Configuration baseline and hardening governance

For FedRAMP-scoped environments, configuration baseline and hardening governance is the difference between “we hardened it once” and “we can prove we run securely every day.” The requirement is simple on paper: maintain approved secure baselines for all in-scope cloud components. In practice, teams stumble because “baseline” spans far beyond virtual machines. It includes managed services, cloud identities, network controls, containers, images, endpoints used for administration, and the CI/CD paths that build and deploy these components.

A CCO or GRC lead needs this requirement operationalized into repeatable governance, clear accountability, and audit-ready artifacts. That means: (1) deciding what “in scope” means for baselines, (2) defining hardened configuration standards and mapping them to your system boundary, (3) implementing enforcement and drift monitoring, and (4) proving exceptions are reviewed, approved, time-bound, and remediated.

This page gives requirement-level implementation guidance you can hand to security engineering and cloud operations without turning it into an academic exercise. It also flags common audit hangups and the evidence packages that consistently pass FedRAMP-style scrutiny. Sources are limited to program guidance and underlying framework references provided in the fact pack. ¹

Regulatory text

Requirement (FedRAMP): “Maintain approved secure baselines for all in-scope cloud components.” ²

What the operator must do:
You must (a) define secure configuration baselines for each component type in your authorization boundary, (b) obtain documented approval for those baselines, (c) implement the baselines in the environment, and (d) continuously manage configuration drift with documented remediation and controlled exceptions. FedRAMP expects this to be maintained as an operational control, supported by evidence and repeatable governance, not handled as an ad hoc engineering preference. ¹

Plain-English interpretation (what “baseline and hardening governance” really means)

A “secure baseline” is the minimum acceptable configuration state for a class of assets (for example: a Linux image, a container base image, an RDS instance, a Kubernetes cluster, an IAM role pattern, a security group pattern). “Hardening governance” is the management system that keeps those baselines real over time: ownership, review/approval, change control, testing, rollout, drift monitoring, and exception handling.

If your baseline is a PDF that no one can tie to actual builds, you will struggle in assessment. The baseline has to be traceable to running configurations and enforceable through tooling or repeatable procedures. ¹

Who it applies to (entity and operational context)

Primary applicability: Cloud Service Providers operating systems intended for FedRAMP authorization, including the underlying cloud infrastructure and supporting services within the defined system boundary. ²

Operational context:

• Cloud components in scope: OS images, managed databases, load balancers, VPC/VNet constructs, firewalls/security groups, IAM identities and policies, secrets management, logging pipelines, container registries, orchestration platforms, admin endpoints, and CI/CD systems that build/deploy into the boundary.
• Teams involved: Cloud platform/SRE, security engineering, IAM, network/security operations, DevOps, and GRC/control owners.
• Third parties: If a third party provides managed components inside your boundary (for example, a managed SOC tool deployed in your tenant), you still need baseline expectations and exception rules for how it is configured and maintained.

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

1) Define scope and inventory “baseline-able” components

Create a component inventory aligned to your system boundary and categorize by baseline type:

• Compute (VM images, OS builds)
• Containers (base images, runtime policies)
• Network (routing, segmentation, security groups)
• Identity (roles, policies, MFA, service accounts)
• Managed services (databases, queues, storage, key management)
• Build/deploy systems (CI runners, IaC pipelines)

Operator tip: If the component can be configured, it can drift. Baseline it or formally justify why it is excluded.

2) Choose baseline sources and translate them into your standards

Pick an authoritative baseline source for each technology stack and create your organization’s “approved secure baseline” artifact:

• Map baseline statements to implementable settings (examples: SSH config, TLS settings, logging flags, IAM policy guardrails).
• Include rationale where deviations exist.
• Record baseline version, owner, approval date, and effective date.

FedRAMP programs commonly align to NIST control expectations, so your baseline governance should map cleanly into your control narrative and SSP-style descriptions. ³

3) Implement baselines as code (where possible) and make approvals real

Turn baseline requirements into enforceable mechanisms:

• Golden images: Packer/Image pipelines producing signed images with hardened configurations.
• IaC modules: Approved Terraform/CloudFormation modules with secure defaults (and blocked insecure options).
• Policy-as-code: Preventive controls (for example, guardrails that block public storage or weak IAM patterns).
• Configuration management: Desired state for OS and middleware.

Approval workflow: Route baseline changes through a documented change process with security and system owner sign-off. Store approvals in your change system and link them to baseline version tags.

4) Establish drift monitoring with documented remediation

Implement continuous monitoring that detects and records:

• What drifted (parameter/config change)
• Where (asset ID/account/project/cluster)
• When (timestamp)
• Who/what changed it (identity, pipeline)
• Ticket created, remediation steps, and closure evidence

Drift response should be consistent:

• Auto-remediate low-risk, high-confidence drifts.
• Escalate high-risk drifts to incident or emergency change processes.
• Track exceptions with explicit risk acceptance and expiry.

This aligns to the recommended control: enforce baseline standards and monitor drift with documented remediation. ²

5) Build an exception process that auditors can follow

You need a formal exception pattern for cases where a component cannot meet baseline:

• Business justification
• Risk description and compensating controls
• Approver(s): system owner + security + compliance as needed
• Expiration date and review trigger
• Plan to remediate or permanently accept with rationale

Keep exceptions rare and time-bound. In practice, repeated exceptions usually mean your baseline is unrealistic or your engineering path can’t meet it.

6) Prove it works: testing, reporting, and governance cadence

Create a recurring governance routine:

• Review baseline changes
• Review drift and remediation metrics (qualitative is fine; don’t invent numbers)
• Sample evidence for each component class
• Validate new services are onboarded to a baseline before production

A lightweight, repeatable monthly control meeting with engineering owners often satisfies “governance” expectations, as long as it produces artifacts (minutes, decisions, action items) tied to control operation. ²

Required evidence and artifacts to retain (audit-ready)

Keep a “baseline evidence package” organized by component class:

1. Baseline standards (version-controlled)

• Secure baseline documents or baseline-as-code repositories
• Version history (tags/commits) and change rationale
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2. Approval records

• Change tickets, pull request approvals, meeting minutes showing formal approval
• Named owners and approvers for each baseline

3. Implementation evidence

• Golden image build logs and configuration outputs
• IaC module references used by production stacks
• Screenshots/exports of key managed service settings (where IaC is not possible)

4. Drift monitoring evidence

• Tool reports, alerts, and sample drift events
• Tickets showing remediation from detection to closure
• Evidence of automated enforcement or guardrails
  ²

5. Exception register

• Exception requests, approvals, compensating controls, and expiry tracking

6. Training/operational procedures

• Runbooks for baseline rollout and remediation
• Onboarding checklist requiring baseline alignment before production

Common exam/audit questions and hangups

Auditors and assessors typically probe these areas:

• “Show me your approved baselines.” Expectation: named owner, documented approval, versioning, and applicability statements. ²
• “How do you know production matches the baseline?” Expectation: drift monitoring plus examples of remediation tickets. ²
• “What about managed cloud services?” Hangup: teams baseline only VMs and ignore IAM, storage, KMS, logging, and network defaults.
• “How do you handle exceptions?” Expectation: formal approvals and a tracked register, not Slack messages.
• “How do changes to baselines get tested?” Expectation: some gated path (CI checks, dev/stage validation) and documented change control. ⁴

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails in practice	What to do instead
Baselines live in a Word doc and drift from reality	You can’t prove implementation	Maintain baseline-as-code or link documents to exact build artifacts and IaC modules
“One baseline for everything”	Different services need different controls	Define baselines per component class (OS, DB, IAM, network, containers)
No ownership	Baseline becomes stale	Assign a named baseline owner for each domain and require periodic review
Exceptions handled informally	Auditors treat it as unmanaged risk	Use a formal exception register with approvals and expiration
Drift alerts without remediation trail	Looks like monitoring theater	Require tickets for drift events and store closure evidence 2

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. Practically, the risk is still concrete: weak or inconsistent hardening increases the likelihood of misconfiguration exposure, unauthorized access paths, and audit findings that delay or jeopardize authorization decisions. For FedRAMP work, “insufficient implementation evidence” is a primary failure mode: you may be doing the work, but can’t prove it during assessment. ²

Practical 30/60/90-day execution plan

First 30 days: establish governance and cover the highest-risk components

• Confirm system boundary and produce a component inventory list tied to owners.
• Draft baseline standards for your top component classes (OS images, IAM, network, logging, storage).
• Stand up an exception register and approval workflow.
• Identify drift monitoring sources already available (CSP native tools, configuration scanners, SIEM alerts) and define what evidence you will retain.
  ²

Days 31–60: implement enforcement and generate real evidence

• Convert the most used baselines into enforceable code: golden images and IaC modules with secure defaults.
• Add preventive guardrails for the most common misconfigurations (block or require approval).
• Run drift monitoring, open remediation tickets, and close them with screenshots/exports/logs.
• Hold a baseline governance review meeting and record decisions (baseline updates, exception approvals).
  ²

Days 61–90: expand coverage and make it repeatable

• Extend baselines to remaining in-scope managed services and platform components.
• Add baseline checks to CI/CD so insecure configurations fail before deployment.
• Create an audit-ready evidence pack with representative samples for each component class.
• Run an internal “mock assessment” interview: ask engineers to produce baseline and drift evidence on demand. Fix gaps immediately.
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How Daydream fits (without adding process overhead)

Teams often lose weeks assembling evidence across repos, ticketing, and cloud consoles. Daydream can act as the control workspace where you define the configuration baseline and hardening governance requirement, assign owners, track exception approvals, and attach drift/remediation evidence in a single place so audits become a packaging exercise rather than a scavenger hunt.

Frequently Asked Questions

Do we need a separate baseline for every cloud service?

You need an approved secure baseline for every in-scope component type that has meaningful security configuration. Group services logically (for example, “object storage baseline,” “managed database baseline”) and document applicability. ²

What counts as “approved” for a baseline?

Approval means you can show who reviewed and authorized the baseline and when, with a record that is retained. A change ticket, pull request approval, or governance meeting minutes can satisfy this if it’s traceable to the baseline version. ²

Can we meet this requirement without baseline-as-code?

Yes, but evidence becomes harder. If you cannot enforce via code, you need repeatable build procedures, configuration validation steps, and retained proof that production matches the documented baseline. ²

How do we handle emergency changes that break the baseline?

Treat them as time-bound exceptions with a documented business reason, approver, and a remediation plan. After the emergency, either restore baseline settings or update the baseline through formal change control. ²

What’s the minimum drift evidence auditors expect to see?

Provide examples that show detection, triage, remediation, and closure, tied to specific resources. The record should show that drift leads to action, not just alerts. ²

Does this apply to third-party tools running in our cloud account?

If the tool is deployed inside your authorization boundary, baseline expectations still apply to its configuration and the surrounding cloud controls (IAM, network, logging). If the third party controls the configuration, document the boundary and manage it through third-party governance and exceptions where needed. ²

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control lifecycle management

Footnotes

1. FedRAMP Baseline Documentation; NIST SP 800-53 Rev. 5

2. FedRAMP Baseline Documentation

3. NIST SP 800-53 Rev. 5; FedRAMP Baseline Documentation

4. NIST SP 800-53 Rev. 5