ID.AM-01: Inventories of hardware managed by the organization are maintained

To meet the id.am-01: inventories of hardware managed by the organization are maintained requirement, you must keep an accurate, current hardware asset inventory for all organization-managed devices (on-prem, cloud-connected, remote, and operational tech as applicable), and prove it’s maintained through defined ownership, update workflows, and recurring reconciliation. Your goal is audit-ready completeness: you can identify what you have, who owns it, where it is, and how it’s managed.

Key takeaways:

• A “hardware inventory” is a maintained system of record plus operational processes that keep it current, not a one-time spreadsheet.
• Scope must cover every organization-managed device, including remote endpoints and cloud-managed hardware, with clear ownership and lifecycle states.
• Evidence matters: auditors look for repeatable updates, reconciliation results, and exception handling tied to policy and procedure.

ID.AM-01 sits in the “Identify” function of NIST CSF 2.0 and is a foundational control: if you cannot enumerate managed hardware, you cannot reliably patch, monitor, harden, or respond to incidents. For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing this requirement is to treat the hardware inventory as a governed system of record with defined inputs (procurement, IT operations, endpoint management, cloud/device management), defined outputs (reports, reconciliations, exception queues), and assigned accountability.

This page gives requirement-level implementation guidance you can put into a control statement, assign to an owner, and test. It prioritizes what auditors and assessors typically probe: scope clarity (“what counts as hardware”), data quality (“can we trust the inventory”), and operational maintenance (“how do updates happen and how do we detect drift”). The NIST CSF text is brief, so your defensibility comes from the operational design you wrap around it and the evidence you retain over time ¹.

Regulatory text

Requirement excerpt: “Inventories of hardware managed by the organization are maintained” ¹.

Operator interpretation (what you must do):

• Maintain an inventory of hardware that the organization manages. “Maintained” means it stays current through defined processes, not ad hoc updates.
• Demonstrate that the inventory is authoritative enough to support cybersecurity operations: you can identify devices, tie them to owners, and track lifecycle status.
• Show the control is owned, implemented via procedure, and produces recurring evidence ².

Plain-English interpretation of the requirement

You need a reliable answer to: “What devices do we manage right now?” Then you need to keep that answer current as devices are purchased, deployed, moved, repaired, retired, lost, or replaced.

A practical definition that works in audits: A hardware inventory is a system of record (CMDB/asset platform/MDM/EDR inventory) plus operational workflows that keep device records accurate and complete across the device lifecycle.

Who it applies to (entity and operational context)

Entities: Any organization operating a cybersecurity program and aligning to NIST CSF 2.0, including regulated and non-regulated organizations that use CSF as their control baseline ².

Operational scope (typical):

• End-user computing: laptops, desktops, mobile devices, tablets.
• Server and infrastructure: physical servers, network gear, firewalls, wireless APs, storage appliances.
• Specialized/OT/IoT (where managed by the organization): badge readers, cameras, medical devices, manufacturing controllers, conferencing gear.
• Remote and hybrid: devices managed by corporate tooling even if physically offsite.
• Cloud-adjacent hardware: devices managed through cloud consoles (for example, cloud-managed networking equipment) if you administer them.

Scoping decision you must document: what “managed by the organization” means in your environment (corporate-owned only, or also BYOD enrolled in MDM, or contractor devices with endpoint agents). Auditors accept different boundaries, but they do not accept undocumented ones.

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

1) Name the system of record and the control owner

• Pick the authoritative inventory source (or define a hierarchy, such as CMDB as primary with automated feeds from EDR/MDM).
• Assign a control owner (often IT Asset Management, IT Operations, or Security Operations) and a GRC owner responsible for testing and evidence.
• Write a short control statement that maps to ID.AM-01 and references the system(s) used ².

2) Define minimum required fields (what “inventory” means)

Set a required field standard so records are actionable. Common minimum fields:

• Unique asset ID (tag or logical ID)
• Device type/category
• Manufacturer/model
• Serial number (where available)
• Hostname and/or device name
• Primary user/owner and support group
• Business unit/cost center
• Location (site/region) or “remote”
• Environment (prod/dev/lab) where relevant
• Management method (MDM/EDR/agentless/network discovery)
• Lifecycle status (ordered, in stock, deployed, in repair, retired, disposed)
• Last seen / last check-in timestamp (from MDM/EDR)

If you cannot populate a field for a class of devices (common for OT/IoT), document the exception and define an alternate identifier.

3) Establish inventory inputs (how assets get into the inventory)

Tie the inventory to operational choke points:

• Procurement intake: purchase orders, receiving, and asset tagging create or pre-create records.
• IT service workflows: onboarding tickets, imaging/build processes, device enrollment into MDM/EDR.
• Network discovery feeds: DHCP/DNS, NAC, vulnerability scanners, or discovery tools that detect unmanaged devices.
• Cloud and identity signals: enrollment events, directory joins, and device compliance states.

Your goal is coverage by design: assets enter the inventory because operations require it.

4) Establish maintenance workflows (how records stay current)

Document procedures for:

• New device deployment (create/activate record, assign user, enroll in management)
• Transfers (owner/location changes)
• Repairs/replacements (status changes and linkage to prior asset)
• Decommissioning and disposal (retire record with disposition evidence)
• Lost/stolen handling (status, incident linkage, remote wipe if applicable)

Add an “exception queue” workflow: what happens when a device is detected but not in inventory, or is in inventory but hasn’t checked in.

5) Reconcile and validate completeness (detect drift)

Auditors test whether the inventory reflects reality. Build reconciliation into BAU:

• Compare procurement/receiving logs to the inventory to confirm assets were recorded.
• Compare MDM/EDR device lists to the inventory to find “managed but not inventoried” devices.
• Compare discovery outputs (network scans/NAC) to the inventory to find “present but unmanaged” devices.
• Track and close reconciliation exceptions with tickets and timestamps.

If you use Daydream for control operations, set recurring evidence tasks tied to ID.AM-01 (policy/procedure reference, owner attestations, reconciliation outputs, and exception closure reports) so you can answer audit requests fast and consistently.

6) Set governance: policy, procedure, and review cadence

• Update your asset management or cybersecurity policy to require a maintained hardware inventory aligned to ID.AM-01 ².
• Approve a procedure that describes sources, required fields, and workflows.
• Define who reviews exceptions and who signs off on periodic inventory health reporting.

Required evidence and artifacts to retain

Keep artifacts that prove “maintained” over time:

• Policy statement referencing maintained hardware inventory aligned to ID.AM-01 ².
• Procedure/runbook for inventory creation, updates, and decommissioning.
• System screenshots or exports showing required fields, sample records, and lifecycle statuses.
• Data flow diagram or narrative showing inventory sources (MDM/EDR/CMDB/procurement/discovery).
• Reconciliation reports and exception logs with ticket closures.
• Access controls: list of roles/groups who can edit inventory records; change logging configuration where available.
• Sampling package: a short auditor-ready sample set linking devices to enrollment evidence (MDM/EDR) and ownership assignment.

Common exam/audit questions and hangups

Expect these:

• “Show me your authoritative hardware inventory and who owns it.”
• “How do you know it’s complete for remote endpoints and offices?”
• “How do devices get added, updated, and retired? Show the ticket trail.”
• “How do you detect unknown/unmanaged devices?”
• “Pick a sample of devices from EDR/MDM and prove they exist in the inventory (and vice versa).”
• “What devices are out of compliance (no check-in, unknown owner, missing serial) and how do you remediate?”

Hangups that slow audits:

• Inventory exists but lacks ownership fields.
• Multiple inventories with no declared source of truth.
• “Last seen” data not captured, so staleness can’t be measured or triaged.
• Poor documentation of what “managed by the organization” includes.

Frequent implementation mistakes and how to avoid them

1. Spreadsheet-as-inventory with no maintenance process.
   Fix: keep the spreadsheet only as an export; the maintained record should live in a managed system with defined update workflows.

2. Ignoring “gray” asset classes (labs, conference rooms, OT, kiosks).
   Fix: explicitly include them or document a scoped exclusion with compensating controls and an owner.

3. No reconciliation between tooling and inventory.
   Fix: run routine comparisons between MDM/EDR/discovery lists and the inventory; track exceptions to closure.

4. Treating procurement as the only source of truth.
   Fix: incorporate operational discovery. Devices appear via mergers, emergency purchases, field swaps, or contractor activity.

5. No lifecycle statuses.
   Fix: require states like “in stock,” “deployed,” “retired,” “disposed.” Auditors look for retired assets that still “exist” in tooling.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite enforcement actions.

Operationally, weak hardware inventory creates predictable failure modes: unmanaged endpoints miss patches, unknown devices evade monitoring, and incident response loses time identifying affected assets. Even when a framework control is “medium” severity internally, assessors often treat asset inventory gaps as a root cause that undermines multiple downstream controls ².

Practical 30/60/90-day execution plan

First 30 days (stabilize scope and ownership)

• Define “managed hardware” scope and document inclusions/exclusions.
• Appoint the control owner and name the authoritative inventory system(s).
• Define required fields and lifecycle statuses.
• Produce an initial export and identify the largest data quality gaps (missing owner, missing serial, duplicates).

Days 31–60 (operationalize maintenance and reconciliation)

• Implement workflows that add/update/retire assets via tickets or automated feeds.
• Connect primary tooling feeds (MDM/EDR) to the system of record or define a repeatable import process.
• Stand up an exception queue and assign a team to resolve discrepancies.
• Draft the procedure/runbook and align it to the policy requirement ².

Days 61–90 (make it auditable and repeatable)

• Run formal reconciliations and retain outputs plus closure evidence.
• Build a standard audit sampling package (device record + management proof + owner assignment).
• Add recurring evidence collection in Daydream (or your GRC system) mapped to ID.AM-01: policy, procedure, owner attestation, reconciliation report, and exception closure report ².

Frequently Asked Questions

Does “hardware managed by the organization” include employee BYOD devices?

It depends on whether you manage them. If BYOD devices are enrolled in MDM or required to run corporate endpoint controls, include them in scope and label them as BYOD in the inventory.

Can we have multiple inventories (CMDB plus EDR plus MDM)?

Yes, but you must declare which one is authoritative for audit purposes and document how the others feed it or how you reconcile them. Auditors mainly reject “three sources of truth.”

What’s the minimum data an auditor expects in the inventory?

They expect unique identification, ownership, device type, and lifecycle status, plus a way to show the record is current (often “last seen” from MDM/EDR). If a device class can’t support a field (common in OT), document the exception and alternate identifier.

How do we prove the inventory is “maintained” versus created once?

Keep time-stamped reconciliation outputs, exception logs, and ticket evidence showing adds/changes/retirements. Pair that with a procedure that assigns responsibility and describes update triggers.

We discover unknown devices on the network. Are we automatically noncompliant?

Unknown devices are normal; the compliance question is whether you detect them, investigate them, and either bring them under management, document an approved exception, or remove them.

How should Daydream fit into this control?

Use Daydream to map ID.AM-01 to an owner, policy/procedure references, and recurring evidence tasks (inventory exports, reconciliations, exception closure). That reduces scramble during audits because the evidence package is assembled as operations run.

Footnotes

1. NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes

2. NIST CSWP 29