SI-6(2): Automation Support for Distributed Testing

The si-6(2): automation support for distributed testing requirement is easy to misread as “buy a scanner.” Examiners and assessors usually expect more: automation that supports management of testing across a distributed enterprise where security and privacy functions must be validated repeatedly and consistently. The core operational problem is coordination. In distributed environments, teams run different tools, schedule tests inconsistently, store results in different places, and handle failures through informal channels. That breaks traceability and makes it hard to prove control operation.

SI-6(2) is a management-and-evidence requirement as much as a technical one. You need automated mechanisms that let you (1) define what tests must run, (2) push or schedule them across many systems/enclaves, (3) pull results back into a consistent record, and (4) manage exceptions and remediation. The strongest implementations treat testing as a governed service with clear ownership, standard workflows, and measurable outcomes, backed by artifacts that survive staff turnover and tool changes.

This page gives requirement-level guidance you can implement quickly: applicability, a step-by-step build, the evidence to retain, and the audit questions you should be ready to answer.

Regulatory text

Requirement (verbatim): “Implement automated mechanisms to support the management of distributed security and privacy function testing.” ¹

What the operator must do:
You must put automation in place that helps you manage (not merely perform) testing of security and privacy functions when that testing is distributed across multiple components, environments, or organizational units. “Manage” implies centralized visibility and control over test definition, scheduling, execution, results, and follow-up actions, even if the tests run in many places. ¹

Plain-English interpretation (what SI-6(2) is really asking)

If your environment is spread out, your testing can’t be a collection of local efforts that you “check in on” periodically. SI-6(2) expects automation that makes distributed testing run like a program:

• A defined set of tests for security and privacy functions (what “good” looks like).
• Automated triggers or schedules to run those tests across the fleet.
• Automated collection and normalization of results into a system of record.
• Workflow to route failures, track remediation, and capture retest outcomes.
• Governance for exceptions (missed tests, unreachable assets, compensating controls).

Think of it as: central policy, distributed execution, central evidence.

Who it applies to (entity and operational context)

Entity types: Federal information systems and contractor systems handling federal data. ¹

Operational contexts where SI-6(2) becomes a live requirement:

• Multiple enclaves, segmented networks, or multiple cloud accounts/subscriptions.
• Hybrid estates (on-prem plus cloud) with different admin domains.
• Decentralized operations (product teams own their stacks; central security owns oversight).
• Third-party hosted platforms where you must validate controls via attestation plus technical tests where possible.
• Privacy functions tested across systems (for example, data minimization checks, deletion workflows, access controls for personal data), where results must be centrally tracked.

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

Use this sequence to operationalize SI-6(2) without boiling the ocean.

1) Name the control owner and define “distributed testing” for your org

• Assign a single accountable owner (often Security Assurance, GRC, or a Testing/Validation lead).
• Define what counts as distributed for scope purposes: environments, business units, networks, cloud accounts, data centers, CI/CD pipelines, managed service boundaries.
• Set a RACI for: test authors, tool admins, system owners, privacy office input, and remediation owners.

Output: SI-6(2) control statement with scope and ownership.

2) Define the minimum test catalog (security + privacy functions)

Create a test catalog that answers: “What functions must we prove work?” Examples of test categories you can manage centrally:

• Security function tests: configuration compliance checks, vulnerability scanning, endpoint agent health checks, log forwarding validation, authentication/authorization checks, segmentation validation.
• Privacy function tests: access request workflow tests, data retention/deletion workflow tests, checks that sensitive data repositories have required controls.

Keep the catalog practical:

• For each test: intent, method/tool, execution frequency trigger (event-based is fine), target assets, pass/fail criteria, evidence produced, owner.

Output: Versioned test catalog in a controlled repository.

3) Build (or select) an automation “control plane” for testing management

SI-6(2) is satisfied by different architectures, but you need an automation layer that can:

• Orchestrate runs (scheduled and event-driven).
• Execute remotely or delegate execution to local agents.
• Collect results centrally (normalized enough to trend and audit).
• Open/track tickets or issues for failures.
• Preserve immutable logs of what ran, where, and with what outcome.

Common patterns:

• Security tooling plus a workflow system (scanner + ticketing + reporting).
• CI/CD-driven tests for application/security/privacy checks, with centralized pipeline logs.
• Endpoint/agent-driven checks that report to a central console.

Decision point: If tools are fragmented, implement an aggregation layer (SIEM/GRC evidence store/testing dashboard) that becomes the system of record for test runs and exceptions.

Output: Architecture diagram and toolchain description tied to SI-6(2).

4) Standardize execution and result handling across environments

Write a single operating procedure that answers:

• How tests are scheduled (calendar vs triggers like new build, new asset, configuration change).
• How assets are onboarded into scope (tagging/CMDB, cloud inventory, EDR enrollment).
• What happens when tests fail (severity mapping, ticket creation, SLA targets if you set them internally).
• What happens when tests can’t run (documented exception workflow).
• How retesting is performed and captured.

This is where automation matters most: failures must reliably create trackable work, not email threads.

Output: SI-6(2) SOP with workflow diagrams.

5) Implement exception governance for “distributed reality”

Distributed environments have unreachable segments, maintenance windows, and third-party constraints. Put structure around it:

• Define acceptable exception reasons (network isolation, system lifecycle, third-party restriction).
• Require compensating evidence (attestation, alternative test, or manual validation record).
• Time-bound exceptions with re-approval gates.
• Track exception inventory centrally.

Output: Exception register tied to test catalog entries and assets.

6) Prove ongoing operation with repeatable evidence production

Assessors look for sustained operation, not a one-time setup. Configure recurring exports or snapshots:

• Test run logs and reports.
• Coverage reports by asset group/system.
• Trend views (failures, remediation time, missed runs).
• Sampled tickets showing closure and retest.

If you use Daydream, map SI-6(2) directly to the control owner, implementation procedure, and recurring evidence artifacts so evidence collection is predictable during audits. ¹

Output: Evidence schedule and automated evidence capture process.

Required evidence and artifacts to retain

Store these in a location with controlled access and retention aligned to your audit needs:

1. Control design

• SI-6(2) control narrative (scope, definition of distributed testing, automation mechanisms).
• Testing management architecture diagram (systems, data flows, owners).
• Test catalog (versioned) with pass/fail criteria and evidence outputs.

2. Control operation

• Orchestration configuration (schedules, job definitions, pipeline configs).
• Sample test execution logs from different segments/environments.
• Central dashboard/report exports showing fleet coverage.
• Ticket/issue records for failures, with remediation and retest proof.
• Exception register with approvals and compensating controls.

3. Governance

• RACI and access lists for test management tools.
• Change records for test updates (who approved changes to test logic).

Common exam/audit questions and hangups

Expect these questions and prepare short, document-backed answers:

• “Show me how you manage testing across all environments.”
  Hangup: teams provide local scanner outputs with no central roll-up.

• “How do you know tests ran everywhere they should?”
  Hangup: no authoritative asset inventory mapped to test coverage.

• “What happens when a test fails?”
  Hangup: failures are not consistently ticketed or tracked to closure.

• “What do you do when tests can’t run?”
  Hangup: exceptions exist but lack approvals, expiration, or compensating steps.

• “How do you prevent drift in test definitions?”
  Hangup: test scripts changed without change control, making results non-comparable over time.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Treating “automation” as “we run a scanner.”
   Fix: demonstrate management automation, including scheduling, centralized results, and remediation workflows.

2. Mistake: No linkage between inventory and coverage.
   Fix: define the authoritative inventory source and map asset groups to required tests.

3. Mistake: Distributed ownership with no accountable operator.
   Fix: assign one program owner and require system owners to onboard assets and remediate.

4. Mistake: Exceptions are informal and permanent.
   Fix: implement time-bound exceptions with compensating controls and re-approval.

5. Mistake: Evidence is manual and fragile.
   Fix: automate exports/snapshots into an evidence repository; keep sample sets from multiple segments.

Enforcement context and risk implications

No public enforcement cases were provided for this requirement in the supplied source catalog, so you should treat SI-6(2) primarily as an assessment and authorization risk driver rather than a standalone enforcement headline.

Operationally, SI-6(2) failures tend to show up as:

• Inability to demonstrate consistent testing across enclaves or business units.
• Delayed detection of control failures in remote segments.
• Weak auditability because test results are scattered and non-standard.

These gaps increase the likelihood of adverse assessment outcomes, delayed ATO milestones, customer security findings, and contract friction for systems handling federal data.

Practical execution plan (30/60/90-day)

You asked for speed. Use this plan as an execution checklist, then adjust to your environment.

First 30 days (stabilize scope + ownership)

• Assign SI-6(2) control owner and publish RACI.
• Define “distributed” scope and identify in-scope environments.
• Draft the minimum viable test catalog (start with the tests you already run).
• Select the system of record for test results and exceptions (tooling you have is fine if it can centralize artifacts).
• Document the SI-6(2) procedure: scheduling, collection, failure workflow, exceptions.

Days 31–60 (implement automation and central visibility)

• Configure orchestration for the test catalog (schedules or triggers).
• Integrate results into a central repository/dashboard.
• Connect failures to ticketing with required fields (asset, test, timestamp, owner, evidence, retest requirement).
• Stand up exception workflow and register.
• Run a pilot across at least two distinct segments (for example, one cloud account and one on-prem enclave) and fix gaps.

Days 61–90 (prove repeatability + audit readiness)

• Expand coverage to remaining segments; close onboarding gaps.
• Establish recurring evidence exports and an evidence binder structure.
• Perform a tabletop “audit walk-through” using real artifacts: show coverage, failures, tickets, retests, and exceptions.
• Tighten change control for test definitions and automation configs.
• In Daydream, map SI-6(2) to the owner, procedure, and recurring evidence artifacts so you can generate an assessment-ready package on demand. ¹

Frequently Asked Questions

Does SI-6(2) require a specific testing tool?

No tool is mandated in the text. You need automated mechanisms that support management of distributed testing, which you can meet through an orchestrated toolchain that centralizes scheduling, results, and follow-up. ¹

What counts as “distributed” in practice?

Distributed usually means multiple administrative or network domains, multiple cloud accounts, segmented enclaves, or decentralized teams where tests run in different places. Define the boundaries in your SI-6(2) scope statement and tie them to your inventory sources.

How do we cover third-party hosted systems where we can’t run our own tests?

Track those systems in the same test catalog and exception workflow, then document alternate validation methods (for example, contractual attestations, reports, or provider evidence) as compensating measures. Keep approvals and renewal dates in the exception register.

Is CI/CD security testing part of SI-6(2)?

It can be, if you use automation to manage and record tests consistently across distributed pipelines and environments. Keep pipeline logs, job definitions, and centralized reporting as evidence of distributed execution and centralized management.

What evidence is most persuasive to an assessor?

A coverage view mapped to inventory, plus sampled artifacts that show the lifecycle: a test run, a failure result, a ticket, remediation, and retest closure. Pair that with a clear SOP and exception register.

How do we operationalize SI-6(2) without creating a reporting burden on engineering teams?

Build the burden into automation: results should flow into the system of record automatically, and tickets should be created from failures with minimal manual data entry. Keep the required fields tight and standardized.

Footnotes

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