Safeguard 16.1: Establish and Maintain a Secure Application Development Process

To meet the safeguard 16.1: establish and maintain a secure application development process requirement, you need a documented SDLC that bakes security into planning, coding, testing, deployment, and change control, plus repeatable evidence that teams follow it. Operationalize this by defining required secure dev activities, gating releases, and retaining artifacts for audits. ¹

Key takeaways:

• Define a secure SDLC standard with mandatory security steps, roles, and “ship/no-ship” gates. ¹
• Make the process provable: tickets, approvals, scan results, and release records must be retained and reviewable. ¹
• Treat missing evidence as a control failure even if engineers “do the right thing.” ¹

Safeguard 16.1 expects you to run application development as a controlled process, not a collection of individual team habits. For a CCO or GRC lead, the shortest path to “audit-ready” is to (1) document what secure development means in your organization, (2) make it the default workflow in your engineering tooling, and (3) retain evidence that the workflow ran for real releases. ¹

This requirement matters because application changes are one of the most common ways risk enters production: new code, new dependencies, new cloud services, and configuration drift. A secure development process reduces the chance that security review becomes optional under delivery pressure. It also gives you a consistent story for internal audit, customers, and assessors: security requirements were defined up front, implemented through standard steps, and verified before release. ¹

This page gives requirement-level implementation guidance you can put into a policy pack, engineering standards, and a control testing plan. It prioritizes what examiners ask for: clear process design, clear ownership, and evidence that it operates consistently. ¹

Regulatory text

Framework requirement (excerpt): “CIS Controls v8 safeguard 16.1 implementation expectation (Establish and Maintain a Secure Application Development Process).” ¹

Operator interpretation: You must define, document, and run a secure application development lifecycle (SDLC) process. “Establish and maintain” means the process exists in writing, is approved, is used across in-scope development work, and is kept current as your stack and threats change. ¹

Plain-English interpretation (what an assessor expects)

A secure development process is a set of required steps that engineers follow every time they build or change software. Your process should answer, in plain terms:

• What security requirements apply to new features and changes?
• Who approves risk decisions (and under what conditions)?
• What security checks are required before code merges and releases?
• How you handle vulnerabilities discovered during development and after release. ¹

An assessor typically does not grade you on having a “perfect” SDLC. They grade you on whether you defined a standard, implemented it consistently, and can prove it with artifacts. ¹

Who it applies to (entity and operational context)

Entity scope: Enterprises and technology organizations adopting CIS Controls v8. ¹

Operational scope (what to include):

• Custom software: internal apps, customer-facing apps, APIs, services, scripts, infrastructure-as-code.
• Configuration-as-code and CI/CD workflows that modify production behavior.
• Teams building software directly and teams outsourcing development to third parties (you still need governance and evidence). ¹

Common scoping decision that holds up audits: Define “in-scope application” using a simple rule such as “anything that processes sensitive data, touches production networks, or is customer-facing.” Document exceptions and approvals. ¹

What you actually need to do (step-by-step)

1) Write your secure SDLC standard (one page is fine)

Create a short standard that defines minimum required activities and “release gates.” Include:

• Phases: plan, build, test, release, operate.
• Required security activities per phase: threat review for high-risk changes, peer code review, dependency checks, security testing, and vulnerability triage.
• Roles: engineering owner, security reviewer, product owner, change approver.
• Ship/no-ship criteria: what blocks a production release vs. what can be accepted with documented risk. ¹

Tip: Keep policy stable; put tooling specifics in an engineering procedure that can change more often without governance friction. ¹

2) Embed security tasks into engineering workflows

Policy without workflow integration becomes “optional.” Make the SDLC executable:

• Intake: require a ticket (user story/feature request) with data classification and security impact questions.
• Design: require a lightweight security design review trigger for certain conditions (auth changes, payment flow changes, public endpoints, sensitive data).
• Build: require peer review in your repo settings; define minimum reviewer rules for critical repositories.
• Test: require automated checks in CI for code and dependencies; define what constitutes a pass/fail and who can override.
• Release: require a release record that ties commit hashes/build artifacts to approvals and test results.
• Operate: require a post-release vulnerability handling path (who is paged, how fixes are prioritized, how exceptions are approved). ¹

3) Define vulnerability handling within development

Safeguard 16.1 is not only “secure coding.” Your SDLC must include what happens when you find issues:

• Intake and triage rules (who reviews, what information is required).
• Fix workflow (branching, patching, retesting).
• Risk acceptance workflow (who can approve, required justification, expiration/reevaluation). ¹

4) Set governance: ownership, exceptions, and periodic review

To “maintain” the process:

• Assign a named owner for the SDLC standard.
• Establish an exceptions process with time bounds and compensating controls.
• Review the SDLC content on a set cadence and after major platform changes (new CI/CD, new language, major cloud migration). ¹

5) Make evidence capture automatic

The fastest way to pass assessments is to make evidence a byproduct of normal work:

• Ticketing system becomes the system of record for approvals, exceptions, and risk acceptance.
• CI/CD stores build logs and security scan outputs.
• Repos store code review history and protected branch settings.
• Release tooling stores who approved and what shipped. ¹

If you use Daydream, treat it as the control hub: map safeguard 16.1 to your SDLC policy, link each “gate” to its evidence source, and schedule recurring evidence pulls (for example, per release or per sprint) so you are not reconstructing history during an audit. ¹

Required evidence and artifacts to retain (audit-ready checklist)

Retain artifacts that prove both design (the process exists) and operation (the process ran).

Control design artifacts

• Secure SDLC policy/standard and engineering procedures (approved, versioned).
• RACI or role definitions for security reviews and release approvals.
• Exception/risk acceptance procedure and approval matrix. ¹

Operating evidence (samples taken from real releases)

• Work items showing security requirements considered (e.g., data handling fields, threat triggers).
• Code review records (PR approvals, protected branch rules screenshots/exports).
• CI/CD run logs showing required security checks ran and passed (or documented overrides with approval).
• Dependency and vulnerability scan outputs linked to remediation tickets.
• Release approvals and deployment records tying changes to environments.
• Post-release vulnerability tickets with triage and fix evidence. ¹

Evidence quality rules (what auditors flag)

• Evidence must be traceable from requirement → code change → test results → approval → deployment.
• Evidence must show consistency across teams and repositories, not a single “golden repo.”
• Exceptions must be explicit; silent bypass is treated as noncompliance. ¹

Common exam/audit questions and hangups

Expect questions like:

• “Show me your secure SDLC document and who approved it.” ¹
• “Pick two recent production releases. Show the required security checks and approvals for each.” ¹
• “How do you decide when a security review is required during design?” ¹
• “Who can approve risk acceptance, and where is it documented?” ¹
• “How do you handle third-party code and dependencies in the SDLC?” ¹

Where teams get stuck:

• Inconsistent processes across squads.
• Inability to produce evidence quickly because it lives in chat tools or individual laptops.
• “We scan sometimes” with no defined gates or override approvals. ¹

Frequent implementation mistakes (and how to avoid them)

1. Writing a long SDLC policy no one follows.
   Fix: keep the policy short; enforce the steps through repo protections and CI gates. ¹

2. Treating secure development as only an AppSec team responsibility.
   Fix: assign engineering owners for execution; AppSec provides standards, review, and escalation paths. ¹

3. No exception path, so teams bypass controls quietly.
   Fix: publish a fast exception workflow with required approvers and expiry; test it in tabletop scenarios. ¹

4. Evidence is manual and assembled during audits.
   Fix: define evidence sources up front and automate collection into your GRC system; Daydream can track control mapping and recurring evidence capture so you can answer audits with a current package. ¹

5. Ignoring outsourced development.
   Fix: require third parties to follow your secure SDLC or an equivalent, and require delivery of evidence (review logs, test results, vulnerability remediation records) as part of acceptance. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this safeguard. ¹

Risk still accumulates quickly when secure development steps are informal:

• Vulnerabilities ship to production because checks are optional.
• Root cause analysis is harder because releases are not traceable to approvals and test outcomes.
• Customer due diligence fails because you cannot demonstrate consistent controls, even if engineering practice is strong. ¹

A practical 30/60/90-day execution plan

First 30 days (stabilize scope and minimum viable SDLC)

• Inventory in-scope applications and repos; pick an initial boundary you can defend.
• Publish a one-page secure SDLC standard with required gates and owners.
• Implement protected branches and required peer review on the most critical repos.
• Define evidence sources (tickets, CI logs, release tool) and start collecting samples in Daydream or your existing GRC repository. ¹

Days 31–60 (make it consistent and testable)

• Add CI gating rules for required checks; document override approvals.
• Stand up a standard security design review trigger checklist and route.
• Implement the exception/risk acceptance workflow with named approvers and expirations.
• Run an internal “mock audit”: select recent releases and produce the full trace from ticket to deploy. Fix gaps. ¹

Days 61–90 (expand coverage and harden operations)

• Extend SDLC gates to remaining in-scope repos and teams; track exceptions explicitly.
• Add post-release vulnerability handling expectations and escalation paths.
• Create an ongoing control test: periodic sampling of releases to confirm gates, approvals, and evidence quality.
• Operationalize recurring evidence capture in Daydream so you always have current proof of operation, not a point-in-time scramble. ¹

Frequently Asked Questions

Does safeguard 16.1 require a specific secure SDLC model (Agile, Scrum, Waterfall)?

No specific model is required; you need a defined process that fits your delivery method and produces consistent security outcomes and evidence. Tie security gates to how work actually flows. ¹

What’s the minimum evidence I should be able to produce on demand?

For a sampled release, produce the work item, code review record, CI/security check results, and release approval/deployment record. If any step can be bypassed, show the documented exception approval. ¹

How do we handle emergency changes without failing the control?

Define an emergency change path that still records approvals and requires retrospective review with remediation tasks. Auditors usually accept speed when governance and evidence remain intact. ¹

Are third-party developers and outsourced teams in scope?

Yes if they develop or modify software you run or ship. Contractually require an equivalent secure development process and require deliverable evidence as part of acceptance. ¹

What if teams claim they do secure coding but we can’t prove it?

Treat it as a control gap. Safeguard 16.1 expects a maintainable process with artifacts that demonstrate operation, not verbal attestations. ¹

How should a GRC team work with Engineering without slowing releases?

Focus on defining clear gates, owners, and evidence, then automate collection through existing tools. Use Daydream to map 16.1 to those artifacts and keep a current evidence package without interrupting engineers. ¹

Footnotes

1. CIS Controls v8; CIS Controls Navigator v8