What evidence do auditors commonly ask for on SA-9 External System Services?

SSP SA-9 statement listing external services used, their FedRAMP authorisation status and oversight roles; External services inventory with FedRAMP authorisation status and oversight records; Vendor security questionnaires and SOC reports retained; Software bill of materials for in scope products; Acquisition policy with security clauses for contracts; Secure software development lifecycle procedures.

What is the most common gap auditors find on SA-9?

Vendor SOC reports collected but exceptions not analysed

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

`SA-9` External System Services

Require providers of external system services to comply with security/privacy requirements; document oversight roles.

Source: FedRAMP Moderate (NIST SP 800-53 Rev 5 baseline), SA-9. 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

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

Vendor security questionnaires and SOC reports retained · Vendor register / contract repository

governing documentDocuments that govern the control

SSP SA-9 statement listing external services used, their FedRAMP authorisation status and oversight roles · Policy repository / GRC workspace
External services inventory with FedRAMP authorisation status and oversight records · Policy repository / GRC workspace
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

Vendor SOC reports collected but exceptions not analysed
Code scan findings closed without verification of fix
Security requirements absent from procurement templates for low value buys

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

SA-8 Security and Privacy Engineering Principles · SA-9(1) External System Services | Risk Assessments and Organizational Approvals (SA-9(1))