recovery procedure in section 6 before you enforce anything. Recovery is where attackers go once MFA is in place.
  5. Have the standard approved under your IAM policy and review it every [12] months.

Owner: [Identity team lead] | Approved: [date] | Applies to: [workforce / customers / both]

1. Definitions

  • Phishing-resistant: NIST recognizes two methods, channel binding and verifier name binding (Sec. 3.2.5). Authenticators that rely on the user typing or approving an output, including OTP codes and out-of-band push or SMS, "SHALL NOT be considered phishing-resistant" (NIST). In practice this means WebAuthn/FIDO2 passkeys and security keys, and smart card or certificate-based authentication.
  • Syncable authenticator: a passkey whose private key can be copied to other devices through a sync service (synced passkey). Allowed at AAL2; "syncable authenticators SHALL NOT be used at AAL3" (NIST).
  • Restricted authenticator: the only one NIST names is the public telephone network (SMS or voice) for out-of-band codes. If you offer it you must offer a non-restricted alternative, tell users about its risks, and plan for its removal (NIST, Sec. 3.2.9).

See also: AAL, phishing-resistant MFA, phishable MFA.

2. Tiers by population

Tier Who Target AAL Phishing-resistant Notes
T0 Privileged Domain, cloud and IdP admins; break-glass; CI/CD and secrets admins; [others] AAL3 Required (NIST at AAL3) Device-bound keys only (no synced passkeys)
T1 Workforce All employees and contractors AAL2 Required by [date]; until then strongly preferred NIST: AAL2 verifiers must offer a phishing-resistant option, and federal agencies must require it for staff, contractors and partners
T2 Customers and partners with admin rights in our product [ ] AAL2 Offered, admin-enforceable
T3 Customers End users of [product] AAL1 or AAL2 by risk Offered Step up to AAL2 for [payments, profile change, export]

Guidance: if you are not a US federal agency, the "require at AAL2" rule does not bind you, but it is the clearest benchmark to cite when arguing for phishing-resistant MFA across the workforce. OMB M-22-09 set the same direction for federal agencies.

3. Allowed factors by tier

Factor Phishing-resistant T0 T1 T2 T3 Notes
Device-bound passkey or FIDO2 security key Yes Allowed Allowed Allowed Allowed Preferred everywhere
Synced passkey Yes Not allowed Allowed Allowed Allowed Not permitted at AAL3
Smart card / PIV / certificate-based authentication Yes Allowed Allowed [ ] No Needs PKI
Platform authenticator with device-bound key (e.g., Windows Hello for Business) Yes [Allowed if device-bound and managed] Allowed [ ] [ ]
Push approval with number matching No No Transitional until [date] Allowed Allowed Reduces MFA fatigue, does not stop AitM proxies
TOTP app No No Transitional until [date] Allowed Allowed
SMS or voice OTP No (restricted) No No No Fallback only, with a non-restricted alternative offered
Email OTP or magic link No No No No [Allowed for AAL1 only]
Password alone No No No No AAL1 only

4. Sessions and reauthentication

NIST SP 800-63B-4 sets these limits (Sec. 2):

Level Overall session limit Inactivity limit
AAL1 SHOULD be no more than 30 days MAY be applied, not required
AAL2 SHOULD be no more than 24 hours SHOULD be no more than 1 hour
AAL3 SHALL be no more than 12 hours SHOULD be no more than 15 minutes

Our settings:

Tier Max session Idle timeout Reauthenticate for
T0 [12 hours] [15 minutes] Every privilege elevation
T1 [24 hours] [1 hour, or device lock on managed devices] [sensitive apps, admin portals]
T2 [ ] [ ] [ ]
T3 [ ] [ ] [step-up actions]

Guidance: set the value in the IdP and in each application. A short IdP session does not end a long-lived app session or refresh token. Where you can, bind sessions to the device (see token protection and DBSC) so a stolen cookie is not enough; see session cookie theft.

5. Passwords (where still used)

These rules are from NIST SP 800-63B-4 Sec. 3.1.1:

  • Minimum length 15 characters when the password is the only factor; minimum 8 when it is used only as part of MFA (NIST).
  • No composition rules such as required mixtures of character types (NIST).
  • No periodic forced change; force a change only on evidence of compromise (NIST).
  • Check new passwords against a blocklist of commonly used, expected or compromised passwords (NIST).
  • Allow password managers and paste. [Our maximum length: 64 or more].

6. Enrollment and account recovery

NIST SP 800-63B-4 Sec. 4.2 recognizes four recovery methods: saved recovery codes, issued recovery codes, recovery contacts, and repeated identity proofing. "In all cases, account recovery SHALL cause a notification to be sent to the subscriber or their designee" (NIST).

Our rules:

  • Users enroll at least two phishing-resistant authenticators (for example, a security key plus a platform passkey) so losing one is not a recovery event.
  • First enrollment uses [a Temporary Access Pass issued after identity verification / in-person check / existing strong session]; see temporary access pass.
  • Help desk MFA resets for T0 and T1 require [live video ID check against HR photo / manager callback on a known number / in-person]. Knowledge questions and caller ID are not sufficient.
  • Every recovery and every new authenticator registration notifies the user on a channel other than the one used to recover, and alerts the security team for T0.
  • Registering a new MFA method requires an existing strong authentication or the recovery process above. Protect the registration page with the same conditions as sign-in.
  • T0 recovery requires two people.

Guidance: the MGM Resorts and Okta customer super admin takeovers began with help desk resets. See account recovery and help desk social engineering.

7. Legacy protocols and exceptions

  • Legacy authentication that cannot do MFA (basic auth, older IMAP/POP/SMTP clients) is blocked. Exceptions are listed in [register] with an end date.
  • Accounts that cannot use MFA (shared kiosks, some service integrations) are listed with a compensating control (network restriction, device restriction, no admin rights) and reviewed [quarterly].
  • Non-human identities follow the NHI policy, not this standard.

8. Metrics

Metric Target Current
T0 accounts using only phishing-resistant methods 100% [ ]
T1 users with a phishing-resistant method registered [ ]% by [date] [ ]
Sign-ins using phishing-resistant methods [ ]% [ ]
SMS/voice still registered (T1) 0 by [date] [ ]
Open MFA exceptions past expiry 0 [ ]

Control mapping

Section NIST SP 800-53 Rev. 5 ISO/IEC 27001:2022 Annex A
2, 3 Tiers and factors IA-2(1), IA-2(2) Multi-factor Authentication; IA-2(8) Access to Accounts: Replay Resistant 8.5 Secure authentication
4 Sessions IA-11 Re-authentication; AC-11 Device Lock; AC-12 Session Termination 8.5
5 Passwords IA-5(1) Password-based Authentication 5.17 Authentication information
6 Recovery IA-5 Authenticator Management; IA-12 Identity Proofing 5.17
7 Exceptions IA-2 5.15 Access control
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