SA-11(9)·high·Component: System and Services AcquisitionWhat this control requires
Require developers to use interactive application security testing (IAST) tools to detect vulnerabilities during runtime. Leverage instrumentation to measure control effectiveness across code, configurations, and user interactions, and document results. This control supports the Instrumentation-Based Security Testing Protocol capability within the System and Services Acquisition family.
In plain English
Require developers to use interactive application security testing (IAST) tools to detect vulnerabilities during runtime. In practice, this means you can prove you security 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 System and Services Acquisition, the assessor will trace your implementation back to the catalogue reference (Control SA-11(9)) and look for objective evidence on the latest two assessment cycles.
How to implement
Code Review Testing
Pipeline. Require at least one human reviewer plus passing CI (lint, type, unit, security scan) before merge — protected branches enforce this.
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.
Vulnerability Management
Scanners. Pair an unauthenticated scanner (Nessus / Qualys / Tenable.io) for external surface with an authenticated agent for OS/library CVEs on every host.
SLA. Document remediation SLAs by CVSS / EPSS: critical 7 days, high 30 days, medium 90 days; report monthly trend to leadership.
Containers. Scan images in CI (Trivy / Grype / Snyk Container) AND at runtime; block deploys on critical findings without exception.
Operational checklist
- Security. Document the trigger, the owner and the cadence.
- Review. 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.
- Testing,. Document the trigger, the owner and the cadence.
- Scope: management, system, application, review, services, capability, tools, vulnerability.
Evidence to collect
- Code Repo Scan. Source-control evidence — branch protection, required reviewers, CI status, SCA / SAST reports.
Source control pipelines (GitHub, GitLab) enforce SDLC guardrails. Focus: Interactive Application Security Testing.
Common pitfalls
- CI security checks set to warn-only; the merge button is faster than the security feedback.
- Scans that hit only the perimeter; missing authenticated scans of OS, runtime libs and base images so most CVEs are invisible.
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 3.7.4 — Maintenance Tools
- ISO/IEC 27001:2022 A.8.28 — Secure coding
- CIS Controls v8 16.12 — Implement Code-Level Security Checks
- BSI C5:2020 DEV-08 — Version Control
- SOC 2 (2017 TSC) P5.2 — Correction and Amendment of Personal Information
Related controls in NIST SP 800-53 Rev. 5
- Control SA-11(1) — Static Code Analysis
- Control SA-5(5) — Source Code
- Control SA-18(1) — Multiple Phases Of System Development Life Cycle
- Control SA-15(7) — Automated Vulnerability Analysis
- Control SA-11(8) — Dynamic Code Analysis
- Control SA-10(5) — Mapping Integrity For Version Control
References
- NIST Computer Security Resource Center — NIST SP 800-53 Rev. 5
- Catalogue identifier:
Control SA-11(9)
Topics: application securitysecure developmentcode review testingdevsecopsvulnerability management