CVE-2022-39801 is a high-severity vulnerability (CVSS 7.5) affecting SAP SE's SAP GRC Access Control Emergency Access Management product, specifically versions V1100_700, V1100_731, and V1200_750. The vulnerability is classified under CWE-287, which relates to improper authentication. The issue allows an authenticated attacker, operating within the internal network firewall, to access a Firefighter session even after it has been closed in the Firefighter Logon Pad. Firefighter sessions are privileged emergency access sessions designed to provide temporary administrative access for critical tasks. Exploiting this vulnerability enables the attacker to gain unauthorized access to an administrative session, thereby fully compromising the application. The attack requires the attacker to have some level of authenticated access and be within the network perimeter, as it cannot be exploited remotely over the internet. The vulnerability impacts confidentiality, integrity, and availability, as it allows unauthorized administrative control over the SAP GRC Access Control system, potentially leading to unauthorized changes, data leakage, or disruption of critical governance, risk, and compliance processes. No known exploits are currently reported in the wild, and no official patches are linked in the provided data, indicating that organizations must monitor SAP advisories closely for updates.

For European organizations, this vulnerability poses a significant risk due to the widespread use of SAP GRC Access Control in managing compliance, risk, and governance processes, which are critical in regulated industries such as finance, manufacturing, energy, and public sector entities. Unauthorized administrative access could lead to manipulation or bypassing of compliance controls, fraudulent activities, unauthorized data access, and disruption of audit trails. Given the strict regulatory environment in Europe, including GDPR and sector-specific regulations, exploitation could result in severe legal and financial consequences. The requirement for internal network access limits the attack vector to insider threats or attackers who have breached perimeter defenses, but once inside, the attacker could move laterally and escalate privileges. The compromise of emergency access management undermines trust in the organization's control environment, potentially impacting business continuity and reputation.

Organizations should implement network segmentation and strict access controls to limit internal access to SAP GRC systems, ensuring only authorized personnel can reach the Emergency Access Management components. Monitoring and logging of Firefighter session activities should be enhanced to detect anomalous session behavior, including attempts to access closed sessions. Multi-factor authentication (MFA) should be enforced for all users with access to SAP GRC Emergency Access Management to reduce the risk of credential misuse. Regular audits of Firefighter session logs and user privileges can help identify potential misuse. Until SAP releases an official patch, organizations may consider temporary compensating controls such as restricting Emergency Access Management usage to a minimal set of users and times, and employing network-level controls like firewall rules or intrusion detection systems to detect suspicious internal activity. Prompt application of SAP security notes and patches once available is critical. Additionally, organizations should conduct internal penetration testing and vulnerability assessments focusing on SAP GRC components to identify and remediate related weaknesses.