ID.RA-09: The authenticity and integrity of hardware and software are assessed prior to acquisition and use

To meet id.ra-09: the authenticity and integrity of hardware and software are assessed prior to acquisition and use requirement, you must build a repeatable pre-purchase and pre-deploy gate that verifies the source, integrity, and tamper-resistance of hardware and software before it enters your environment. Operationalize this by tying procurement, third-party due diligence, secure build, and asset intake to documented checks and retained evidence (NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes).

Key takeaways:

• Add an “authenticity + integrity” approval step to buying and deployment workflows, not a one-time review.
• Treat hardware and software supply chain as a risk domain with defined owners, criteria, and exceptions.
• Keep auditable evidence: who approved, what was checked, and what was accepted or rejected.

ID.RA-09 is a supply-chain-facing risk assessment requirement: before you buy or run technology, you must assess whether it is genuine (authentic) and whether it has been altered (integrity). This is a control that fails quietly because procurement and engineering can move fast while evidence collection lags.

For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing ID.RA-09 is to treat it as a gating control embedded into two moments that already exist: (1) acquisition decisions (purchase, subscription, licensing, cloud marketplace buys, open-source adoption), and (2) introduction into production (imaging a laptop, deploying an agent, promoting a build artifact, enabling a SaaS integration). The goal is not perfect certainty. The goal is a defensible, repeatable set of checks that scales by risk tier and produces artifacts an auditor can follow end-to-end.

This page gives requirement-level implementation guidance: applicability, step-by-step execution, evidence to retain, and common audit hangups. It is grounded in the NIST CSF 2.0 requirement statement (NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes).

Regulatory text

Requirement (excerpt): “The authenticity and integrity of hardware and software are assessed prior to acquisition and use” (NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes).

What an operator must do

You must run documented checks before purchasing and before deploying hardware or software to confirm:

• Authenticity: the item comes from the expected publisher/manufacturer/reseller and is not counterfeit, impersonated, or substituted.
• Integrity: the item and its updates/artifacts have not been tampered with in transit, at rest, or during build/release.

Your program must show (a) defined criteria, (b) risk-based application, (c) approval/exception handling, and (d) retained evidence that the checks occurred prior to acquisition and use (NIST CSWP 29).

Plain-English interpretation

ID.RA-09 means: “Don’t buy or run tech you haven’t validated.” Validation is broader than vulnerability scanning. It includes verifying supply chain signals (publisher identity, signing, hashes, provenance), confirming the acquisition channel (authorized seller or official marketplace), and controlling how software enters production (approved repos, signed builds, controlled images).

A practical interpretation for most organizations:

• Low-risk items get lightweight checks (approved source, basic integrity verification, inventory record).
• High-risk items get deeper verification (publisher validation, signing enforcement, provenance review, controlled deployment, and stronger exception controls).

Who it applies to

Entity scope

Applies to any organization operating a cybersecurity program that acquires or deploys:

• End-user hardware (laptops, phones, network gear, IoT)
• Infrastructure hardware (servers, storage, HSMs)
• Commercial software (desktop, server, SaaS)
• Cloud services and marketplace images
• Open-source components and container images
• Managed services where the third party deploys agents or connects integrations

Operational context (where you should embed it)

ID.RA-09 is easiest to operationalize where work already flows:

• Procurement / sourcing: purchase requests, vendor onboarding, contract review
• IT asset management: receiving, imaging, MDM enrollment, CMDB updates
• Software delivery: CI/CD, artifact repositories, container registries, IaC pipelines
• Third-party risk management: due diligence for providers that ship binaries, hardware, or managed agents
• Change management: approvals to introduce new tools, packages, or integrations

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

Step 1: Assign control ownership and define the “gate”

Pick a single accountable owner (often GRC with IT/security execution owners) and define two gates:

1. Pre-acquisition gate (approve buying/subscribing)
2. Pre-use gate (approve installation/deployment/production enablement)

Document who can approve, who can request exceptions, and who can accept residual risk (NIST CSWP 29).

Step 2: Build a risk-tiering model for purchases and deployments

Create a tiering rubric that drives how deep the authenticity/integrity checks must go. A simple rubric can use:

• Data sensitivity touched
• Privilege level (admin/root, kernel drivers, EDR agents)
• Network exposure
• Vendor/third party access model (interactive admin, API tokens, remote management)
• Deployment scale (single user vs enterprise-wide)

Output: “Tier 1/2/3” (or “Low/Moderate/High”) with required checks per tier.

Step 3: Define required checks for hardware

Minimum checks to document in your procedure:

• Authorized channel verification: buy direct or through authorized resellers; record seller identity.
• Chain-of-custody intake: receiving process, tamper-evident packaging review, serial number capture.
• Asset integrity attestation: confirm firmware/BIOS baselines where feasible; record initial configuration state.
• Quarantine before enrollment: separate receiving from production networks until recorded and approved.

High-risk hardware (network/security appliances, HSMs) should require additional steps such as vendor-provided authenticity verification methods and stricter receiving controls.

Step 4: Define required checks for software (commercial, SaaS, open source)

For software, write down checks you can prove happened:

• Source authenticity: confirm publisher identity (official site, official marketplace listing, verified publisher account).
• Artifact integrity: require signed installers or verify checksums/hashes when available; record the evidence.
• Approved distribution: only install from approved package managers/repos; block direct downloads where feasible.
• Provenance controls in CI/CD: control where dependencies come from; restrict build agents; use an artifact repository as the “source of truth.”
• Pre-production validation: promote only approved build artifacts to production.

For SaaS: the “use” moment is often enabling the integration. Your checks should include confirming the provider identity, reviewing the integration permissions scope, and recording what was enabled and by whom.

Step 5: Embed the checks into workflows (make it hard to bypass)

Controls that live in a PDF get ignored. Put the gate into systems people must use:

• Procurement intake form requires: supplier/source, link to publisher listing, signing/hash evidence (as applicable), requested privileges, and tier.
• Change ticket template includes: artifact/source location, integrity verification method, approver, and planned deployment scope.
• IT receiving checklist requires: serial capture, packaging/tamper check, quarantine status, and enrollment approval.

Step 6: Create an exception path that is painful enough to be rare

You need exceptions (emergency patches, end-of-life hardware, niche tools). Make exceptions controlled:

• Exception request must state why checks can’t be completed, compensating controls, time limit, and owner sign-off.
• Track exceptions in a register with review cadence tied to change management.

Step 7: Monitor and test control operation

Add operational testing so you can prove it works:

• Sample recent purchases and deployments; confirm evidence exists and predates acquisition/use.
• Reconcile asset inventory and software catalog against approved sources.
• Review exceptions and confirm closure.

Daydream (as a workflow layer) fits naturally here if you need a single place to map ID.RA-09 to a control owner, required evidence, and recurring collection tasks across procurement, IT, and engineering.

Required evidence and artifacts to retain

Auditors rarely accept “we always do that.” Keep artifacts that show timing and decisioning.

Core evidence set (keep per item or per sampled item):

• Policy/standard: “Authenticity and Integrity Verification Standard” mapped to ID.RA-09 (NIST CSWP 29).
• Procedure/checklist: hardware receiving + software intake steps.
• Risk tiering rubric and decision matrix.
• Purchase request / procurement ticket with:
  • seller/source identified
  • tier assigned
  • approvals captured
• Integrity verification evidence (as applicable):
  • checksum/hash verification record
  • code-signing validation screenshot/log
  • artifact repository record (immutable build ID)
• Asset inventory record (CMDB/ITAM) with serial, model, acquisition channel, owner, and deployment date.
• Exception register entries with approvals and expiration/closure evidence.
• Periodic control test results (sampling log and remediation notes).

Common exam/audit questions and hangups

Questions you should be ready for:

• “Show me three examples where you verified integrity before installing or deploying.”
• “How do you know software wasn’t altered between download and deployment?”
• “How do you prevent employees from installing tools from unapproved sources?”
• “How do you validate hardware authenticity from resellers?”
• “Where is the evidence that the check happened before purchase/use, not after?”

Hangups that stall audits:

• Evidence exists, but it’s scattered across email, chat, and screenshots with no traceability.
• Teams do checks informally; nothing ties the check to the asset record.
• “SaaS” is excluded because there’s no installer; auditors still expect pre-use assessment.

Frequent implementation mistakes and how to avoid them

1. Treating ID.RA-09 as a one-time vendor assessment.
   Fix: require the gate per acquisition and per deployment path, scaled by tier.

2. No distinction between authenticity and integrity.
   Fix: your checklist must explicitly ask for both. Example: “Verified publisher identity” and “Verified signing/hash.”

3. Relying on “reputation” instead of proof.
   Fix: record objective signals (official listing, signed artifact, controlled repository).

4. Engineering-only control with no procurement linkage.
   Fix: procurement workflows must capture source and approvals. Otherwise you cannot prove “prior to acquisition.”

5. Exception process that becomes the default.
   Fix: time-bound exceptions, compensating controls, and periodic review with ownership.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. Practically, ID.RA-09 maps to real failure modes that create regulatory exposure under other regimes: counterfeit hardware, trojanized installers, dependency hijacking, compromised update channels, and unauthorized software introduction. Treat it as a foundational control for supply chain risk and change governance (NIST CSWP 29).

Practical 30/60/90-day execution plan

First 30 days (Immediate)

• Name the control owner and RACI across Procurement, IT, Security, and Engineering.
• Draft the ID.RA-09 standard: scope, tiers, required checks, and exceptions (NIST CSWP 29).
• Add required fields to purchase requests and change tickets: source, tier, approval, integrity proof.
• Start an evidence register: where each artifact lives and who attaches it.

Days 31–60 (Near-term)

• Roll out hardware receiving checklist and quarantine step for in-scope assets.
• Implement software intake controls: approved repos, artifact repository requirement for production, basic signing/hash verification capture.
• Train approvers and requesters using real examples (one hardware, one commercial software, one SaaS integration, one open-source dependency).
• Run a sample-based control test; log gaps and remediation owners.

Days 61–90 (Operationalize)

• Expand coverage to harder areas: cloud marketplace images, container images, and developer tooling.
• Tighten prevention: restrict local admin installs where feasible; enforce approved software catalogs.
• Operationalize exception governance: expirations, review meetings, and closure evidence.
• Build a recurring evidence collection cadence in Daydream (or your GRC system) so ID.RA-09 stays audit-ready without a fire drill.

Frequently Asked Questions

Does ID.RA-09 require cryptographic verification (hashes/signatures) for every piece of software?

The requirement is outcome-focused: assess authenticity and integrity prior to use (NIST CSWP 29). For many tools, signature or checksum validation is the cleanest evidence, but you can scale methods by risk tier and document why a given method is sufficient.

How do we apply this to SaaS where there is nothing to “install”?

Treat “use” as the moment you enable the service or integration. Capture evidence of provider identity verification, permission scope review, and the approval that allowed the connection prior to enablement (NIST CSWP 29).

What’s the minimum viable evidence set for auditors?

Auditors need traceability: a request record, tiering decision, approval, and proof of the authenticity/integrity check dated before acquisition or deployment. A checklist plus ticket attachments is often enough if it’s consistent and retrievable.

We buy hardware through distributors. How do we show authenticity?

Require documentation of the authorized reseller relationship where feasible, record distributor details on the purchase, and implement receiving controls (tamper checks, serial capture, quarantine). If the hardware is high-risk, require stronger validation steps before deployment.

How do we handle emergency patches or urgent tool buys?

Use a formal exception with defined compensating controls (restricted deployment scope, added monitoring, post-implementation verification) and a time-bound follow-up to complete missing checks. Keep exceptions rare and review them regularly.

Where does third-party risk management stop and ID.RA-09 start?

Third-party risk management evaluates the provider; ID.RA-09 also covers the specific hardware/software artifact entering your environment. You need both: supplier due diligence plus artifact-level controls in procurement and deployment workflows (NIST CSWP 29).