SI-7(10): Protection of Boot Firmware

To meet the si-7(10): protection of boot firmware requirement, you must implement technical mechanisms that prevent, detect, and block unauthorized changes to boot firmware (UEFI/BIOS and related boot components) on the systems you specify in your control scope. Operationalize it by standardizing secure boot settings, controlling firmware updates, attesting boot integrity, and retaining proof of configuration and monitoring.

Key takeaways:

• Scope the assets first: endpoints, servers, and appliances where firmware integrity materially affects system trust.
• Enforce secure boot and signed firmware updates, then verify boot integrity through attestation or integrity checking.
• Keep assessment-ready evidence: baselines, config exports, update approvals, and monitoring/alert records.

SI-7(10) sits in the “System and Information Integrity” family, but it’s a platform security control in practice. If an attacker can modify boot firmware (UEFI/BIOS, option ROMs, boot loaders, or pre-OS components), they can undermine every control that runs after the operating system loads. That includes endpoint security tools, disk encryption, authentication agents, and logging.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat SI-7(10) as a requirements package with three outputs: (1) a clearly defined asset scope, (2) enforced configuration and change control for firmware, and (3) repeatable evidence that integrity protections are turned on and monitored.

This page translates the requirement into concrete operator steps you can assign to infrastructure and endpoint teams. It also calls out audit friction points: unclear scope, “enabled by default” assumptions, missing proof of enforcement, and gaps for remote staff or cloud-hosted hardware. The goal is simple: prove you can trust the boot process for in-scope systems and prove it on demand.

Regulatory text

Control excerpt (as published): “Implement the following mechanisms to protect the integrity of boot firmware in [organization-defined systems/components]: [organization-defined mechanisms].” ¹

What the operator must do:

1. Define the scope (which systems/components are covered).
2. Define the mechanisms you will use to protect boot firmware integrity.
3. Implement and operate those mechanisms with evidence that they are enforced and working.
   The control is intentionally parameterized, so assessors expect you to fill in the blanks with a defensible scope statement and a concrete technical implementation, then demonstrate ongoing operation. ²

Plain-English interpretation (what SI-7(10) is asking for)

You need to prevent unauthorized or unverified changes to firmware and boot-time code, and you need the ability to detect if it happens. In practice, that means:

• Systems boot only from trusted, approved code (secure boot chain).
• Firmware changes occur only through approved update processes (signed updates, admin control, change management).
• You can verify integrity (attestation, measured boot signals, or integrity checks) and investigate exceptions.

Who it applies to (entity and operational context)

Entity types most commonly in scope: federal information systems and contractors handling federal data, or any organization aligning to NIST SP 800-53 for security programs and authorizations. ²

Operational contexts where it matters most:

• Enterprise endpoints (laptops/desktops) where physical access risk exists (travel, remote work, shared spaces).
• Servers (on-prem and hosted) where firmware compromise can persist across reinstalls.
• Network/security appliances where firmware compromise can impact traffic inspection or access control.
• Privileged admin workstations and build systems where trust anchors are critical.

A common scoping approach is “all managed endpoints and servers that access, store, or process regulated data,” plus security infrastructure. Your risk assessment can justify exclusions (for example, truly immutable appliances), but assessors will expect a clear rationale and compensating controls.

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

Step 1: Set the scope and write the control “fill-ins”

Create a one-page SI-7(10) control statement that names:

• In-scope systems/components: endpoints, servers, appliances, virtual hosts as applicable.
• Mechanisms: secure boot configuration, firmware password protections, signed firmware updates, attestation/integrity monitoring, and update/change control.

This is the “contract” between GRC and engineering. Daydream is useful here because you can map SI-7(10) to a control owner, implementation procedure, and recurring evidence artifacts so the work stays operational instead of becoming a one-time document. ¹

Step 2: Establish a firmware integrity baseline (what “good” looks like)

Work with endpoint/server teams to define standard configurations:

• UEFI mode required; legacy boot disabled where feasible.
• Secure Boot enabled with approved keys (platform/OEM keys, enterprise keys if you manage them).
• Boot order locked (no external boot without admin authorization).
• Firmware admin password or equivalent control to reduce local tampering.
• TPM enabled where your integrity mechanism depends on it (for measured boot/attestation patterns).

Deliverable: a baseline standard per platform (Windows endpoints, Linux servers, hypervisors, etc.) plus a documented exception process.

Step 3: Control firmware updates like production code

Firmware is code. Treat it like code:

• Only allow updates from approved sources (OEM tools, enterprise management tooling).
• Require cryptographic signing verification where supported.
• Gate updates behind change control (ticket/approval) for servers and critical systems.
• For endpoints, allow automated deployment but still require: defined rollout rings, rollback plan, and version tracking.

Key point for audits: “We patch firmware” is not enough. You need to show the process prevents unauthorized firmware modification and records what changed.

Step 4: Implement boot integrity verification (detect and respond)

Choose one or more mechanisms appropriate to your environment:

• Secure Boot enforcement (prevents unsigned boot loaders/drivers).
• Measured boot / attestation using TPM-backed measurements reported to a management plane.
• Endpoint security platform checks that flag secure boot disabled, TPM disabled, or firmware anomalies.
• Configuration monitoring that detects drift in BIOS/UEFI settings.

Then connect it to operations:

• Alerts route to a monitored queue.
• Triage steps exist (is this a false positive, misconfig, or tamper?).
• Remediation paths are documented (re-enable secure boot, reflash firmware, isolate device, forensic review).

Step 5: Handle exceptions explicitly (or audits will)

You will have systems where secure boot/attestation is hard:

• Older hardware lacking modern UEFI features.
• Specialized OT/embedded gear.
• Cloud or hosted systems where firmware controls are abstracted.

For each exception, document:

• Why it cannot meet the baseline.
• What compensates (restricted access, enhanced monitoring, replacement plan, segmentation).
• Who approved it and when it will be revisited.

Step 6: Prove it continuously (not once)

Operationalize recurring evidence:

• Regular configuration exports/reports showing secure boot state and firmware settings compliance.
• A process to reconcile inventory vs. compliance reports (no “unknown” devices).
• Periodic review of firmware update logs and exception list.

Required evidence and artifacts to retain

Assessors typically want proof in three buckets: design, implementation, and operation.

Design artifacts

• SI-7(10) control statement with defined scope and defined mechanisms. ¹
• Firmware/boot security standard (baseline configuration) and exception process.

Implementation artifacts

• Configuration profiles (MDM, GPO, server management policies) that enforce secure boot/UEFI settings.
• Screenshots or exported settings from representative systems (better: automated compliance reports).
• Firmware update tooling configuration showing approved sources and signing validation where applicable.

Operational artifacts

• Firmware update/change records (tickets, approvals for critical systems).
• Monitoring alerts and incident tickets tied to boot integrity issues.
• Exception register with approvals and compensating controls.
• Inventory list of in-scope assets mapped to reporting coverage.

Common exam/audit questions and hangups

• “Which systems are in scope for SI-7(10)?” If you can’t answer in one sentence and produce an inventory slice, expect findings.
• “Show me secure boot is enforced, not just recommended.” Auditors look for policy enforcement and drift detection.
• “How do you prevent unauthorized firmware updates?” They want access controls plus update provenance (approved tooling, signed updates).
• “What happens when secure boot is disabled?” If your only answer is “we re-enable it,” you may be missing response rigor (isolation, investigation, root cause).
• “How do you handle cloud/hosted hardware?” You need a scoped statement: shared responsibility boundaries and what you can verify.

Frequent implementation mistakes (and how to avoid them)

1. Relying on OEM defaults. Defaults vary by model and can be changed locally. Fix: enforce via management tooling and monitor drift.
2. No written “organization-defined mechanisms.” SI-7(10) is parameterized. Fix: explicitly name mechanisms and map each to evidence. ¹
3. Treating firmware patching as the only control. Patching helps, but integrity controls also require secure boot chain and unauthorized-change prevention/detection.
4. Ignoring exceptions until audit week. Fix: keep an exception register and require approvals plus compensating controls.
5. No linkage to incident response. Fix: define a playbook for boot integrity failures (containment, re-image vs reflash, forensic triggers).

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat SI-7(10) primarily as an assessment and authorization expectation under NIST-aligned programs rather than a standalone enforcement driver. ²

Risk-wise, boot firmware compromise is a “trust anchor” failure: it can survive OS rebuilds and can subvert security tools. From a governance view, weak firmware controls also create a hard-to-detect persistence path that can undermine your broader integrity and monitoring controls.

Practical 30/60/90-day execution plan

First 30 days (Immediate)

• Assign a single accountable owner (Endpoint or Infrastructure) and a GRC co-owner for evidence.
• Write the SI-7(10) scope/mechanisms statement and get sign-off. ¹
• Inventory in-scope device classes and identify coverage gaps (unknown devices, unmanaged endpoints).
• Define baselines per platform: secure boot, UEFI settings, boot order controls, firmware password approach.

By 60 days (Near-term)

• Deploy enforcement for endpoints (MDM/GPO profiles) and servers (configuration management) where feasible.
• Stand up reporting: secure boot status and key firmware posture indicators.
• Implement firmware update governance for critical servers and security infrastructure (change records, approvals, version tracking).
• Create an exception register and route it through risk acceptance.

By 90 days (Operational)

• Turn on alerting and ticketing for integrity drift and secure boot disablement.
• Exercise the response playbook with at least one tabletop scenario (device found with secure boot off; suspected tamper).
• Formalize recurring evidence collection so you can produce it on demand (monthly posture export, exception review cadence).
• In Daydream, map SI-7(10) to the control owner, the implementation procedure, and the recurring evidence artifacts so audit prep becomes a routine pull, not a scramble. ¹

Frequently Asked Questions

What counts as “boot firmware” for SI-7(10)?

Treat UEFI/BIOS, option ROMs, and boot-time components that establish the chain of trust as in scope. If compromise would let an attacker persist before the OS loads, include it.

Do I have to implement TPM-based measured boot to satisfy SI-7(10)?

The control is parameterized, so you must implement your defined mechanisms. Many organizations satisfy the intent with secure boot enforcement plus monitoring; measured boot/attestation strengthens detection where available. ¹

How do we handle cloud servers where we can’t access firmware settings?

Document the shared responsibility boundary in your scope statement and implement the mechanisms you control (secure boot features exposed by the provider, hardened images, integrity monitoring, and strong access control). Keep the rationale and evidence that your defined scope matches what you can operate.

What evidence is strongest for auditors?

Automated posture reports showing secure boot enabled and configuration enforcement across the in-scope fleet are stronger than screenshots. Pair them with written baselines, change records for firmware updates on critical systems, and an exception register.

Is “we have a policy requiring secure boot” sufficient?

Policy alone rarely passes. You need enforcement (profiles/config management), monitoring for drift, and tickets showing you remediate exceptions.

How should we scope SI-7(10) if we have mixed legacy hardware?

Scope modern managed endpoints and servers first, then track legacy systems as exceptions with a replacement or containment plan. Auditors accept limitations when you document them and apply compensating controls.

Footnotes

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

2. NIST SP 800-53 Rev. 5