What evidence do auditors commonly ask for on CM-3(7) Configuration Change Control | Review System Changes?

Configuration management policy; Procedures addressing system configuration change control; Configuration management plan; Change control records; System architecture and configuration documentation; System configuration settings and associated documentation.

What is the most common gap auditors find on CM-3(7)?

System changes are not reviewed at the defined frequency or circumstances to detect unauthorized changes

NIST SP 800-53 Rev 5 · CM - Configuration Management

`CM-3(7)` Configuration Change Control | Review System Changes

Review changes to the system organization-defined frequency or when organization-defined circumstances to determine whether unauthorized changes have occurred.

Source: NIST SP 800-53 Rev 5, CM-3(7). 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 NIST SP 800-53 Rev 5 in the compliance library.

Base controls and their enhancements. Which apply follows the baseline you are assessed against (for example FedRAMP Moderate or High, or the low, moderate and high baselines of SP 800-53B). Text in square brackets is a parameter your organisation sets.

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

Procedures addressing system configuration change control · Cloud console / configuration management
Change control records · Cloud console / configuration management

periodic reviewEvidence produced at each review

System audit records · Cloud console / configuration management
Test of Organizational processes for configuration change control; mechanisms implementing audit records for changes · Cloud console / configuration management

governing documentDocuments that govern the control

Configuration management policy · Policy repository / GRC workspace
Configuration management plan · Policy repository / GRC workspace
System architecture and configuration documentation · Policy repository / GRC workspace
System configuration settings and associated documentation · Policy repository / GRC workspace
System component inventory · Policy repository / GRC workspace
System security plan · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 2 system-held artefacts from your Cloud console / configuration management on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.

Common gaps auditors find

System changes are not reviewed at the defined frequency or circumstances to detect unauthorized changes
Reviews compare changes against nothing because approved change records are incomplete

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-3(6) Configuration Change Control | Cryptography Management · CM-3(8) Configuration Change Control | Prevent or Restrict Configuration Changes