CA-7: Continuous Monitoring

To meet the ca-7: continuous monitoring requirement, you must document a system-level continuous monitoring strategy and run ongoing monitoring activities that align to your organization-level continuous monitoring strategy, with repeatable collection of security signals, review, response, and retained evidence. The fastest path is to define the monitoring scope, assign control owners, set a monitoring cadence by risk, and prove operation through recurring artifacts.

Key takeaways:

• CA-7 requires a documented system-level strategy aligned to the organization-level strategy ¹.
• Auditors look for operational proof: recurring monitoring outputs, reviews, and remediation tracking, not a policy statement.
• Treat CA-7 as a program of record: defined scope, accountable owners, measurable outputs, and evidence retention mapped to controls.

CA-7 is where “security assessment” stops being a periodic event and becomes day-to-day operations. For a Compliance Officer, CCO, or GRC lead, the practical challenge is predictable: teams have logs, scans, alerts, tickets, and dashboards, but they cannot show a coherent strategy that ties those signals to control coverage, risk decisions, and documented follow-through.

The ca-7: continuous monitoring requirement is explicit about two things: you need a system-level continuous monitoring strategy, and you must implement monitoring in accordance with the organization-level strategy ¹. That means you cannot rely on generic enterprise monitoring language alone. Each system boundary needs its own monitoring plan that reflects its environment, data sensitivity, threat exposure, and dependencies (including third parties that materially affect the system).

This page gives requirement-level implementation guidance you can execute quickly: who must be involved, what decisions you must document, how to build a monitoring schedule that survives audits, and what evidence packages consistently satisfy assessors. Where helpful, it also notes how tools like Daydream typically fit: not as a replacement for monitoring systems, but as the control-to-evidence backbone that keeps CA-7 operable.

Regulatory text

Requirement excerpt: “Develop a system-level continuous monitoring strategy and implement continuous monitoring in accordance with the organization-level continuous monitoring strategy that includes:” ¹

Operator interpretation of the text

• “Develop a system-level … strategy” means you need a written, system-scoped plan. It must be more specific than a corporate policy. It should name the system boundary, control coverage, monitoring methods, frequency expectations, roles, and escalation paths.
• “Implement continuous monitoring” means you must operate the plan, not just publish it. Assessors will expect recurring outputs (alerts, reports, tickets, meeting notes, exceptions) that show you are monitoring, reviewing, and responding.
• “In accordance with the organization-level … strategy” means your system plan must align to enterprise expectations. If your org strategy defines categories of controls monitored centrally (for example, vulnerability management), your system strategy should reference that and clarify what is inherited versus system-specific ¹.

Primary sources: the NIST SP 800-53 Rev. 5 catalog and the Rev. 5 publication landing page ².

Plain-English interpretation (what CA-7 is really asking)

CA-7 asks: “Can you show, continuously, that this system stays in a known security state, and can you prove you notice and act when it drifts?” Your monitoring does not need to be “real-time for everything.” It does need to be risk-based, documented, repeatable, and evidenced.

Think in three layers:

1. Strategy (what and why): what you monitor and why it is sufficient for the system’s risk.
2. Operations (how): tools, reviews, and workflows that collect and triage signals.
3. Governance (prove it): decisions, exceptions, and remediation tracked to closure.

Who it applies to

CA-7 commonly applies to:

• Federal information systems that use NIST SP 800-53 as the control baseline ³.
• Contractor systems handling federal data where NIST 800-53 controls are flowed down contractually or required as part of an authorization approach ³.

Operationally, it applies to any system boundary you describe in your SSP or equivalent system documentation. It also applies to systems with material reliance on third parties (cloud providers, managed security service providers, SaaS platforms), because their controls and telemetry often feed your monitoring claims.

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

Use this sequence to operationalize CA-7 quickly and cleanly.

1) Confirm the authoritative organization-level monitoring strategy

• Identify the enterprise document that defines continuous monitoring expectations (often a policy, ISMS procedure, or continuous monitoring plan).
• Extract the parts that matter for implementation: required monitoring domains (vuln mgmt, configuration, logging), required reporting lines, and escalation rules.
• Decide what is centrally provided versus what each system must do locally.

Deliverable: a short “inheritance statement” that your system strategy will reference.

2) Define system scope and control coverage

• Document system boundary, environment(s), data types handled, and key dependencies.
• Map monitoring coverage to controls. Start with a pragmatic matrix:
  • Control area → signal source → owner → review workflow → evidence output
• Track shared responsibility boundaries (especially for cloud and third party services).

Practical tip: This is where many programs fail. They monitor a lot, but can’t show which control objectives those signals support. Daydream is often used here to map CA-7 to an owner, a procedure, and recurring evidence artifacts so the monitoring program stays audit-ready as staff and tools change ¹.

3) Build a risk-based monitoring schedule

For each monitoring domain, define:

• Event-driven checks (triggered by change, incident, new asset onboarding).
• Recurring checks (routine review of dashboards, scan outputs, access reviews).
• Continuous feeds (SIEM alerts, EDR detections) paired with human review and triage.

Document how you set frequency: higher-risk systems and externally exposed components get tighter review cycles; lower-risk inherits more from central monitoring.

Deliverable: a monitoring calendar plus “what good looks like” acceptance criteria for each review.

4) Specify tooling and data sources (with ownership)

List, by system:

• Security telemetry sources (logging platform, SIEM, EDR, vulnerability scanner, CSPM, CI/CD security, IAM audit logs).
• Who owns each tool and who reviews outputs.
• How findings become work (ticketing workflow, severity, SLA targets if your org defines them).
• How you handle tool gaps (compensating controls, manual reviews, documented exceptions).

5) Define triage, escalation, and remediation workflows

CA-7 becomes credible when you can prove action:

• Triage rules: what constitutes a finding vs noise.
• Escalation thresholds: when the system owner, IR team, or compliance must be notified.
• Remediation tracking: tickets with owner, due date, evidence of fix, closure approval.
• Exception handling: formal risk acceptance, time-bounded, with compensating monitoring.

6) Prove alignment to assessment and authorization activities

Tie CA-7 outputs to:

• Ongoing assessment plans (control testing results, POA&M updates).
• Change management (monitoring triggered by significant changes).
• Risk management (recurring risk reviews informed by monitoring).

Even if different teams run these motions, CA-7 expects a coherent system story.

Required evidence and artifacts to retain

Auditors typically accept multiple forms of evidence if it is consistent and repeatable. Build an “evidence package” per system that includes:

Strategy and governance

• System-level continuous monitoring strategy (dated, approved, versioned).
• Trace to organization-level strategy (reference and inheritance statement).
• RACI / ownership list for monitoring activities.

Operational monitoring outputs (recurring)

• Vulnerability scan summaries and remediation tickets.
• Configuration/compliance drift reports (as applicable).
• Logging/SIEM alert summaries with triage notes.
• EDR detections and incident linkage (if any).
• Meeting notes or review attestations for periodic monitoring reviews.

Remediation and exceptions

• Finding register (or ticket exports) with status and closure evidence.
• POA&M entries or equivalent remediation plan where used.
• Risk acceptances/exceptions with approvals and expiration.
• Third party attestations or monitoring reports where you inherit controls.

Evidence hygiene

• A retention rule (what you keep, where, and who can produce it).
• Immutable timestamps and access controls for evidence repositories.

Common exam/audit questions and hangups

Expect these questions, and pre-answer them in your artifacts:

1. “Show me your system-level continuous monitoring strategy.” They want a document, not a verbal description ¹.
2. “How does this align to the organization-level strategy?” Missing linkage is a frequent finding driver.
3. “What monitoring is continuous vs periodic vs event-driven?” You should be able to categorize and justify.
4. “Who reviews results, how often, and where is that recorded?” Tool screenshots alone rarely satisfy this.
5. “Pick a recent high-severity finding and walk me through end-to-end handling.” If you can’t demonstrate closure evidence, CA-7 looks weak.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	What to do instead
Treating CA-7 as “we have a SIEM”	Tools are not a strategy or process	Write the system strategy and tie signals to controls and owners
No evidence of human review	Continuous feeds without review are hard to defend	Add review checkpoints and retain review attestations
Monitoring exists, but isn’t mapped to control objectives	Assessors can’t confirm coverage	Maintain a control-to-signal matrix and update it on system changes
Findings tracked outside governance	Remediation work disappears in engineering backlogs	Force tickets into a traceable workflow with closure evidence
Third party dependencies ignored	Inherited controls become blind spots	Document shared responsibility and capture third party monitoring/attestations

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for CA-7. Practically, CA-7 failures tend to surface during audits, authorizations, and incident post-mortems as “you didn’t know you were out of compliance,” which then cascades into missed control operation, delayed detection, and weak remediation governance ³.

A practical 30/60/90-day execution plan

Use this as an operator’s rollout sequence. Adjust scope by system criticality and team capacity.

First 30 days (foundation)

• Name the CA-7 control owner and approver for each system.
• Collect existing monitoring inputs and document current-state telemetry sources.
• Draft the system-level continuous monitoring strategy aligned to the org strategy ¹.
• Build the control-to-signal matrix and identify top gaps (missing logs, missing scan coverage, unclear owners).
• Stand up an evidence repository and a simple evidence index (what, where, owner).

Days 31–60 (operationalize)

• Implement recurring reviews (security findings review, vuln remediation review, logging review) and record attendance/attestation.
• Normalize tickets: severity, routing, closure criteria, and exception path.
• Add monitoring triggers to change management (new internet-facing service, major config change, new third party integration).
• Run one internal “CA-7 walkthrough” audit: pick a finding and trace detection → triage → remediation → closure.

Days 61–90 (stabilize and scale)

• Tune signal quality (reduce false positives, refine alerting thresholds, adjust dashboards to control objectives).
• Integrate third party signals where inherited controls exist (attestations, reports, shared dashboards).
• Produce a management-ready continuous monitoring report that summarizes coverage, open items, and systemic issues for the system owner.
• In Daydream (or your GRC system), lock in the recurring evidence requests and owners so CA-7 stays alive through staff turnover ¹.

Frequently Asked Questions

Do I need “real-time” monitoring to satisfy ca-7: continuous monitoring requirement?

CA-7 requires a continuous monitoring strategy and implementation aligned to the org strategy, not a guarantee that every control is monitored in real time ¹. Define a risk-based mix of continuous feeds, periodic reviews, and event-driven checks, and retain evidence.

What’s the minimum acceptable CA-7 artifact set for an audit?

A system-level strategy, an ownership/RACI, a monitoring schedule, and recurring outputs that show review and remediation tracking usually form the core package ¹. Add exception approvals and closure evidence for sampled findings.

How do I handle inherited monitoring from a cloud provider or managed service?

Document which monitoring controls are inherited and what evidence you receive (reports, dashboards, attestations) versus what you run yourself. Your system strategy should explicitly describe the shared responsibility boundary and the review process for third party-provided outputs.

Our teams monitor a lot, but we don’t have a written strategy. Is that still noncompliant?

CA-7 explicitly requires development of a system-level continuous monitoring strategy ¹. Monitoring activity without the strategy usually fails an assessment because it can’t be shown as planned, complete, and governed.

Who should own CA-7: security operations, GRC, or the system owner?

The system owner typically owns the control outcome, while security operations owns many monitoring activities and GRC owns the evidence, governance, and assessment alignment. Put this in a RACI so auditors see accountability rather than informal expectations.

What’s the fastest way to make CA-7 sustainable across many systems?

Standardize the strategy template and the control-to-signal matrix, then automate recurring evidence collection and reminders in your GRC workflow. Many teams use Daydream to map CA-7 to an owner, implementation procedure, and recurring evidence artifacts so monitoring proof is consistent across systems ¹.

Footnotes

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

2. NIST SP 800-53 Rev. 5 OSCAL JSON; Source: NIST SP 800-53 Rev. 5

3. NIST SP 800-53 Rev. 5