AC-16(5): Attribute Displays on Objects to Be Output

AC-16(5) requires your system to display security and privacy attributes (for example, classification, sensitivity, handling caveats, or privacy markings) in a human-readable way on each object sent to an output device so recipients can identify what it is and how it must be handled. Operationalize it by standardizing which attributes must appear, where they appear on each output type, and by testing and retaining evidence across key output paths. ¹

Key takeaways:

• Define a mandatory “attribute display profile” per object type and output channel (print, PDF export, screen render, email, file transfer).
• Implement consistent, human-readable markings at render time (headers/footers/banners/cover sheets/metadata views), not just in back-end tags.
• Prove it works with repeatable tests and screenshots/spool samples tied to systems, releases, and configurations.

The ac-16(5): attribute displays on objects to be output requirement is easy to misunderstand because many teams already store labels in metadata and assume that satisfies the control. AC-16(5) is narrower and more operational: the attributes must be displayed in a human-readable form on each object the system transmits to output devices. That means the person receiving the output can immediately see the marking and handle the object appropriately, without needing privileged tooling to inspect hidden metadata. ¹

For a Compliance Officer, CCO, or GRC lead, the fast path is to treat this as an “output marking” requirement with clear scope boundaries: identify which object types and output channels are in scope; decide the minimum attribute set that must be displayed; and implement the markings consistently across applications, reporting pipelines, and print services. Your audit readiness depends less on policy language and more on demonstrable behavior: can an assessor trigger common outputs and observe the attributes displayed exactly as specified, across environments and user roles?

This page gives requirement-level implementation guidance you can hand to system owners and engineering teams, plus the evidence package you should retain for assessment.

Regulatory text

Control requirement (excerpt): “Display security and privacy attributes in human-readable form on each object that the system transmits to output devices to identify {{ insert: param, ac-16.05_odp.01 }} using {{ insert: param, ac-16.05_odp.02 }}.” ¹

Operator interpretation: Configure your system so that whenever it outputs an object (for example, a report, a generated PDF, an exported dataset, a print job, or a rendered document), it visibly displays the relevant security and privacy attributes. The purpose is identification at the point of use, not just enforcement through access controls. ¹

What the parameterized placeholders mean for you: The excerpt includes organization-defined parameters (ODPs). In practice, you must:

• Define which attributes must be displayed (the “identify …” portion).
• Define how/where they must be displayed (the “using …” portion), such as banners, headers/footers, cover pages, watermarks, UI ribbons, or print labels.
  Your assessor will expect those decisions to be documented and implemented consistently. ¹

Plain-English requirement interpretation

If your system creates or transmits something that can be viewed, printed, saved, or otherwise output, that output must carry visible markings that tell a human what the object is and how it must be handled. Hidden tags are helpful, but they do not satisfy the “human-readable display” requirement by themselves.

Common examples of “attributes” to display (you decide which apply based on your program and data):

• Data classification / sensitivity marking
• Distribution or handling caveats (internal, controlled, etc.)
• Privacy marking or category indicators
• Dataset owner or system-of-record identifier (if that is part of your defined attributes)

Who it applies to

Entity types: Federal information systems and contractor systems handling federal data, where NIST SP 800-53 is the control baseline or is flowed down contractually. ¹

Operational contexts where AC-16(5) shows up in audits:

• Systems that generate reports (financial, mission, security, HR, case management)
• Data platforms that export datasets (CSV, XLSX, JSON, bulk extract APIs)
• Document management systems and collaboration tools
• Print services and virtual print-to-PDF
• Email gateways or automated notification systems that attach files or embed report content

Typical control owners: Application owners, platform engineering, security architecture, and GRC. You need a single accountable owner for the attribute display standard, plus implementers for each output path.

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

1) Define scope: “object” and “output device” for your environment

Build a list of in-scope output paths:

• Rendered UI views (screens where a user views a record/report)
• Generated documents (PDFs, Word exports, print jobs)
• Data exports (CSV/XLSX, bulk downloads)
• Machine-to-machine outputs that still end up in user-visible form (scheduled reports emailed as attachments; files dropped to shared drives)

Keep it practical: start with the outputs that move data outside the originating application boundary (export, print, attachment, file transfer).

2) Establish your “Attribute Display Profile” (your ODP decisions)

Create a short standard that answers two questions:

• Which attributes must appear on each object type (e.g., “Classification” and “Privacy Handling”).
• How they must appear (e.g., top banner + footer; watermark; cover sheet; UI ribbon; filename prefix; first row of CSV as a comment line if your tooling supports it; an accompanying README if it does not).

Write it as an implementable matrix:

Output type	Where attribute appears	Minimum attribute set	Example
Web report page	Persistent header banner	Classification, handling caveat	“INTERNAL – Privacy Sensitive”
PDF report	Header + footer on every page	Same as web	Header/footer text
Print job	Header/footer + cover sheet (if needed)	Same as PDF	Cover sheet includes owner
CSV export	First line + export summary page	Classification + handling caveat	“# INTERNAL – handle per policy”
Email attachment	In-document + email subject prefix	Same as attachment	“(INTERNAL)” in subject

Your matrix is the anchor artifact auditors ask for because it shows you made the parameter choices explicitly. ¹

3) Implement markings at render time, not only at rest

Engineering tasks to assign:

• Add a labeling service/module that takes an object’s attribute values and produces the exact display string.
• Update templates for reports and documents to include those strings in required placements.
• Ensure the attribute is applied every time the object is generated, including scheduled jobs and background workers.
• Confirm role-based views do not accidentally suppress the label for privileged users (a common defect).

If your system already stores attributes, focus on the “last mile”: making them visible in the output format.

4) Handle edge cases explicitly

Document decisions for:

• Multi-object outputs (bundled PDFs, zip files, multi-tab spreadsheets): require marking per contained object or a cover page plus per-file naming convention.
• Downstream transformations (print-to-PDF, scanning, re-saving): require markings that survive transformation (header/footer/watermark survive better than sidecar metadata).
• Third-party output tools (BI tools, managed print): confirm templates and export settings preserve markings.

5) Test like an assessor

Create repeatable test cases:

• For each in-scope output type, generate an output using representative data and confirm the label appears in the required place.
• Include at least one test for “highest sensitivity” attributes you define, because formatting issues often appear with longer caveats.
• Record the exact configuration version/template version used.

6) Operationalize: governance + change control

Make it sustainable:

• Put the attribute display profile under change control.
• Require a check in release testing: “output markings present and correct.”
• Review new output features for labeling impact (new export button, new report engine, new print service).

Where Daydream fits naturally: Use Daydream to map AC-16(5) to a control owner, implementation procedure, and recurring evidence artifacts so evidence collection is not a scramble each assessment cycle. ¹

Required evidence and artifacts to retain

Assessors typically want “show me” evidence tied to a documented standard. Retain:

• Attribute Display Profile / ODP decision record (the matrix described above)
• System design notes showing where attributes are sourced and where they are rendered (architecture diagram or short design doc)
• Configuration and templates (report templates, document generation templates, BI export settings, print configurations)
• Test evidence: screenshots of UI banners; sample PDFs with headers/footers; print spool samples or print-to-PDF outputs; sample exports showing the marking mechanism
• Change records: tickets/PRs showing implementation and ongoing updates
• Control mapping: control owner, frequency of evidence refresh, and where evidence is stored (GRC system entry)

Common exam/audit questions and hangups

Expect these questions:

1. “Which attributes are displayed, and who decided that?” Show the ODP decision record and approval.
2. “Does every output path have a marking?” Auditors will click export buttons and try alternate report formats.
3. “Are markings human-readable without special tools?” Hidden metadata alone usually fails this.
4. “Do markings persist across pages and prints?” A first-page-only footer often triggers a finding.
5. “Is this consistent across environments?” Dev vs prod template drift is a common gap.

Frequent implementation mistakes and how to avoid them

• Mistake: Only tagging records in the database.
  Fix: Add render-time banners/headers/footers/watermarks for each output format.

• Mistake: Marking only the first page of a PDF.
  Fix: Apply headers/footers on every page or a watermark, based on your profile.

• Mistake: CSV/XLSX exports with no practical place to show labels.
  Fix: Define an export “summary sheet” or prefix comment line when supported, and standardize file naming conventions.

• Mistake: One application is compliant, but shared report tooling is not.
  Fix: Treat BI/report platforms as separate systems with their own output paths and evidence.

• Mistake: No durable evidence.
  Fix: Store dated samples and test cases per output type and refresh them on meaningful template/config changes.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. Treat AC-16(5) as an assessment-driven control: failures usually show up as audit findings because missing output markings increase the chance of mishandling, misrouting, or unauthorized redistribution of sensitive information. ¹

Practical 30/60/90-day execution plan

First 30 days (Immediate stabilization)

• Assign a control owner and name system owners for in-scope systems.
• Inventory output paths per system (UI, PDF, print, export, scheduled email).
• Draft the Attribute Display Profile matrix and get formal approval (security + privacy + data governance, as applicable).
• Pick one high-traffic system and implement the standard end-to-end as a reference pattern.

By 60 days (Broaden coverage + testing)

• Implement markings for remaining high-risk output paths (exports, print, email attachments).
• Build a test pack that reproduces outputs on demand and captures screenshots/samples.
• Put template/configuration items under change control; ensure releases include an “output marking check.”

By 90 days (Audit-ready operations)

• Complete coverage for remaining systems and edge cases (bundles, BI tools, shared services).
• Centralize evidence storage and update cadence (who captures what, when).
• Run an internal “assessor-style” walkthrough: generate each output type and verify markings match the profile.
• In Daydream, map AC-16(5) to the owner, procedure, and recurring artifacts so your next assessment is evidence-driven, not memory-driven.

Frequently Asked Questions

Does AC-16(5) require a specific set of attributes like “CUI” or “PII”?

AC-16(5) requires you to display the security and privacy attributes you define in your parameters. Document your chosen attribute set in an Attribute Display Profile and apply it consistently. ¹

Are hidden metadata tags in a PDF or file enough?

Usually no, because the requirement calls for “human-readable” display on the object transmitted to output devices. Keep metadata tags if they help, but add visible markings such as headers, footers, banners, or watermarks. ¹

What counts as an “output device” in practice?

Treat any destination where a user can view, save, print, or forward content as an output device or output channel, including printers, screens, and generated files. Scope it explicitly in your output path inventory so auditors see you made a reasoned boundary. ¹

How do we handle exports like CSV where headers/footers don’t exist?

Define a consistent mechanism in your profile, such as an initial comment line, an accompanying summary sheet (for XLSX), or a standardized README included in the export bundle. Then test that the mechanism is present on every export path you support.

Do we need to mark every page of a multi-page report?

Your profile should state the rule, but auditors commonly expect markings to remain visible throughout the object’s lifecycle and use. Headers/footers on each page or a watermark reduces the chance that separated pages lose context.

What evidence is most persuasive in an audit?

A concise profile matrix plus dated samples from each output type (screenshots, PDFs, export files) tied to the system and configuration version is hard to argue with. Pair that with change records showing the markings are maintained over time.

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON