What evidence do auditors commonly ask for on CM-10 Software Usage Restrictions?

SSP CM-10 statement describing licence tracking for commercial software and the controls blocking peer-to-peer file sharing; Software licence register reconciled to installed counts and proxy rules blocking peer-to-peer protocols; Software inventory generated from authoritative discovery tooling; Emergency change records with retroactive approvals; Configuration management policy and change control procedure; Approved baseline configurations for each platform family.

What is the most common gap auditors find on CM-10?

Baselines exist on paper but production hosts drift without alerting

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

`CM-10` Software Usage Restrictions

Use software in accordance with contracts and copyright laws; track licenses; document peer-to-peer file sharing controls.

Source: FedRAMP Moderate (NIST SP 800-53 Rev 5 baseline), CM-10. 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 Moderate (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

easy

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

Software inventory generated from authoritative discovery tooling · Cloud console / configuration management
Emergency change records with retroactive approvals · Cloud console / configuration management
Approved baseline configurations for each platform family · Cloud console / configuration management

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

SSP CM-10 statement describing licence tracking for commercial software and the controls blocking peer-to-peer file sharing · Policy repository / GRC workspace
Software licence register reconciled to installed counts and proxy rules blocking peer-to-peer protocols · Policy repository / GRC workspace
Configuration management policy and change control procedure · Policy repository / GRC workspace

First move

Automate the pull from your Cloud console / configuration management. Configuration snapshots and change history from the cloud console or IaC repository, diffed against the baseline.

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

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-9 Configuration Management Plan · CM-11 User-Installed Software