BAI07: Managed IT Change Acceptance and Transitioning

If your organization treats “deployment complete” as the finish line, BAI07 will fail in an audit. This objective expects a disciplined acceptance and transition process: changes must meet defined acceptance criteria before they move to production, and the transition must be planned, authorized, and verifiable. For a CCO, GRC lead, or IT risk owner, the fastest path is to treat BAI07 as a release-governance requirement with three practical outcomes: (1) the business and IT agree on acceptance criteria; (2) the organization can prove those criteria were met before go-live; (3) the organization can show the change was transitioned safely (implementation plan, backout plan, communications, monitoring, and confirmation of success).

BAI07 also shows up indirectly in third-party risk. If critical services are delivered by cloud providers, MSPs, or SaaS platforms, you still need acceptance and transition evidence for changes that affect your environment, integrations, security posture, or customer-impacting features. Your job is to design “right-sized” gates for different risk levels while keeping the paper trail consistent enough that auditors can follow it without reading minds. COBIT provides the control objective framing ¹.

bai07: managed it change acceptance and transitioning requirement (plain-English)

BAI07 expects you to run a controlled path from “change ready” to “change live,” with formal acceptance criteria and documented authorization. In plain terms:

• Acceptance: You define what must be true before a change can be promoted (tests passed, security checks completed, documentation ready, stakeholder approval obtained).
• Transitioning: You move the change into production using a planned, authorized procedure (release plan, deployment steps, backout, communications, monitoring, verification).
• Evidence: You can demonstrate each step happened for each change or release, not only that you “have a policy.”

This is a governance requirement, but it lives in engineering operations: release management, change management, testing, security reviews, and service operations.

Regulatory text

Provided excerpt: “COBIT 2019 objective BAI07 implementation expectation.” ¹

Operator interpretation (what you must do):

• Translate the COBIT objective into documented procedures and assigned ownership for acceptance and transition activities.
• Implement defined acceptance criteria for changes (what gets checked, by whom, and what constitutes pass/fail).
• Require authorization before production transition.
• Retain implementation evidence that ties back to each change/release and demonstrates the process ran as designed. ¹

Who it applies to (entity + operational context)

Applies to:

• Any enterprise IT organization using COBIT 2019 as its governance framework baseline ².
• Regulated environments adopting COBIT mappings for audit readiness and control alignment ³.

Operationally, this touches:

• Application and infrastructure change/release management (CI/CD, pipelines, manual deployments).
• ITSM change tickets (standard/normal/emergency change flows).
• Security and privacy teams who gate changes (vulnerability, configuration, access, encryption, logging).
• Third parties performing changes on your behalf (managed service providers, SaaS feature changes affecting integrations, outsourced development).

Scoping tip (fast): Start with production changes to systems that support financial reporting, customer data, regulated processes, or core availability. Then expand to remaining systems using risk-tiered gates.

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

1) Assign clear ownership and RACI

• Name a process owner (often ITSM/change manager or release manager).
• Define approvers: service owner, security, operations, business owner (as needed).
• Define who can declare acceptance vs who can deploy.

Output: RACI + role descriptions; approval matrix.

2) Define change categories and acceptance “gates”

Create a simple classification that drives how strict the acceptance is:

• Low-risk (pre-authorized/standard): repeatable, low-impact, heavily automated checks.
• Normal: full acceptance criteria, documented approvals.
• Emergency: expedited approval with mandatory after-the-fact validation and documentation.

Output: Change classification standard; criteria by category.

3) Write acceptance criteria that can be evidenced

Acceptance criteria should be specific and testable. Examples you can audit:

• Functional testing completed with results attached.
• Security checks completed (SAST/DAST results, dependency scanning results, configuration review).
• Required documentation updated (runbooks, architecture notes, user impact notes).
• Operational readiness done (monitoring/alerts updated; on-call informed).
• Data migration validated (if applicable).
• Stakeholder sign-off recorded.

Output: Acceptance checklist template ².

4) Implement a controlled “ready to deploy” decision

Before deployment:

• Confirm all required checks are complete.
• Confirm segregation of duties where applicable (the same person should not be the only approver and implementer for higher-risk changes).
• Capture formal approval (ticket approval, CAB note, e-signature, or equivalent).

Output: Ticket state change (e.g., “Accepted for Release”), with approver identity and timestamp.

5) Plan and execute the production transition

Require a transition package for normal/high-risk changes:

• Deployment plan (steps, owners, timing, freeze windows if relevant).
• Backout plan and triggers.
• Communication plan (internal stakeholders; customer notices where relevant).
• Verification plan (smoke tests, dashboards to watch, success criteria).
• Monitoring plan (new alerts/logging changes).

Output: Release/implementation plan attached to the change record.

6) Perform post-implementation verification (PIV)

After production deployment:

• Validate the change achieved intended outcomes.
• Confirm no critical incidents/regressions were introduced.
• Close the change only after PIV completion, or document exceptions.

Output: PIV checklist with evidence (screenshots, links to dashboards, test confirmations, incident references).

7) Operate metrics and governance (so it stays real)

You do not need fancy KPIs to meet the spirit of BAI07, but you do need governance:

• Sample changes each month/quarter for completeness of evidence.
• Track recurring failure patterns (missing approvals, weak backout, incomplete testing).
• Feed lessons learned into templates and pipeline gates.

Output: QA review log, remediation tickets, process updates.

8) Extend to third parties (right-sized)

Where third parties deploy or change systems that affect you:

• Require notice and acceptance artifacts for impactful changes (release notes, test attestation, rollback plan).
• Map their evidence into your control record (or store pointers with immutable references).

Output: Contract/SLA change-notice clauses; third-party change evidence repository links.

Required evidence and artifacts to retain (audit-ready)

Keep artifacts in a way that an auditor can trace from a production change back to acceptance.

Minimum evidence set ²:

• Change record (ticket) with unique ID and classification.
• Acceptance checklist completed (or automated pipeline evidence).
• Test results (links or attachments).
• Security review evidence (as applicable).
• Approval/authorization record (who/when).
• Transition package: deployment plan + backout plan + communications plan (as applicable).
• Post-implementation verification record.
• Exception record for emergencies (why expedited, who approved, what follow-up occurred).

Program-level evidence (process proof):

• Documented procedure and ownership mapped to BAI07 (recommended control in your data pack).
• Templates/checklists, approval matrix, and training/enablement materials.
• Evidence of periodic sampling/QA and remediation actions.

If you need a simple way to manage this, Daydream can host the requirement narrative, map artifacts to BAI07, and keep a live evidence index that stays current as teams ship changes.

Common exam/audit questions and hangups

Auditors tend to probe for “show me” gaps. Expect questions like:

• “Show three recent production changes and the acceptance evidence for each.”
• “Where are your acceptance criteria defined, and who owns them?”
• “How do you prevent bypassing approvals in CI/CD?”
• “How are emergency changes reviewed after the fact?”
• “How do you ensure third-party changes follow equivalent acceptance and transition controls?”

Hangup to anticipate: Teams can often show a change ticket and a deployment log, but not a clear acceptance decision with criteria and sign-off.

Frequent implementation mistakes (and how to avoid them)

1. Acceptance criteria live in people’s heads.
   Fix: Use a checklist template by change type; require completion before the ticket can be marked ready.

2. Approval exists, but it’s not tied to evidence.
   Fix: Make approvals conditional on linked test/security artifacts. Train approvers to reject “LGTM” with no attachments/links.

3. CI/CD pipelines deploy without governance hooks.
   Fix: Add pipeline gates (manual approval steps for certain branches/environments; required checks must pass).

4. Emergency changes become a loophole.
   Fix: Require a follow-up record: what was skipped, who approved, and completion of missing validations after restoration.

5. Third-party changes are ignored.
   Fix: Treat provider release notes and change notices as artifacts. Maintain a register of “third-party driven changes” that affect your environment.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. Practically, BAI07 failures show up as operational and control failures: outages from poorly transitioned releases, security exposures from unreviewed changes, and audit findings where you cannot prove approvals, testing, or readiness. In regulated exams, the highest friction is usually “inconsistent execution” across teams or platforms, not the absence of a policy.

Practical 30/60/90-day execution plan

Because this is an operational control, plan by maturity phases rather than calendar promises.

First 30 days (establish the control)

• Appoint process owner; publish RACI and approval matrix.
• Define change categories and minimum acceptance criteria per category.
• Roll out a single acceptance checklist template and a transition package template.
• Select a system of record (ITSM tool, ticketing system, or GRC evidence tool) and standardize where artifacts live.

Days 31–60 (make it real in tooling and workflows)

• Implement ticket workflow states: “Ready for acceptance,” “Accepted,” “Ready to deploy,” “Deployed,” “PIV complete.”
• Add required fields/attachments (or links) for tests, approvals, and backout plan.
• Implement CI/CD gates aligned to risk categories.
• Run a pilot with two to three high-change teams; remediate friction points.

Days 61–90 (scale and prove operating effectiveness)

• Expand to remaining production teams and key infrastructure changes.
• Start periodic sampling and QA reviews; track issues to closure.
• Formalize emergency change after-action review requirements.
• Extend expectations to critical third parties through contract language, attestations, and evidence collection.

Frequently Asked Questions

Do we need a CAB meeting to satisfy BAI07?

No. BAI07 cares about defined acceptance criteria, authorization, and controlled transition evidence. A CAB is one way to implement approvals, but automated approvals and risk-based approver routing can also meet the objective.

How do we handle fully automated deployments?

Treat pipeline controls as the acceptance mechanism: required tests and security scans must pass, and approvals must be recorded where risk warrants. Keep immutable logs that show which checks ran and the outcome, linked to the change record.

What counts as “acceptance criteria” in practice?

Criteria must be specific enough to prove completion, such as attached test results, completed security checks, updated runbooks, and named approver sign-off. Avoid subjective statements like “tested” without artifacts.

How should we document emergency changes?

Record the emergency rationale, expedited approvals, what was skipped, and the post-change validation steps. Close the loop with a follow-up review and attach the missing evidence once conditions stabilize.

Our third party pushes changes frequently. How can we keep up?

Focus on changes that affect your environment or risk posture: integrations, authentication, data flows, and availability commitments. Require release notes or change notices as evidence, and log material changes in your internal change register.

What’s the minimum evidence set auditors usually accept?

A traceable chain: change ID, acceptance checklist, test/security evidence, approval record, deployment/backout plan, and post-implementation verification. Program-level documents alone rarely satisfy sampling-based testing.

Footnotes

1. ISACA COBIT overview; OSA COBIT 2019 objective mapping

2. ISACA COBIT overview

3. OSA COBIT 2019 objective mapping