Safeguard 18.3: Remediate Penetration Test Findings

Safeguard 18.3 requires you to take penetration test findings and drive them through a controlled remediation process: assign ownership, prioritize by risk, fix (or formally accept) each issue, and keep proof that closure happened. To operationalize quickly, treat pen test findings like high-fidelity security defects with SLAs, exception governance, and retest/validation. ¹

Key takeaways:

• Build a single remediation workflow for all pen test findings (internal, external, third party) with owners, due dates, and closure criteria. ²
• Require verification of fixes (retest, evidence, or compensating controls) before a finding can be closed. ³
• Keep audit-ready artifacts: the report, triage records, remediation tickets, approvals, and validation evidence mapped to the safeguard. ²

The safeguard 18.3: remediate penetration test findings requirement is where many security programs fail the “so what?” test. Running a penetration test is not the control. Closing the loop is the control. If findings sit in a PDF, live in email, or get “fixed” without proof, you will struggle to show effective risk reduction and consistent governance.

Operationally, Safeguard 18.3 is a repeatable remediation discipline: intake the pen test report, convert findings into trackable work items, assign accountable owners, prioritize based on business and technical risk, and validate remediation before closure. The work spans Security, Engineering, Infrastructure, and often third parties (for SaaS, managed services, or externally hosted apps). It also overlaps change management, vulnerability management, and exception management.

This page gives requirement-level guidance you can implement fast: a step-by-step workflow, evidence to retain, audit questions to expect, and common failure modes. Where teams get stuck is not in “how to fix vulnerabilities,” but in governance: ownership, deadlines, exception approvals, and proof of retest. ¹

Regulatory text

Provided excerpt: “CIS Controls v8 safeguard 18.3 implementation expectation (Remediate Penetration Test Findings).” ¹

What the operator must do:
You must maintain a defined, repeatable process to remediate penetration test findings to closure. “To closure” means you can show one of the following for each finding:

• The issue was fixed, and you have evidence of the fix plus validation (retest or equivalent confirmation).
• The issue was not fixed, but was formally risk-accepted with documented rationale, duration/expiry, and compensating controls.
• The issue was transferred to a responsible third party with tracking, escalation, and documented acceptance of responsibility.

Your deliverable is not a policy statement. It is demonstrable execution: findings are translated into tracked remediation work with owners, timetables, and closure evidence that you can produce on demand. ¹

Plain-English interpretation of the requirement

Pen tests produce high-signal findings that represent real-world exploit paths. Safeguard 18.3 expects you to treat those findings as prioritized security debt:

• Convert findings into actionable tasks.
• Fix the root causes (not just the symptom in the report).
• Prove the fix worked.
• Govern exceptions explicitly.

If you cannot show how each finding moved from discovery to resolution (or approved exception), your penetration testing program will look performative in an assessment. ²

Who it applies to

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

Operational context (where this bites in practice):

• Application security: web apps, APIs, mobile apps, CI/CD misconfigurations, auth flaws.
• Infrastructure/security engineering: network segmentation gaps, identity weaknesses, cloud misconfigurations, exposed services.
• Third parties: findings in hosted environments, managed platforms, or shared responsibility models where a third party owns the fix.
• M&A / inherited systems: pen tests uncover legacy issues that need triage and rational exceptions.

Teams you need involved:

• Security (pen test sponsor, triage, validation)
• Engineering / IT (remediation owners)
• Product (risk tradeoffs, release scheduling)
• GRC / Compliance (evidence, exception governance)
• Procurement / Vendor management (third-party remediation commitments)

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

1) Define “finding lifecycle” and closure criteria

Create a short standard that answers:

• What qualifies as a “penetration test finding” (include internal, external, and third-party-led tests).
• Where findings must be tracked (ticketing system, GRC platform, or vulnerability tracker).
• What fields are mandatory (owner, system, severity, due date, remediation plan, validation method, closure approval).
• What counts as “closed” (retest evidence, code review evidence, config screenshot, scan output, or test note).

Operator tip: closure without validation is the fastest way to fail an audit walk-through. Require proof. ²

2) Intake and normalize the pen test report

For each engagement:

• Store the final report in a controlled repository.
• Extract each finding into a tracking record.
• Map each finding to the in-scope asset/service owner and to a system of record (CMDB, service catalog, cloud account, app inventory).

If the pen test provider uses their own portal, you still need an internal record to show governance and due diligence. ³

3) Triage: prioritize and decide the remediation path

Run a structured triage meeting with Security + the owning team:

• Confirm reproducibility and affected scope (environments, accounts, endpoints, versions).
• Identify root cause categories (identity, access control, patching, input validation, misconfiguration).
• Choose disposition:
  • Remediate
  • Mitigate with compensating control
  • Risk accept (time-bound, with explicit approval)
  • Transfer to third party (with contractual and tracking follow-through)

Document the reasoning in the record. Assessors look for consistency and traceability more than perfect scoring. ²

4) Assign ownership and deadlines that force movement

Each finding needs:

• Accountable owner (a named person, not “Engineering”)
• Responsible team (service owner)
• Target completion date tied to release cycles and operational constraints
• Escalation path when overdue (manager chain, security governance committee)

If you do nothing else, do this. Most “stuck findings” have no real owner. ²

5) Execute remediation with change control discipline

Remediation work should produce:

• A code change, config change, or infrastructure change that addresses root cause.
• A linked change record (where your environment requires formal change management).
• Notes on deployment scope (prod, staging, shared services).

For findings that require architectural change, record interim mitigations and the long-term plan in the ticket. ³

6) Validate remediation (retest or equivalent confirmation)

Define acceptable validation methods by finding type:

• App findings: retest steps documented, evidence of fixed behavior, and prevention of regression (tests, SAST rule, secure coding pattern).
• Infra findings: configuration evidence plus independent verification (scan output, command output, control-plane screenshot).
• Identity findings: policy screenshots/exports, access logs, and a negative test (cannot reproduce prior escalation).

Close only after validation evidence is attached and reviewed by Security (or an approved delegate). ²

7) Manage exceptions formally (risk acceptance and compensating controls)

For any finding not remediated:

• Record business rationale.
• Define compensating controls (WAF rule, network restriction, monitoring alert, feature flag).
• Set an expiry condition (date, milestone, next pen test, or product release).
• Capture approver identity and role.

Avoid “accepted forever.” If it must remain open, revisit on a defined cadence and keep the approval trail. ²

8) Prove the control operates continuously

Build a recurring evidence capture routine:

• A report showing all pen test findings, status, aging, and exceptions.
• A sample set of closed findings with attached validation.
• Metrics are optional, but status and traceability are not.

Daydream (or any GRC system you use) should map the safeguard to your workflow and automatically collect recurring evidence from tickets, change records, and validation artifacts so you are not rebuilding the story at audit time. ²

Required evidence and artifacts to retain

Keep evidence in a way that supports a clean “report → ticket → fix → validate → close” narrative.

Artifact	What auditors expect to see	Where it usually lives
Pen test report (final)	Scope, timing, methodology summary, findings list	Sec repository / GRC
Findings register	Every finding has a unique record and status	Ticketing/GRC
Triage notes	Severity rationale, scope confirmation, disposition	Ticket comments/attachments
Remediation ticket(s)	Owner, due date, tasks, linked PR/changes	Jira/ServiceNow
Change records (if applicable)	Approval trail for production changes	ITSM
Validation proof	Retest results, screenshots, logs, scan outputs	Ticket attachments
Exception approvals	Approver, rationale, compensating controls, expiry	GRC exception module
Third-party correspondence	Commitments, timelines, escalation	Vendor management system

Common exam/audit questions and hangups

• “Show me the last penetration test and walk me through how one critical/high finding was remediated and validated.”
• “How do you ensure findings are assigned to the right owner and not lost between Security and Engineering?”
• “What is your definition of ‘closed’? Who is allowed to close a finding?”
• “Do you have any accepted findings? Who approved them, and when do they expire?”
• “How do you handle findings in third-party systems or SaaS platforms?”

Hangup to anticipate: teams can show tickets, but cannot show validation or approval evidence. Build that into closure criteria upfront. ²

Frequent implementation mistakes and how to avoid them

1. PDF-only remediation

• Mistake: Findings live only in the report and “get fixed” informally.
• Fix: Require a system-of-record entry for every finding with owner and status. ²

2. Closing without proof

• Mistake: “Developer said it’s fixed” becomes the closure standard.
• Fix: Attach validation evidence and require Security review before closure. ³

3. No exception governance

• Mistake: Long-lived “accepted risk” with no approver trail.
• Fix: Use a formal exception record with expiry and compensating controls. ²

4. Third-party findings treated as “not our problem”

• Mistake: You forward the report and stop tracking.
• Fix: Track third-party remediation like any other finding; escalate through procurement and contractual obligations. ²

5. Fixing symptoms, not root causes

• Mistake: One endpoint patched while the pattern persists.
• Fix: Add root-cause fields and require a “scope review completed” checkbox or note. ³

Enforcement context and risk implications

No public enforcement cases are provided in the source catalog for this safeguard. Practically, remediation failures increase the likelihood that known exploit paths remain open and can compound impact during an incident investigation. Expect internal audit, customer security reviews, and cyber insurers to ask for proof that pen test findings are governed and closed with validation. ²

Practical 30/60/90-day execution plan

Days 1–30: Establish the remediation mechanism

• Define closure criteria and minimum required fields for pen test findings records. ²
• Pick the system of record and implement a standard template for pen test findings tickets. ³
• Run a tabletop on the most recent pen test: extract findings into tickets, assign owners, set due dates, and document dispositions. ²

Days 31–60: Make it auditable and enforceable

• Implement a weekly (or governance-appropriate) triage/remediation review with Security + owners. ²
• Add an exception workflow for risk acceptance with required approvers and expiry conditions. ²
• Pilot validation requirements: attach retest evidence for a subset of remediated findings; refine what “good evidence” looks like. ³

Days 61–90: Operationalize as a recurring control

• Tie the workflow to each penetration test engagement: kickoff includes evidence expectations and retest planning. ²
• Build a recurring evidence package (register export, sample closures, exception log) and store it in your audit repository or Daydream control record. ²
• Review open findings for patterns and drive systemic fixes (secure coding standards, hardening baselines, monitoring). ³

Frequently Asked Questions

Do we have to remediate every penetration test finding?

You must drive each finding to a governed outcome: fixed and validated, or formally risk-accepted with compensating controls and documented approval. “We chose not to fix it” without an exception record will not hold up in an audit. ²

What counts as “validation” for closing a pen test finding?

Validation is evidence that the exploit path no longer works (or is materially reduced) after remediation. Retest by the tester is ideal; otherwise use documented reproduction steps plus independent verification artifacts appropriate to the finding type. ³

How should we handle findings in a third-party SaaS platform?

Track the finding internally, assign an internal owner for follow-up, and record the third party’s remediation commitment and timeline. If you cannot get remediation, document risk acceptance plus compensating controls you control. ²

Can Engineering close findings directly in Jira/ServiceNow?

They can complete remediation tasks, but closure should require validation evidence and an approval step by Security or a designated control owner. This separation reduces “closed without proof” outcomes. ²

What evidence do auditors ask for most often?

They usually want one end-to-end example: report excerpt, the ticket, the remediation change, and proof of retest/validation, plus any exception approval if it wasn’t fixed. Keep that chain intact and searchable. ²

How do we map Safeguard 18.3 in a GRC tool without creating busywork?

Map the safeguard to your existing defect/change workflow and automate evidence collection from the system of record (tickets, approvals, attachments). Daydream is effective here because the control record can point to live artifacts and recurring exports rather than manual screenshots. ²

Footnotes

1. CIS Controls v8; CIS Controls Navigator v8

2. CIS Controls v8

3. CIS Controls Navigator v8