Government agencies should use an alternate authenticator that can be issued quickly, supports strong authentication, and does not depend on in-person enrollment. The practical goal is to preserve mission access while reducing phishing exposure. A good approach is to pair remote-friendly authenticators with multi-factor authentication and existing government approval pathways, so deployment can scale without weakening assurance.
What agencies are actually trying to preserve when PIV or CAC is not feasible
The core problem is not simply “replace the card.” Agencies need a remote authenticator that preserves strong assurance, supports mission access, and can be issued without the delays and logistics of in-person enrollment. The right answer usually combines remote-friendly enrollment, phishing-resistant authentication where possible, and a lifecycle process that still lets security teams revoke or rotate access quickly when risk changes.
That means the decision should be driven by assurance and operability together, not by convenience alone. A remote worker credential that is easy to deploy but hard to govern will usually create a bigger problem later, especially if it is reused across systems or granted broader access than the original PIV or CAC workflow would have allowed.
When agencies need a governance reference point for this problem, NIST Cybersecurity Framework 2.0 is useful because it frames the issue as a governance and protection problem, not just an authentication swap.
How to choose an alternate authenticator without weakening assurance
The practical test is whether the alternate authenticator can be issued quickly, bound to the right user, and used in a way that reduces phishing exposure rather than merely shifting it. Agencies should prefer authenticators that support strong cryptographic authentication or equivalent controls, and they should avoid choices that depend on weak shared secrets, ad hoc manual approval, or long-lived credentials that are hard to revoke.
Remote enrollment is where many programs succeed or fail. If the authenticator can be issued remotely but the identity proofing, approval, or recovery steps are sloppy, the new process can become easier to abuse than the original on-site card issuance path. That is why the approval workflow matters as much as the authenticator itself.
For agencies that want a formal identity baseline, NIST SP 800-63 Digital Identity Guidelines is the most direct external anchor for identity proofing, authentication assurance, and authenticator lifecycle decisions. If the implementation relies on certificates or strong token material, the issuance and revocation model should also align with certificate governance in CA/Browser Forum-style baseline expectations for certificate handling and revocation discipline.
Risk and Threat Considerations
Remote-friendly access increases the chance that agencies will rely on credentials that are easier to phish, replay, misissue, or fail to revoke quickly. The main security risk is not remote work itself, but a weaker assurance path that keeps mission access available while quietly broadening the attack surface for credential theft and unauthorized access.
Failure mechanism: If the alternate authenticator is not strongly bound to the right user and lifecycle-managed with timely revocation, an attacker can exploit phishing, enrollment weaknesses, or credential reuse to impersonate the user and pivot into agency systems.
Impact: The result can be unauthorized access to sensitive government systems, data exposure, and a larger blast radius than the original in-person-issued credential model would have allowed.
Standards & Framework Alignment
This section maps relevant standards and security frameworks to the operational risks and controls described in this guidance.
NIST CSF 2.0, NIST SP 800-63, NIST Zero Trust (SP 800-207) and CIS Controls v8 set the governance and control requirements practitioners need to meet.
| Framework | Control / Reference | Relevance |
|---|---|---|
| NIST CSF 2.0 | GV.OC — Organizational Context | Remote authenticator choice must fit mission and operational constraints. |
| PR.AA — Identity Management, Authentication, and Access Control | Alternate authenticators are an authentication and access-control decision. | |
| PR.DS — Data Security | Remote access should protect sensitive government data from exposure. | |
| Recommendation — Define remote-access requirements around mission continuity and assurance. Require strong authentication and least-privilege access for remote workers. Protect sensitive data traversing remote-access channels. | ||
| NIST SP 800-63 | IAL — Identity Assurance Level | Remote issuance depends on the strength of identity proofing. |
| AAL — Authenticator Assurance Level | Alternate authenticators must maintain strong authentication assurance. | |
| FAL — Federation Assurance Level | Government remote access often relies on federated approval pathways. | |
| Recommendation — Match remote enrollment to an appropriate identity-proofing level. Select an authenticator assurance level that resists phishing. Use federation controls that preserve assurance across remote access. | ||
| NIST Zero Trust (SP 800-207) | 3e — Dynamic and Least Privilege Resource Access | Remote workers should receive only the access needed for the session. |
| 2a — Strong Identity Governance | Remote issuance requires strong identity governance and lifecycle control. | |
| Recommendation — Apply least-privilege, session-based access for remote workers. Govern issuance, revocation, and recovery for alternate authenticators. | ||
| CIS Controls v8 | 6.3 — Access Control Management | Alternate authenticator deployment needs structured access approval and review. |
| 6.8 — Account Management | Remote worker credentials need lifecycle management and timely removal. | |
| Recommendation — Centralize approval, review, and revocation of remote access paths. Track and remove remote worker access promptly when no longer needed. | ||
Practitioner Guidance
What to verify: Before approving an alternate authenticator, confirm that the agency can issue it remotely, revoke it quickly, and tie it to a documented approval path that security staff can audit. If the process cannot show who approved issuance, how the authenticator was bound to the user, and how recovery works after loss or compromise, the control is too weak for serious remote use.
What good looks like: Remote workers authenticate with a method that is resistant to phishing, the agency can scale issuance without manual bottlenecks, and access remains least-privilege by default. The strongest programs treat the alternate authenticator as a governed identity lifecycle item, not a temporary workaround.
Practitioner takeaway: The best substitute for a PIV or CAC is not the fastest credential to issue, but the one that preserves assurance, is operationally supportable, and can be governed with the same discipline as any other high-value government authenticator.
Related resources from NHI Mgmt Group
- Why does relying only on PIV and CAC create friction for remote government onboarding?
- Why does strong authentication matter more when organisations rely on remote workers and third-party access?
- How can organizations secure their MCP server credentials?
- How should organisations secure email access for remote workers?
Deepen Your Knowledge
Reviewed and updated by the NHIMG editorial team on September 20, 2026.
NHI Mgmt Group — the #1 independent authority on Non-Human Identity, IAM, and Agentic AI security. nhimg.org
