What evidence do auditors commonly ask for on CA-8 Penetration Testing?

SSP CA-8 statement describing annual penetration testing scope aligned to the FedRAMP test guidance, including attack vectors and the tester; Latest penetration test report with findings carried into the POA&M; Independent assessor statement of independence; System security plan covering the authorization boundary; Control assessment report with tester names and dates; Plan of action and milestones tracking open findings.

What is the most common gap auditors find on CA-8?

Continuous monitoring metrics collected but not reported to leadership

FedRAMP High (NIST SP 800-53 Rev 5 baseline) · CA - Assessment, Authorization, and Monitoring

`CA-8` Penetration Testing

Conduct penetration testing annually on FedRAMP-defined systems and components.

Source: FedRAMP High (NIST SP 800-53 Rev 5 baseline), CA-8. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open FedRAMP High (NIST SP 800-53 Rev 5 baseline) in the compliance library.

A FedRAMP baseline is a subset of NIST SP 800-53 Rev 5, enhancements included.

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Latest penetration test report with findings carried into the POA&M · Vulnerability scanner / patch tooling
Control assessment report with tester names and dates · Document repository

governing documentDocuments that govern the control

SSP CA-8 statement describing annual penetration testing scope aligned to the FedRAMP test guidance, including attack vectors and the tester · Policy repository / GRC workspace
Independent assessor statement of independence · Document repository
System security plan covering the authorization boundary · Policy repository / GRC workspace
Plan of action and milestones tracking open findings · Policy repository / GRC workspace
Authorization to operate memorandum signed by the authorizing official · Document repository

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Continuous monitoring metrics collected but not reported to leadership
Assessment scope omits inherited cloud provider controls
Reauthorization scheduled past the policy required interval
Authorization boundary description does not match the asset inventory

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

CA-7(4) Continuous Monitoring | Risk Monitoring (CA-7(4)) · CA-8(1) Penetration Testing | Independent Penetration Testing Agent or Team (CA-8(1))