What evidence do auditors commonly ask for on CM-11 User-Installed Software?

SSP CM-11 statement stating who may install software, the enforcement method (application allowlisting, no local admin) and how installs are monitored; Endpoint or host report of software installed outside the approved catalogue with follow-up tickets; Emergency change records with retroactive approvals; Configuration management policy and change control procedure; Approved baseline configurations for each platform family; Change advisory board minutes with risk assessments.

What is the most common gap auditors find on CM-11?

Baselines exist on paper but production hosts drift without alerting

FedRAMP High (NIST SP 800-53 Rev 5 baseline) · CM - Configuration Management

`CM-11` User-Installed Software

Establish policies governing installation of software by users; enforce; monitor compliance.

Source: FedRAMP High (NIST SP 800-53 Rev 5 baseline), CM-11. 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

moderate

to go live

Cloud console / configuration management

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

Emergency change records with retroactive approvals · Cloud console / configuration management
Approved baseline configurations for each platform family · Cloud console / configuration management
Configuration drift detection reports from the CMDB or tooling · Cloud console / configuration management

periodic reviewEvidence produced at each review

Endpoint or host report of software installed outside the approved catalogue with follow-up tickets · Endpoint management (MDM / EDR)
Change advisory board minutes with risk assessments · Cloud console / configuration management

governing documentDocuments that govern the control

SSP CM-11 statement stating who may install software, the enforcement method (application allowlisting, no local admin) and how installs are monitored · Policy repository / GRC workspace
Configuration management policy and change control procedure · Policy repository / GRC workspace

First move

Start with the 3 of 7 artefacts that already live in a system (Cloud console / configuration management); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Baselines exist on paper but production hosts drift without alerting
Emergency changes bypass CAB and lack retrospective review
Unauthorised software present on endpoints not flagged by tooling
Hardening benchmarks applied at build but not re evaluated annually

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

CM-10 Software Usage Restrictions · CM-12 Information Location (CM-12)