SA-4(10)·high·Component: System and Services AcquisitionWhat this control requires
Use only IT products listed on the FIPS 201-approved product list for implementing Personal Identity Verification (PIV) capabilities, ensuring compliance with federal multi-factor authentication standards. This control supports the Approved PIV Module capability within the System and Services Acquisition family.
In plain English
Use only IT products listed on the FIPS 201-approved product list for implementing Personal Identity Verification (PIV) capabilities, ensuring compliance with federal multi-factor authentication standards. 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 System and Services Acquisition, the assessor will trace your implementation back to the catalogue reference (Control SA-4(10)) and look for objective evidence on the latest two assessment cycles.
How to implement
- Write a short policy stating intent, scope and named owner.
- Encode it as a platform guardrail — SCP, Azure Policy initiative, Organisation Policy, or repository policy.
- Wire a monitoring signal that catches drift (CSPM rule, SIEM rule, scheduled query, Workspace alert) and ticket it.
- 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.
- Authentication. Document the trigger, the owner and the cadence.
- System. Document the trigger, the owner and the cadence.
- Identity. Document the trigger, the owner and the cadence.
- Scope: management, authentication, system, only, identity, compliance, review, services.
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: Use Of Approved Piv Products.
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 5.2 — Use Unique Passwords
- NIST SP 800-171 Rev. 3 3.5.5 — Identifier Management
- ISO/IEC 27001:2022 A.8.23 — Web filtering
- ISO/IEC 27701:2025 A.3.8 — Identity management
- SOC 2 (2017 TSC) CC1.5 — Accountability for Internal Control Responsibilities
Related controls in NIST SP 800-53 Rev. 5
- Control IA-5(3) — In-Person Or Trusted External Party Registration
- Control IA-5(15) — Gsa-Approved Products And Services
- Control IA-2(10) — Single Sign-On
- Control IA-4(3) — Multiple Forms Of Certification
- Control SA-8(9) — Trusted Components
- Control SA-19(3) — Component Disposal
References
- NIST Computer Security Resource Center — NIST SP 800-53 Rev. 5
- Catalogue identifier:
Control SA-4(10)
Topics: identity accessidentity managementaccess reviewprivileged accessmulti factor auth