NIST SP 800-53 Rev. 5 CM-1 — Policy And Procedures

What this control requires

Develops, documents, and disseminates configuration management policies and procedures, designating an official to manage and update them periodically. This control supports the Policy Management System capability within the Configuration Management family.

In plain English

Develops, documents, and disseminates configuration management policies and procedures, designating an official to manage and update them periodically. In practice, this means you can prove you policy procedures-level controls on a defined cadence.

Why it matters

SP 800-53 is the catalogue every U.S. federal authorisation (FedRAMP, FISMA, CMMC) and most regulated industries point at. A missing control surfaces as a Plan of Action & Milestones (POA&M) item that an Authorizing Official must approve before the Authority To Operate is granted or renewed.

What an auditor looks for

A 3PAO (FedRAMP) or Independent Assessor (NIST RMF) tests against NIST SP 800-53A assessment procedures. For each control they expect a documented implementation that addresses every assessment objective (Examine, Interview, Test) and an implementation summary in the System Security Plan.

Within Configuration Management, the assessor will trace your implementation back to the catalogue reference (Control CM-1) and look for objective evidence on the latest two assessment cycles.

How to implement

Configuration Management

Policy-as-code. Codify the control as Service Control Policies (AWS), Azure Policy initiatives, or Organisation Policy (GCP) so the platform enforces what the document promises.

IaC. Gate Terraform / Pulumi / CloudFormation changes with Checkov / tfsec / OPA so misconfigurations never reach production.

Drift. Run a CSPM (Wiz / Prisma / Defender for Cloud / Security Command Center) over every account and route findings to a single risk register.

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

• Policy. Document the trigger, the owner and the cadence.
• Configuration. Document the trigger, the owner and the cadence.
• System. Document the trigger, the owner and the cadence.
• Control. Document the trigger, the owner and the cadence.
• Risk. Document the trigger, the owner and the cadence.
• Scope: procedures, management, system, configuration, capability, documents, policy, configuration management.

Evidence to collect

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

Signed policy or standard documents the safeguard. Focus: Policy And Procedures.

Common pitfalls

• Manual cloud-console changes that never make it back to Terraform — drift accumulates until the next outage forces a reconciliation.
• 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.

• NIST SP 800-171 Rev. 3 3.4.1 — Baseline Configuration
• HIPAA (45 CFR Part 164) 164.308(a)(5)(ii)(B) — Security Awareness, Training, and Tools - Protection from Malicious Software
• BSI C5:2020 AM-02 — Acceptable Use and Safe Handling of Assets Policy
• SOC 2 (2017 TSC) A1.3 — Testing of System Recovery Procedures

Related controls in NIST SP 800-53 Rev. 5

• Control CM-3 — Configuration Change Control
• Control CM-9 — Configuration Management Plan
• Control CM-9(1) — Assignment Of Responsibility
• Control CA-1 — Policy And Procedures
• Control CM-3(3) — Automated Change Implementation
• Control SC-1 — Policy And Procedures

References

• NIST Computer Security Resource Center — NIST SP 800-53 Rev. 5
• Catalogue identifier: Control CM-1

Topics: governance riskconfiguration managementpatch managementpolicy management