PM-5·high·Component: Program ManagementWhat this control requires
Develop and update an inventory of organizational systems at a defined frequency, in accordance with OMB A-130 guidelines, ensuring comprehensive documentation and reporting of systems across the organization. This control supports the System Inventory Management capability within the Program Management family.
In plain English
Develop and update an inventory of organizational systems at a defined frequency, in accordance with OMB A-130 guidelines, ensuring comprehensive documentation and reporting of systems across the organization. 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 Program Management, the assessor will trace your implementation back to the catalogue reference (Control PM-5) 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.
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.
Operational checklist
- Policy. 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.
- Documentation. Document the trigger, the owner and the cadence.
- Inventory. Document the trigger, the owner and the cadence.
- Scope: management, organization, system, capability, systems, policy, inventory, documentation.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
Signed policy or standard documents the safeguard. Focus: System Inventory.
Common pitfalls
- Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.
- Inventories that exclude SaaS, shadow IT and ephemeral cloud resources (Lambda, Cloud Run, K8s pods) miss the assets where most modern incidents start.
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.
- CIS Controls v8 3.2 — Establish and Maintain a Data Inventory
- HIPAA (45 CFR Part 164) 164.308(a)(5)(i) — Security Awareness and Training
- BSI C5:2020 AM-01 — Asset Inventory
Related controls in NIST SP 800-53 Rev. 5
- Control SA-4(4) — Assignment Of Components To Systems
- Control CA-6(2) — Joint Authorization -- Inter-Organization
- Control CM-8 — System Component Inventory
- Control CM-8(6) — Assessed Configurations And Approved Deviations
- Control MA-6(3) — Automated Support For Predictive Maintenance
- Control PE-21 — Electromagnetic Pulse Protection
References
- NIST Computer Security Resource Center — NIST SP 800-53 Rev. 5
- Catalogue identifier:
Control PM-5
Topics: governance riskpolicy managementasset inventorypatch management