What evidence do auditors commonly ask for on SA-4 Acquisition Process?

SSP SA-4 statement describing security and privacy requirements included in acquisition contracts; Sample contracts with security clauses and assurance requirements; Software bill of materials for in scope products; Acquisition policy with security clauses for contracts; Secure software development lifecycle procedures; Threat modelling and design review evidence for major releases.

What is the most common gap auditors find on SA-4?

Threat modelling performed inconsistently across product teams

FedRAMP Moderate (NIST SP 800-53 Rev 5 baseline) · SA - System and Services Acquisition

`SA-4` Acquisition Process

Include security/privacy requirements in contracts; FedRAMP-defined assurance requirements.

Source: FedRAMP Moderate (NIST SP 800-53 Rev 5 baseline), SA-4. 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

hard

to go live

Vendor register / contract repository

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

Threat modelling and design review evidence for major releases · Document repository
Static and dynamic code analysis reports with finding remediation · Document repository

governing documentDocuments that govern the control

SSP SA-4 statement describing security and privacy requirements included in acquisition contracts · Vendor register / contract repository
Sample contracts with security clauses and assurance requirements · Vendor register / contract repository
Software bill of materials for in scope products · Policy repository / GRC workspace
Acquisition policy with security clauses for contracts · Vendor register / contract repository
Secure software development lifecycle procedures · Policy repository / GRC workspace

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

Threat modelling performed inconsistently across product teams
Open source components used without SBOM or licence review
Vendor SOC reports collected but exceptions not analysed
Code scan findings closed without verification of fix

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.

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SA-3 System Development Life Cycle · SA-4(1) Acquisition Process | Functional Properties of Controls (SA-4(1))