16.4·high·Component: ProtectWhat this control requires
Establish and manage an updated inventory of third-party components used in development, often referred to as a "bill of materials," as well as components slated for future use. This inventory is to include any risks that each third-party component could pose. Evaluate the list at least monthly to identify any changes or updates to these components, and validate that the component is still supported.
In plain English
Establish and manage an updated inventory of third-party components used in development, often referred to as a "bill of materials," as well as components slated for future use. In practice, this means you can prove you manage software-level controls on a defined cadence.
Why it matters
The CIS Controls are an industry-vetted, prioritised defence: skipping a safeguard widens the attack surface that the safeguards above and below it assume is closed. Audit frameworks (FedRAMP, PCI DSS, HIPAA) all cite CIS as evidence of due care.
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 CIS-aligned reviewer wants to see (a) which Implementation Group you are targeting, (b) a documented owner for the safeguard, and (c) a tooling or process artefact (config, scan output, ticket) that proves the safeguard runs on the cadence the control demands.
Within Protect, the assessor will trace your implementation back to the catalogue reference (Control 16.4) and look for objective evidence on the latest two assessment cycles.
How to implement
Asset Inventory
AWS. AWS Config Aggregator across every account + region gives a real-time inventory; ship the daily snapshot to S3 and surface drift in Security Hub.
Azure. Azure Resource Graph plus Defender for Cloud's inventory blade enumerates every subscription; export to Log Analytics for retention and Workbooks for reporting.
GCP. Cloud Asset Inventory exports a daily feed of every resource and IAM binding; query via BigQuery and alert on appearance/disappearance.
Endpoints. Pipe MDM telemetry (Intune / Jamf / Workspace ONE) into your CMDB so laptops and phones are inventoried with the same rigour as cloud resources.
Secure Development
Pipeline. Require code review, SAST (Semgrep / Snyk Code), SCA (Dependabot / Renovate), secret-scanning and IaC scanning in the merge pipeline.
Branch protection. Protected branches enforce reviews, signed commits and passing CI before merge; document the protection rules as the control evidence.
Operational checklist
- Manage. Document the trigger, the owner and the cadence.
- Establish. Document the trigger, the owner and the cadence.
- Protect. Document the trigger, the owner and the cadence.
- Establish And Manage. Document the trigger, the owner and the cadence.
- Validate. Document the trigger, the owner and the cadence.
- Scope: software.
Evidence to collect
- Vendor Risk Management.
vendor_risk_managementevidence
Third-party risk management evidence (assessments, contracts, due diligence) shows supplier oversight. Focus: Establish and Manage an Inventory of Third-Party Software Components.
Common pitfalls
- Inventories that exclude SaaS, shadow IT and ephemeral cloud resources (Lambda, Cloud Run, K8s pods) miss the assets where most modern incidents start.
- CI security checks set to warn-only; the merge button is faster than the security feedback.
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.
- ISO/IEC 27001:2022 A.8.30 — Outsourced development
- SOC 2 (2017 TSC) CC9.2 — Vendor Risk Management
- GDPR Article 76 — Confidentiality
- BSI C5:2020 COS-02 — Security requirements for connections in the Cloud Service Provider's network
- ISO/IEC 27701:2025 A.3.10 — Supplier agreements
Related controls in CIS Controls v8
- Control 16.2 — Establish and Maintain a Process to Accept and Address Software Vulnerabilities
- Control 16.5 — Use Up-to-Date and Trusted Third-Party Software Components
- Control 9.1 — Ensure Use of Only Fully Supported Browsers and Email Clients
- Control 16.1 — Establish and Maintain a Secure Application Development Process
- Control 15.1 — Establish and Maintain an Inventory of Service Providers
- Control 3.13 — Deploy a Data Loss Prevention Solution
References
- Center for Internet Security — CIS Controls v8
- Catalogue identifier:
Control 16.4
Topics: vendor riskvendor managementsupply chain securityasset inventorysecure development