What evidence do auditors commonly ask for on CM-5 Access Restrictions for Change?

SSP CM-5 statement listing who may change production, how access is enforced (pipeline only, break-glass) and how changes are logged; Repository and deployment pipeline permission exports showing production change rights limited to approved staff; Change advisory board minutes with risk assessments; Configuration drift detection reports from the CMDB or tooling; Software inventory generated from authoritative discovery tooling; Emergency change records with retroactive approvals.

What is the most common gap auditors find on CM-5?

Baselines exist on paper but production hosts drift without alerting

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

`CM-5` Access Restrictions for Change

Define, document, approve, enforce physical and logical access restrictions for changes.

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

Repository and deployment pipeline permission exports showing production change rights limited to approved staff · Identity provider / directory
Configuration drift detection reports from the CMDB or tooling · Cloud console / configuration management
Software inventory generated from authoritative discovery tooling · Cloud console / configuration management
Emergency change records with retroactive approvals · Cloud console / configuration management

periodic reviewEvidence produced at each review

Change advisory board minutes with risk assessments · Cloud console / configuration management

governing documentDocuments that govern the control

SSP CM-5 statement listing who may change production, how access is enforced (pipeline only, break-glass) and how changes are logged · 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-4(2) Impact Analyses | Verification of Controls (CM-4(2)) · CM-5(1) Access Restrictions for Change | Automated Access Enforcement and Audit Records (CM-5(1))