BSI C5:2020·Criterion DEV-03·high·Component: Development & Change Management

What this control requires

Documents change management policies per SP-01, specifying risk assessment, testing, approvals, and customer notification. Enforces segregation of duties and documentation to ensure secure updates, protecting cloud customer data from errors.
— BSI C5:2020, Criterion DEV-03

In plain English

Documents change management policies per SP-01, specifying risk assessment, testing, approvals, and customer notification. In practice, this means you can prove you information 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 Development & Change Management, the assessor will trace your implementation back to the catalogue reference (Criterion DEV-03) and look for objective evidence on the latest two assessment cycles.

How to implement

Incident Response

Runbook. Maintain a runbook keyed by incident type with named roles (IC, comms, scribe), an out-of-band comms channel, and a 72-hour timeline for external notification.

Tabletop. Run a quarterly tabletop exercise (ransomware, insider, supply-chain) and feed gaps back into the runbook.

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.

Cloud Posture

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

Operational checklist

  • Information. Document the trigger, the owner and the cadence.
  • Segregation. Document the trigger, the owner and the cadence.
  • Risk. Document the trigger, the owner and the cadence.
  • Documentation,. Document the trigger, the owner and the cadence.
  • Data. Document the trigger, the owner and the cadence.
  • Scope: cloud customer data, development, changes, management.

Evidence to collect

  • Ticketing Workflow. ticketing_workflow evidence
  • Policy Document. A signed and version-controlled policy / standard / procedure document.
  • Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.

Workflow metrics (ServiceNow, Jira) show approvals and remediation. Signed policy or standard documents the safeguard. Focus: Policies for changes to information systems.

Common pitfalls

  • Runbooks that name a role but no person, or list a paging channel that no longer exists.
  • Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.
  • Treating CSPM findings as a backlog instead of a hot queue: findings older than the policy SLA accumulate until the auditor asks why.

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 riskchange managementincident responsepolicy managementcloud posture