BSI C5:2020·Criterion COM-02·high·Component: Compliance Management

What this control requires

Documents audit policies per SP-01, restricting access to read-only, scheduling activities to avoid disruptions, and logging actions. Ensures controlled audits to verify security controls, protecting cloud customer data and service integrity.
— BSI C5:2020, Criterion COM-02

In plain English

Documents audit policies per SP-01, restricting access to read-only, scheduling activities to avoid disruptions, and logging actions. In practice, this means you can prove you risk cloud customer data-level controls on a defined cadence.

Why it matters

BSI C5 is the default cloud-security baseline German public-sector buyers and many DAX-listed enterprises expect; gaps here directly block procurement in the DACH region and frequently appear as must-have items in EU public-tender documents.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

What an auditor looks for

A C5 attesting auditor (under ISAE 3000 / IDW PS 860) tests both the design and — for a Type 2 — the operating effectiveness over the attestation period. For each criterion they look for both the Basic and any in-scope Additional objectives.

Within Compliance Management, the assessor will trace your implementation back to the catalogue reference (Criterion COM-02) and look for objective evidence on the latest two assessment cycles.

How to implement

Logging Monitoring

AWS. Org-trail CloudTrail to a central log archive account, GuardDuty in every region, and Security Hub for cross-source correlation.

Azure. Pipe every diagnostic setting into a central Log Analytics workspace; onboard Microsoft Sentinel for SIEM/SOAR.

GCP. Aggregate audit logs in a dedicated logging project with sink to BigQuery; enable Security Command Center Premium and route findings to Chronicle SIEM.

Cloud Posture

CSPM. Run Wiz / Prisma / Defender for Cloud / Security Command Center over every account; auto-ticket findings above your accepted-risk threshold.

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Operational checklist

  • Risk. Document the trigger, the owner and the cadence.
  • Security. Document the trigger, the owner and the cadence.
  • Data. Document the trigger, the owner and the cadence.
  • Policy. Document the trigger, the owner and the cadence.
  • Access. Document the trigger, the owner and the cadence.
  • Scope: cloud customer data, management.

Evidence to collect

  • Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policy or standard documents the safeguard. Focus: Policy for planning and conducting audits.

Common pitfalls

  • Per-account logging that nobody stitches together at the org level — incidents that cross accounts go undetected for days.
  • Treating CSPM findings as a backlog instead of a hot queue: findings older than the policy SLA accumulate until the auditor asks why.
  • Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

Related controls in BSI C5:2020

References

Topics: governance risklogging monitoringcloud posturepolicy management