SR-9: Tamper Resistance and Detection

SR-9 requires you to run a tamper protection program for each in-scope system, component, or service: prevent unauthorized physical or logical modification, detect tampering quickly, and respond with controlled investigation and recovery steps. To operationalize it, define tamper scenarios, implement anti-tamper controls, instrument detection, and retain evidence that the program runs continuously. ¹

Key takeaways:

• SR-9 is a program requirement: defined scope, documented procedures, implemented controls, and recurring evidence. ¹
• Cover both resistance (make tampering hard) and detection (know when it happened) across hardware, firmware, software, and services. ²
• Your fastest audit win is a control-to-evidence map with owners, procedures, and repeatable artifacts. ¹

The sr-9: tamper resistance and detection requirement is easy to misunderstand because the control text is short, but the operational scope is broad. It applies to systems, components, and services, which means you must think beyond “data center locks” and include endpoints, network devices, cloud workloads, CI/CD pipelines, images, firmware, and third-party managed services that form part of your system boundary. The requirement is to implement a tamper protection program, not a single control. Program language drives examiner expectations: assigned accountability, defined “tamper” conditions, layered protections, detection and alerting, and an operational response loop that produces evidence.

For a CCO or GRC lead, the practical objective is assessment-ready proof that (1) you identified tamper paths that matter for your mission, (2) you implemented protections proportionate to those paths, and (3) you can detect and respond to tampering in time to contain impact. SR-9 also tends to fail for mundane reasons: unclear ownership between facilities and security teams, incomplete coverage of cloud-managed components, and missing evidence that controls are operating rather than merely documented. ¹

Regulatory text

Requirement (verbatim): “Implement a tamper protection program for the system, system component, or system service.” ¹

Operator interpretation of what you must do:

• Implement a “program,” not a point solution. You need defined scope, roles, procedures, and recurring execution. ¹
• Cover the whole stack: “system, system component, or system service” means physical devices, firmware, software supply chain touchpoints, and externally provided services within your authorization boundary. ²
• Address both outcomes: tamper resistance (prevent/impede) and tamper detection (identify quickly and reliably), plus response handling to preserve integrity and evidence. ²

Plain-English interpretation (what SR-9 is asking for)

You must make it hard for someone to modify critical technology without authorization, and you must be able to tell when it happened. “Tampering” includes:

• Physical access that enables component swaps, port access, or device implants.
• Firmware/boot manipulation (bootloader changes, unauthorized BIOS/UEFI changes).
• Unauthorized changes to system images, configurations, code, pipelines, or deployment artifacts.
• Third-party service or admin actions that alter security posture or integrity of workloads.

A good SR-9 program assumes tampering will be attempted at the most operationally convenient points: during shipping/receiving, at remote sites, via privileged access, through CI/CD, or via management planes.

Who it applies to (entity + operational context)

Entities: Federal information systems and contractor systems handling federal data. ²

Operational contexts where SR-9 is commonly tested:

• Enterprise IT: endpoints, servers, network appliances, identity systems, logging infrastructure.
• Cloud: IaaS/PaaS control planes, Kubernetes clusters, images, secrets stores, serverless deployments.
• OT/IoT: field devices, gateways, sensors, embedded firmware.
• Third party dependencies: managed security services, colocation, cloud providers, hardware suppliers, software publishers (within your system boundary and shared responsibility model).

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

1) Define scope and ownership (make it auditable)

1. Create an SR-9 control record with a single accountable owner (by role) and named supporting teams (SecOps, IT Ops, Facilities, Cloud Platform, Product Engineering).
2. List in-scope assets where tampering would create unacceptable integrity or availability impact (prioritize: identity, key management, logging, boundary devices, build systems, golden images, critical endpoints).
3. Set “tamper definitions” per asset class (what events count as tamper, what signals indicate it, what response is required).
4. Map SR-9 to evidence artifacts you will produce on a recurring basis (see “Required evidence” section). ¹

Deliverable you want early: a one-page SR-9 “control-to-operations” sheet that an auditor can follow without extra meetings.

2) Implement tamper resistance controls (prevention/impedance)

Choose controls that match how the asset can be tampered with:

Physical/device layer

• Controlled access to network closets, racks, and secure storage.
• Tamper-evident seals for field-deployed equipment (where appropriate).
• Secure receiving and chain-of-custody steps for sensitive devices (especially replacements/RMAs).
• Port protections (disable unused ports, restrict console access, lock down boot media access).

Platform/firmware layer

• Secure boot and measured boot where available.
• Firmware update governance: signed updates only; restrict who can push firmware; log update actions.
• Baseline configuration for BIOS/UEFI settings with change control and monitoring.

OS/app/config layer

• Configuration management with drift detection for critical configurations.
• File integrity monitoring (FIM) for sensitive paths (configs, binaries, security agents, logging agents).
• Hardening of privileged access (MFA, least privilege, break-glass controls with logging).

Build/deploy layer (often missed)

• Protect CI/CD runners and build agents from unauthorized modification.
• Signing for artifacts (images/packages) and enforcement of signature verification at deploy time.
• Immutable infrastructure patterns where feasible: redeploy from trusted images rather than patching in place.

3) Implement tamper detection and alerting (prove you can know)

Detection must be measurable and evidenced. Build it around:

• Integrity signals: secure boot/measured boot logs, FIM alerts, package signature verification failures, configuration drift alerts.
• Privileged action signals: admin actions in cloud control planes, device management consoles, PAM session logs.
• Physical signals: badge access logs for sensitive rooms, camera coverage (where used), receiving logs for device custody.

Operationalize with:

• Alert routing to a monitored queue (SIEM/SOAR/ticketing).
• Triage procedures defining what is “suspected tamper” vs routine change.
• Containment actions (isolate endpoint, revoke credentials, quarantine image, pause pipeline).
• Forensic preservation steps appropriate to your environment (snapshots, log preservation, device hold).

4) Response playbooks and decision matrix (so teams act consistently)

Create a short matrix that your on-call staff can use:

Scenario	Example signal	Immediate action	Evidence to preserve	Escalate to
Physical device tamper suspected	Seal broken, unexpected console session	Remove from service; replace with known-good	Photos, chain-of-custody, access logs	Security + Facilities
Workload/image tamper suspected	Image hash mismatch; unsigned artifact	Block deploy; roll back; isolate cluster	Build logs, artifact registry logs, commit IDs	Cloud Sec + Eng
Config drift on critical control	Logging agent disabled	Re-enable from baseline; open incident	Drift report, change ticket check	SecOps

5) Make it assessable: evidence cadence and reviews

• Establish a recurring control check: review tamper alerts, exceptions, and asset coverage changes.
• Track exceptions/risk acceptances (e.g., legacy devices without secure boot) with compensating controls and planned remediation.
• Ensure third parties in scope have clear responsibilities and evidence-sharing expectations (contract language or operational runbooks).

Daydream fit (earned, not forced): teams most often stumble on SR-9 because evidence is scattered across Facilities, IT, Cloud, and Engineering. Daydream can act as the system of record for the SR-9 control map (owner, procedure, evidence list) and can keep recurring artifacts attached to the requirement so audit prep is a retrieval task, not a scramble. ¹

Required evidence and artifacts to retain

Retain artifacts that prove design and operation:

Governance / program

• SR-9 policy or standard (tamper protection scope, definitions, roles).
• SR-9 procedure/runbook (prevention controls, detection sources, response steps).
• Asset scope list with tamper-critical designation and owner.

Operational / technical

• Samples of integrity monitoring outputs (FIM reports, drift detection reports, secure boot logs where applicable).
• SIEM/SOAR alert records for suspected tamper events (or test alerts) and associated tickets.
• Change management records tying approved changes to observed configuration changes.
• Privileged access logs (PAM session records, cloud admin audit logs) for relevant events.
• Chain-of-custody records for sensitive hardware (receiving, storage, disposal where applicable).

Assurance

• Evidence of periodic review: meeting notes, control attestations, exception review decisions.
• Test results from tabletop exercises for tamper scenarios (at least for highest-risk assets).

Common exam/audit questions and hangups

1. “Show me your tamper protection program.” Auditors usually want a single narrative with links to evidence, not a pile of tools.
2. “What is your definition of tamper for cloud services?” Many programs stop at physical tamper and miss control-plane tamper.
3. “Which assets are covered, and why?” If you cannot explain prioritization, coverage looks accidental.
4. “How do you detect unauthorized changes, and who reviews alerts?” Detection without an owned queue and triage steps fails operationally.
5. “How do you handle exceptions?” Unsupported legacy devices are common; unmanaged exceptions are a red flag.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Treating SR-9 as only Facilities work. Fix: include CI/CD, images, registries, and admin planes in scope for integrity threats.
• Mistake: No evidence trail. Fix: define your recurring artifacts up front (reports, tickets, logs) and store them centrally by requirement. ¹
• Mistake: Alert fatigue equals silent noncompliance. Fix: tune tamper detections to high-signal areas first (golden images, identity systems, logging pipeline).
• Mistake: No chain-of-custody for field devices. Fix: simple receiving checklist plus “do not redeploy until verified” rules.
• Mistake: Third-party managed services assumed out-of-scope. Fix: document shared responsibility and require audit logs and integrity assurances for in-boundary services.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for SR-9. The practical risk is still direct: undetected tampering undermines integrity controls, can invalidate logs as evidence, and can turn a contained incident into a systemic compromise. For federal systems and contractors, SR-9 gaps also create assessment findings that can delay authorization outcomes or require compensating controls. ²

A practical 30/60/90-day execution plan

First 30 days (establish the program spine)

• Assign SR-9 owner and supporting roles; document RACI.
• Define “tamper” per asset class and draft the SR-9 procedure.
• Build the initial asset scope list and identify the top tamper-critical assets.
• Create the SR-9 evidence map: what you will capture, where it lives, and who produces it. ¹

By 60 days (deploy detection on what matters most)

• Implement or confirm integrity monitoring and drift detection for the tamper-critical asset set.
• Route tamper-related signals into a monitored queue with ticketing.
• Publish response playbooks and run a tabletop on a high-risk tamper scenario.
• Start exception tracking for gaps (legacy devices, constrained environments) with compensating controls.

By 90 days (make it repeatable and auditable)

• Expand coverage to the next asset tier (broader endpoints, network segments, additional cloud services).
• Tune alerts and document thresholds/escalations based on real noise levels.
• Complete at least one evidence cycle: reports generated, alerts triaged, review meeting held, exceptions updated.
• Centralize artifacts by requirement in your GRC system so audits become export-and-explain, not recollect-and-rebuild.

Frequently Asked Questions

What counts as “tampering” in a cloud-first environment?

Treat unauthorized changes to images, infrastructure-as-code, CI/CD pipelines, secrets, and control-plane configurations as tampering. Document the signals you use to detect these changes and the response steps you take. ²

Do I need tamper-evident seals on all hardware?

No universal rule fits every environment. Use seals where physical access risk is credible and where breakage is a meaningful signal; document your rationale and use other controls (access logs, secure boot, monitoring) where seals add little value. ²

How do we prove SR-9 is operating, not just documented?

Keep time-bound artifacts: integrity/drift reports, alert tickets, review records, and exception decisions. An auditor should be able to trace a tamper signal from detection to triage to closure. ¹

What if a third party manages the system component?

If the service is in scope for your system boundary, document shared responsibility and require the right evidence (audit logs, change records, integrity attestations) in the contract or operating procedures. Keep those artifacts tied to SR-9 for assessments. ²

We have legacy devices that cannot support secure boot or integrity agents. How do we handle that?

Record an exception with compensating controls such as stricter physical access control, tighter network segmentation, and enhanced monitoring of management access. Track a plan to replace or upgrade the device class and review exceptions regularly. ²

What’s the fastest way to get audit-ready for SR-9?

Build the SR-9 control-to-evidence map first, then backfill the minimum viable detection and response evidence for your tamper-critical assets. Centralizing evidence in a GRC workflow tool like Daydream reduces the last-minute evidence chase. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5