CA-8(1): Independent Penetration Testing Agent or Team

To meet the ca-8(1): independent penetration testing agent or team requirement, you must have penetration tests performed by testers who are demonstrably independent from the system’s development and day-to-day operation, and you must be able to prove that independence to assessors. Operationalize this by defining independence criteria, contracting an external qualified third party (or segregated internal team), scoping systems/components, and retaining test and remediation evidence. ¹

Key takeaways:

• Independence must be real and defensible: document org separation, conflicts checks, and procurement decisions.
• Treat independence as a control with recurring evidence, not a one-time pen test purchase.
• Auditors will look for proof that findings drove fixes, not just a report.

CA-8(1) is a narrow requirement with a high failure rate in audits because teams focus on “did we run a pen test?” and miss “was the tester independent?” The control enhancement is explicit: you must employ an independent penetration testing agent or team to test the system or its components. ¹

For a CCO, GRC lead, or compliance officer, the fastest path to compliance is to convert “independent” into procurement-ready, audit-ready criteria that your security team can execute without ambiguity. That means: define what independence means in your environment (reporting lines, access, incentives, conflict of interest), bake it into vendor selection and statements of work, and keep artifacts that show the testing was truly independent and that remediation was governed.

This page gives requirement-level implementation guidance you can hand to security leadership, internal audit, and procurement. It also covers the most common assessor hangups: internal teams that are “technically separate” but share leadership, consultants who helped build the system they test, and pen tests that cover a subset of components without a recorded rationale.

Requirement: CA-8(1) Independent Penetration Testing Agent or Team

Control intent: reduce bias and blind spots by ensuring the people attempting to break your system are not the same people who built, administer, or have incentives to defend it.

Regulatory anchor: NIST SP 800-53 Rev. 5 control enhancement CA-8(1). ²

Regulatory text

“Employ an independent penetration testing agent or team to perform penetration testing on the system or system components.” ¹

Operator translation: You must (1) run penetration testing and (2) ensure the testers are independent from the system being tested. “System or system components” means you can scope testing to the full system boundary or selected components, but you need a defensible scoping decision and evidence that independence exists for whatever is tested. ¹

Plain-English interpretation

Independence is about freedom from conflicts and organizational separation. A pen test performed by the same team that develops the application, administers the infrastructure, or owns the security tooling will not satisfy the spirit of CA-8(1) unless you can show meaningful separation (for example, a distinct internal red team with separate reporting and no build/run responsibilities for the target system).

A common assessor view: if the tester had a hand in designing, implementing, or operating the target, they may be grading their own work. You should be prepared to show:

• who performed the test,
• how they are independent,
• what was tested,
• what was found,
• what you fixed, and
• what you accepted as risk and why.

Who it applies to

CA-8(1) is typically applied in environments using NIST SP 800-53 as a control baseline, including:

• Federal information systems (agency-operated systems) ²
• Contractor systems handling federal data (for example, service providers supporting federal missions or processing federal information) ¹

Operational contexts where it matters most:

• Major application releases, new external attack surface, or architectural migrations (cloud, identity, network segmentation).
• High-impact systems or systems with sensitive federal data where assessor scrutiny is higher.
• Shared-service environments where “components” include identity providers, APIs, WAF/CDN, and CI/CD pipelines.

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

1) Define “independent” for your organization (write it down)

Create a short CA-8(1) procedure that sets minimum independence criteria. Keep it measurable. Example criteria you can adopt:

• Tester is not in the reporting chain of the system owner or delivery org.
• Tester did not design, implement, or operate the in-scope components within a defined lookback period (define the lookback in your policy as a local requirement).
• Tester is free from financial or performance incentives tied to the system’s delivery timeline or availability.
• Conflicts of interest are declared and reviewed before testing starts.

Deliverable: CA-8(1) implementation standard (1–2 pages) mapped to your system authorization boundary. Tie it to your assessment cadence via CA-8 (penetration testing) and your POA&M process.

2) Choose the execution model (external third party vs segregated internal team)

Use a simple decision matrix and record the outcome:

Option	When it works	What auditors will ask
External third-party pen test firm	Most common path; cleanest independence argument	Who selected them? Any prior build/operate work? Contract language?
Internal red team (organizationally separate)	Large orgs with mature security testing	Show org chart, separation of duties, and lack of operational responsibility

If you use an internal team, treat independence like segregation-of-duties: document reporting lines, role descriptions, and system access boundaries.

3) Scope “system or components” with an assessor-ready rationale

Define:

• in-scope assets (apps, APIs, cloud accounts/subscriptions, identity plane, critical services),
• out-of-scope items with rationale,
• test method (black/gray/white box),
• test constraints (maintenance windows, safe testing rules).

Avoid the “checkbox scope” mistake: a single web app test does not automatically cover your identity provider, admin interfaces, or CI/CD attack paths unless explicitly included.

Deliverable: Pen test scope document approved by system owner and security leadership.

4) Put independence into procurement and the statement of work

Your contract/SOW should state:

• the tester’s independence and conflict-of-interest obligations,
• deliverables (report, exec summary, reproduction steps, severity model),
• rules of engagement and legal authorization to test,
• retest expectations and evidence format.

Procurement needs one additional artifact: a conflict-of-interest attestation from the testing firm (and named testers if feasible).

5) Execute testing with controlled access and logging

Operational controls to run the engagement cleanly:

• Provide time-bound accounts or test credentials; log access provisioning and removal.
• Keep rules-of-engagement approvals (who authorized testing, on which targets).
• Ensure findings are handled through your vulnerability management and risk acceptance workflow.

6) Drive remediation and record closure decisions

A pen test report is not the endpoint. Examiners will trace:

• finding → ticket → fix → validation/retest or compensating control. For accepted risk, retain documented approval by an authorized risk owner and expiration or review trigger.

7) Map ownership and recurring evidence (make it audit-repeatable)

CA-8(1) often fails because it is “owned by nobody.” Assign:

• Control owner (GRC),
• Technical owner (security testing lead),
• System owner (authorizing official delegate),
• Procurement support (third-party engagement artifacts).

Daydream (or any GRC system) becomes useful here as the system of record to map CA-8(1) to an owner, procedure, and recurring evidence artifacts, then track completeness per system boundary. ¹

Required evidence and artifacts to retain

Keep evidence in a single audit folder per system (or per authorization boundary). Minimum set:

• CA-8(1) procedure/standard defining independence criteria and approval workflow.
• Engagement approval (email/thread/ticket) authorizing test targets and dates.
• Tester independence evidence, such as:
  • contract/SOW independence clause,
  • conflict-of-interest attestation,
  • org chart or reporting-line proof (for internal teams),
  • statement that testers did not build/operate the system.
• Scope and rules of engagement (targets, methods, constraints).
• Penetration test report (final) and, if issued, executive summary.
• Remediation tracking: tickets, change records, PRs, configuration changes.
• Retest/validation evidence or documented compensating controls.
• Risk acceptances with approvals and review triggers.

Common exam/audit questions and hangups

Expect these questions:

1. “Who performed the test and how are they independent?” Provide COI attestation and org separation artifacts.
2. “Did the tester help implement the system?” If yes, independence is questionable; document a different tester or additional independent retest.
3. “What exactly was tested?” Provide scoped targets and asset inventory mapping.
4. “What happened to the findings?” Show closure evidence and retest results.
5. “Was the test done on the system boundary or only a small component?” Provide rationale and risk assessment for component-only testing. ¹

Frequent implementation mistakes (and how to avoid them)

• Mistake: Hiring a consulting firm that also built the app.
  Fix: require COI disclosure; prohibit testers who performed build/run work for in-scope components.
• Mistake: Calling a vulnerability scan a pen test.
  Fix: ensure the engagement includes human-led exploitation attempts and documented methodology, then label artifacts correctly.
• Mistake: Internal team “independence” without proof.
  Fix: keep org charts, role descriptions, and access boundaries; show they do not operate the target environment.
• Mistake: No recorded authorization to test.
  Fix: store rules-of-engagement approvals and target lists alongside the report.
• Mistake: Findings closed without validation.
  Fix: require retest evidence for high-risk items or document compensating controls with owner approval.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for CA-8(1). The practical risk is still material: if independence is weak, you get lower-quality findings, repeat issues across releases, and poor assessor outcomes because you cannot substantiate CA-8(1) design and operating effectiveness. ¹

Practical 30/60/90-day execution plan

You asked for speed. Use phased execution without betting compliance on a single report.

Immediate

• Assign a CA-8(1) control owner and technical owner.
• Publish independence criteria and an approval checklist (one page).
• Identify which systems/components need independent testing first based on exposure and authorization timeline. ¹

Near-term

• Run procurement: select an independent third party (or formalize internal red team independence) and capture COI attestations.
• Finalize scope and rules of engagement; get system owner approval.
• Execute testing and ingest findings into vulnerability management with clear ownership.

Ongoing

• Track remediation through closure and retest/validation.
• Refresh evidence each cycle: independence proof, scope approvals, final reports, and closure records.
• In Daydream, keep CA-8(1) mapped to each system boundary with a recurring evidence request so you do not rebuild the audit binder every time. ¹

Frequently Asked Questions

Can our internal security team perform the penetration test and still meet CA-8(1)?

Yes, if you can prove the team is independent from the system’s development and operation. Keep org separation evidence (reporting lines, role descriptions) and document conflicts checks. ¹

Does “independent” require an external third party?

The requirement says “independent,” not “external.” External third parties are simpler to defend, but a segregated internal red team can qualify if independence is documented and real in practice. ¹

If the pen test firm also provides advisory services, is that a conflict?

It can be, depending on whether they designed, implemented, or operate the in-scope components. Require a conflict-of-interest disclosure and prohibit testing by individuals who performed build/run work on the target. ¹

Can we test only “system components” instead of the whole system?

Yes, but you need a scoping rationale that maps tested components to the system boundary and explains exclusions. Assessors will ask what risks remain for untested paths. ¹

What evidence is most likely to fail an audit if missing?

Independence proof (COI attestation or internal org separation) and remediation closure evidence are the most common gaps. A report alone rarely demonstrates operating effectiveness. ¹

How do we operationalize CA-8(1) across many systems without chaos?

Standardize the independence criteria, SOW language, and evidence checklist, then attach them to each system boundary as recurring tasks in your GRC workflow. Daydream is well-suited as the system of record for owners, procedures, and evidence artifacts tied to CA-8(1). ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5