NIST SP 800-53 Rev. 5 MA-2(1) — Record Content

What this control requires

Include in Maintenance records details such as date, time, activity descriptions, personnel involved, and components removed or replaced to ensure transparency and accountability. This control supports the Maintenance Records capability within the Maintenance family.

In plain English

Include in Maintenance records details such as date, time, activity descriptions, personnel involved, and components removed or replaced to ensure transparency and accountability. In practice, this means you can prove you access 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 Maintenance, the assessor will trace your implementation back to the catalogue reference (Control MA-2(1)) and look for objective evidence on the latest two assessment cycles.

How to implement

1. Write a short policy stating intent, scope and named owner.
2. Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
3. Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
4. Review on a documented cadence and capture the review in the risk register or compliance tracker.

Operational checklist

• Access. Document the trigger, the owner and the cadence.
• Review. Document the trigger, the owner and the cadence.
• Maintenance. Document the trigger, the owner and the cadence.
• Content. Document the trigger, the owner and the cadence.
• Time. Document the trigger, the owner and the cadence.
• Scope: management, personnel, records, time, identity, review, maintenance, components.

Evidence to collect

• Identity Scan. IAM / IdP exports — Entra ID, Okta, IAM Identity Center, Workspace directory — showing accounts, roles, MFA state and last sign-in.

Identity analytics (Okta, SailPoint, Access Analyzer) demonstrates least-privilege. Focus: Record Content.

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 3.7.5 — Nonlocal Maintenance
• ISO/IEC 27001:2022 A.5.33 — Protection of records
• CIS Controls v8 9.2 — Use DNS Filtering Services
• ISO/IEC 27701:2025 A.3.8 — Identity management

Related controls in NIST SP 800-53 Rev. 5

• Control MA-4(2) — Document Nonlocal Maintenance
• Control MA-4 — Nonlocal Maintenance
• Control MA-3(3) — Prevent Unauthorized Removal
• Control MA-5(3) — Citizenship Requirements For Classified Systems
• Control MA-5(5) — Non-System Maintenance
• Control AU-6(6) — Correlation With Physical Monitoring

References

• NIST Computer Security Resource Center — NIST SP 800-53 Rev. 5
• Catalogue identifier: Control MA-2(1)

Topics: identity accessidentity managementaccess reviewprivileged access