Solutions / PIM implementation
Privileged Identity Management, the way the auditor actually wants it.
A SOX, NYDFS Part 500, HIPAA, or CJIS auditor asking about privileged access is testing three things: is Global Administrator activated only when needed, is the activation approved and logged, and can you produce a defensible audit trail. Microsoft Entra Privileged Identity Management satisfies all three when configured correctly. Identra runs the implementation from role scoping through activation approval workflow to Sentinel workbook export in a fixed scope.
- Product
- Microsoft Entra Privileged Identity Management
- License requirement
- Entra ID P2 (M365 E5 or EMS E5)
- Delivery mode
- Remote-first, US timezone
- Delivery
- Fixed scope, fixed price
01 / What we configure
Four workstreams for a defensible PIM implementation.
- 01
Role scoping
Every built-in Entra role assessed for who currently holds it and whether the assignment is justified. Global Administrator typically reduced to 2 or 3 named humans plus break-glass. Application Administrator, User Administrator, and other high-impact roles moved to PIM eligible assignments.
Role auditGA reductionRole scoping - 02
Activation workflow
PIM activation configured with MFA requirement (FIDO2 or Windows Hello preferred), justification text, and approver assignment. Approvers scoped by role: GA needs two named approvers, lower roles need one. Auto-activation permitted only for narrow scenarios with time-boxed windows.
MFAApprovalTime-boxed - 03
Break-glass isolation
Two break-glass accounts documented, isolated from CA policies, monitored via Sentinel alert on any use, and reviewed monthly by internal audit. Break-glass credentials stored in a physical safe or password vault with dual-custody access. Never used for daily operations.
Break-glassAlertDual custody - 04
Audit trail export
Sentinel workbook produces the PIM activation log, approval decision log, and role assignment change log in the format the SOX, NYDFS, HIPAA, or CJIS auditor asks for. Quarterly access review on all PIM-eligible assignments with reviewer decision captured.
Sentinel workbookAccess reviewsAuditor-ready
02 / What it looks like
Three PIM implementation engagements.
Different regulator overlays, same defensible workflow.
IT Compliance Manager at a US-listed manufacturer
Situation. External auditor deficiency last cycle: no evidence that Global Administrator access was reviewed. GA held permanently by three IT staff members. Break-glass account existed but had never been used or documented.
Outcome. PIM turned on for all privileged Entra roles. Three IT staff moved from permanent to PIM-eligible assignment. Break-glass account isolated, alerted, and documented. Sentinel workbook produces the review evidence quarterly. Deficiency cleared at the next audit cycle.
CISO at a NYDFS-covered financial services firm
Situation. NYDFS Part 500 examiner asked for evidence of MFA on all privileged access and approval workflow on tenant administration. Existing MFA was Authenticator push, no approval on privileged activation.
Outcome. FIDO2 keys deployed to all privileged users. PIM activation requires FIDO2 MFA plus approval from a second named person. Sentinel workbook exports the activation log in the NYDFS annual filing format.
Security Officer at a healthcare payer
Situation. HIPAA audit produced finding that no documented process existed for granting temporary elevated access during incident response. Team was granting GA permanently to responders and forgetting to revoke.
Outcome. Incident response role defined in Entra with PIM-eligible assignment to the responder pool. Auto-activation during declared incidents with 4-hour time-box. Sentinel alert on activation outside declared incident. HIPAA finding closed.
03 / Frequently asked
What buyers ask first.
- Do we need Entra ID P2 for PIM?
- Yes. Privileged Identity Management is a P2 feature. P2 is included with M365 E5 and EMS E5. If you have E3 or M365 Business Premium, you need a separate Entra ID P2 add-on to use PIM. The licence covers the entire tenant, not per-user, so the cost is fixed regardless of how many roles you configure.
- What is PIM for Groups?
- PIM for Groups (2023 GA) extends PIM eligibility from built-in Entra roles to any Entra role-assignable group. This lets you PIM-enable application-specific roles (SharePoint site owner, Teams admin, Exchange admin scoped to a specific domain) that are not built-in Entra roles. Most implementations use PIM for Groups for tenant administration scopes and application-specific admin roles.
- How do you handle service accounts?
- Service accounts should not use PIM. PIM is designed for humans who activate a role, complete a task, and deactivate. Service accounts running scheduled jobs need continuous access. Identra recommends migrating service accounts to workload identities (Entra Workload ID) where possible, or using dedicated service accounts with narrow role assignment and password-less authentication where workload identity is not feasible.
- Can PIM approvers be outside the IT team?
- Yes and it is often required. SOX and NYDFS auditors typically want to see that privileged activation approval is not concentrated within the same team that will benefit from the activation. Common patterns: Global Administrator activation approved by the CISO or CIO. ERP admin activation approved by someone outside the finance chain. Application admin activation approved by the application business owner.
- How long does a PIM implementation take?
- Typical implementation runs 6 to 10 weeks. Weeks 1 to 2 audit current role assignments and design the PIM-eligible role set. Weeks 3 to 6 configure PIM, approvers, and MFA requirements. Weeks 7 to 10 build the Sentinel workbook, run the first quarterly access review, and hand over runbooks. Complex tenants with many custom roles can run longer.