NIST SP 800-53 Rev. 5 CM-11 — User-Installed Software

What this control requires

Define and enforce policies for user software installation, specifying permitted/prohibited software, using procedural or automated methods, and monitoring compliance at defined intervals. This control supports the Software Installation Controls capability within the Configuration Management family.

In plain English

Define and enforce policies for user software installation, specifying permitted/prohibited software, using procedural or automated methods, and monitoring compliance at defined intervals. In practice, this means you can prove you policy management-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.

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 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-11) and look for objective evidence on the latest two assessment cycles.

How to implement

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.
• Control. Document the trigger, the owner and the cadence.
• Compliance. Document the trigger, the owner and the cadence.
• Software. Document the trigger, the owner and the cadence.
• Scope: management, controls, configuration, software, compliance, capability, 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: User-Installed Software.

Common pitfalls

• 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 3.4.8 — Authorized Software - Allow by Exception
• HIPAA (45 CFR Part 164) 164.312(b) — Audit Controls
• ISO/IEC 27001:2022 A.8.19 — Installation of software on operational systems
• SOC 2 (2017 TSC) CC4.1 — Control Monitoring
• BSI C5:2020 SP-01 — Documentation, communication and provision of policies and instructions

Related controls in NIST SP 800-53 Rev. 5

• Control CM-11(3) — Automated Enforcement And Monitoring
• Control CM-8(6) — Assessed Configurations And Approved Deviations
• Control CM-9 — Configuration Management Plan
• Control CM-10 — Software Usage Restrictions
• Control CM-4(2) — Verification Of Controls
• Control CM-1 — Policy And Procedures

References

• NIST Computer Security Resource Center — NIST SP 800-53 Rev. 5
• Catalogue identifier: Control CM-11

Topics: governance riskcontinuous monitoringpolicy management