CA-9(1): Compliance Checks

CA-9(1): Compliance Checks requires you to verify each system component meets your security and privacy compliance baseline before you connect it internally to other components or segments. Operationalize it by gating “internal connection approval” on documented compliance checks (configuration, patching, hardening, privacy settings), and retaining evidence that the checks happened before the connection. ¹

Key takeaways:

• Treat internal connections as a controlled change that must pass a compliance-check gate before approval. ¹
• Define “constituent components” and “internal connection” for your environment, then standardize pre-connection checklists and evidence. ¹
• Audit success depends on timestamps and traceability: request/ticket → checks performed → approval → connection established. ¹

CA-9(1): compliance checks requirement is a “don’t connect first, validate later” control enhancement. It focuses on the moment risk spikes: when a new component is introduced to a trusted internal environment (a network segment, cluster, identity domain, or shared service plane). If that component is misconfigured, unpatched, or missing privacy protections, the connection can turn a local issue into a broader incident.

For most organizations, the fastest path to implementation is to embed CA-9(1) into your existing change management and access workflows. You are already provisioning servers, onboarding appliances, adding SaaS integrations, connecting VPCs/VNETs, joining endpoints to MDM, and peering networks. CA-9(1) says: before the internal connection is established, perform security and privacy compliance checks on the components you are connecting. ¹

This page gives you requirement-level guidance you can hand to engineering and operations: exact scope decisions to make, step-by-step execution, the artifacts auditors ask for, and a practical phased plan to get to “repeatable and provable.”

Regulatory text

Requirement (verbatim): “Perform security and privacy compliance checks on constituent system components prior to the establishment of the internal connection.” ¹

Operator meaning: Before you allow a component to connect to your internal environment, you must run and document checks that confirm it meets your defined security and privacy compliance expectations. The checks must occur before the connection is established, and you must be able to prove sequencing with records (for example, a change ticket timeline). ¹

Plain-English interpretation

• Constituent system components: the building blocks that make up your system, such as hosts, containers, network devices, hypervisors, endpoints, databases, identity components, and security tools.
• Internal connection: any action that materially increases trust or connectivity between components (network routing/peering, joining a domain, adding to a cluster, opening security group paths, connecting to shared storage, or enabling service-to-service credentials).
• Compliance checks: predefined validations against your baseline (secure configuration, patch levels, approved images, required agents, logging, encryption, privacy configuration, and policy conformance).

Your job is to define the baseline and enforce a gate: “no internal connection until checks pass and evidence is recorded.” ¹

Who it applies to

CA-9(1) is commonly applied in:

• Federal information systems and the organizations operating them. ¹
• Contractor systems handling federal data, including cloud and managed service environments supporting federal workloads. ¹

Operationally, it applies wherever teams connect components inside a boundary of trust, including:

• Cloud network connections (VPC/VNET peering, private endpoints, transit gateways)
• Data plane connections (app to database, service mesh enrollment)
• Identity and management plane connections (domain join, MDM enrollment, centralized logging onboarding)
• Hybrid connections (on-prem to cloud routing, VPN establishment, direct connect attachments)

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

Step 1: Set scope and definitions you will enforce

Write down, in one page, what counts as:

1. Constituent component (list common types in your environment)
2. Internal connection (list the connection events you will gate)
3. Compliance checks (list minimum checks and what “pass” means)

This prevents the classic audit failure: engineering believes “connection” means a physical cable, while audit means “any route or trust path.” ²

Step 2: Define the pre-connection compliance baseline (security + privacy)

Create a baseline checklist with required validations. Keep it small enough to run every time, but strict enough to matter. Typical items:

• Approved build source (gold image/approved base container)
• Patch/hotfix currency ¹
• Secure configuration benchmark applied (OS, container runtime, network device)
• Required security tooling present and reporting (EDR, vulnerability agent, config management)
• Logging/telemetry configured (system, auth, network as applicable)
• Encryption requirements met (at rest/in transit as applicable)
• Privacy checks: data minimization settings, logging redaction, access controls around personal data, retention defaults aligned to your privacy requirements

CA-9(1) does not tell you which checklist items to choose; it requires that you perform compliance checks before connection and can show evidence. ¹

Step 3: Implement a “connection approval gate” in operational workflows

Pick the mechanism that your teams already obey:

• Change management: “Internal connection” changes require a pre-implementation task: attach compliance check results.
• Infrastructure as Code (IaC) pipeline: block merges/deploys that create internal routes/peering unless an automated compliance job passes.
• Network/security approvals: firewall/security group requests require a compliance attestation for the connecting endpoints.
• Service onboarding: joining a cluster/service mesh requires an onboarding runbook with checks.

Minimum viable control design: a ticket type for internal connections that cannot be closed without a compliance-check artifact and approval. ¹

Step 4: Standardize how checks are performed (automated where possible)

Use a repeatable method per component type:

• Servers/VMs: configuration compliance scan + vulnerability scan + agent health check
• Containers/Kubernetes: image provenance checks + policy checks + admission controls validation
• Network devices: config diff against standard template + firmware/version check
• SaaS/third party integrations (where they become “components” in your system context): validate SSO/MFA, least-privilege scopes, logging, and privacy settings before enabling internal connectivity or data flows

Document which tools run which checks and where results are stored. Auditors do not need the tool brand; they need traceability and repeatability. ²

Step 5: Prove timing: checks happened before the connection

CA-9(1) is sequencing-sensitive. Build your evidence trail so it answers:

• When was the connection requested?
• When were checks run?
• Who reviewed results?
• When was the connection established?

Practical approach: require that the check output is time-stamped and attached to the same change record that authorizes the internal connection. ¹

Step 6: Define exceptions and compensating controls

You will have emergency changes and legacy components. Decide:

• Who can approve an exception
• What minimum checks still apply
• How quickly you must remediate to full compliance
• What monitoring is required until compliance is achieved

Keep exceptions rare, documented, and time-bounded by policy (your policy can specify the bound). ²

Required evidence and artifacts to retain

Auditors typically want “design + operating evidence.” Build a simple evidence set:

Design artifacts

• Control statement / procedure describing CA-9(1) gate, scope, and responsibilities ²
• Definitions of “internal connection” and “constituent component” for your environment
• Pre-connection compliance checklist(s) per component category
• Exception process and approval matrix

Operating artifacts ¹

• Change/request tickets for internal connections with timestamps
• Compliance check outputs (scan results, configuration reports, agent health screenshots/exports, policy evaluation results)
• Approval record (who approved, when, and what they reviewed)
• Implementation evidence (deployment logs, network change record, IaC commit ID)
• Post-connection validation (optional but helpful): confirmation of connectivity only after approval

If you want this to be assessment-ready, map CA-9(1) to a named owner, a written procedure, and a recurring evidence cadence in your GRC system. Daydream is often used here to keep the control-to-evidence mapping current and to prompt owners for clean, time-stamped artifacts that match audit sampling. ¹

Common exam/audit questions and hangups

Expect these questions and prep answers in advance:

1. “Define internal connection for this system boundary.”
   Have a diagram and a list of gated connection types.

2. “Show me three recent examples where checks happened before connection.”
   Have a curated evidence packet with ticket timelines and attachments.

3. “What about ephemeral assets (autoscaling, CI test runners)?”
   Show how your golden images, pipeline checks, or admission controls enforce compliance prior to joining internal networks.

4. “How do you handle exceptions?”
   Show exception approvals, rationale, and follow-up remediation records.

5. “Where are privacy compliance checks performed?”
   Point to privacy-specific settings checks (logging redaction, access scopes, retention defaults) embedded in the same gate. ¹

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Running checks after the connection “just to be safe”	Violates “prior to the establishment” sequencing	Put checks as a prerequisite in change/IaC workflows. 1
Treating this as a one-time assessment	New components get connected later without checks	Make the gate event-driven: every internal connection triggers checks. 2
No written definition of “internal connection”	Teams apply the control inconsistently	Publish a scoped list of connection events and owners.
Evidence scattered across tools with no traceability	Audits stall; you cannot prove ordering	Require a single “system of record” ticket with attachments and timestamps.
Privacy checks ignored	Control explicitly includes privacy	Add privacy items to the pre-connection checklist and require sign-off. 1

Enforcement context and risk implications

No public enforcement cases were provided in the source set for this requirement, so this page does not cite enforcement outcomes.

Operational risk still matters: connecting a noncompliant component expands attack paths, increases likelihood of lateral movement, and can expose personal data through misconfigured logging, access scopes, or unapproved data flows. CA-9(1) reduces that risk by forcing a compliance decision before trust is extended. ²

A practical 30/60/90-day execution plan

First 30 days: Stand up the gate (minimum viable)

• Assign a control owner and backup; document RACI for network, platform, security, and privacy.
• Define “internal connection” events you will control (start with the highest-risk paths).
• Publish a pre-connection checklist (security + privacy) and a single evidence location (change ticket template).
• Pilot with one infrastructure team and one application onboarding path. ¹

By 60 days: Make it repeatable and easier than workarounds

• Convert checklists into standard runbooks and, where possible, automated checks in CI/CD or provisioning.
• Add required fields/attachments to change tickets; block closure without evidence.
• Implement exception workflow with required approvers and required follow-up tasks.
• Start monthly spot checks: pick a sample of internal connections and verify ordering evidence exists. ²

By 90 days: Scale and harden for assessment readiness

• Expand scope to remaining connection types (cloud peering, shared services, identity joins, third party integrations in scope).
• Centralize evidence indexing in your GRC tool so you can answer audit sampling quickly.
• Add metrics that are not statistical claims: counts of connections reviewed, exception counts, and aging of exception remediation (track internally).
• Run a tabletop audit: can your team produce a clean evidence packet within a business day? ²

Frequently Asked Questions

What counts as an “internal connection” in CA-9(1)?

Treat it as any action that expands trust or connectivity between components inside your environment, such as routing/peering, domain joins, cluster membership, or opening internal network paths. Document your definition and gate those events with pre-connection checks. ¹

Do the compliance checks have to be automated?

No. The requirement is that checks are performed before connection and you can prove it. Automation improves consistency, but a documented manual checklist with time-stamped evidence can satisfy the requirement if it is consistently used. ¹

How do we handle autoscaling or ephemeral infrastructure?

Use compliant golden images, enforce pre-join checks in provisioning, and prevent noncompliant instances from joining internal networks or clusters. Your evidence can be pipeline logs, policy evaluation outputs, and image approval records tied to the connection event. ²

What privacy checks are expected here?

The control explicitly calls for privacy compliance checks, so include validations relevant to your environment: access scopes, logging content controls, retention defaults, and configuration that prevents unintended collection or exposure of personal data. Record those checks alongside security checks in the same gate. ¹

What’s the single most common audit failure for CA-9(1)?

Inability to prove sequencing. Teams often have scan results, but cannot show they occurred before the internal connection. Fix it with a single change record that includes timestamps, attachments, and approval before implementation. ¹

How should we document CA-9(1) ownership and evidence?

Map the requirement to a named control owner, a written procedure, and a defined set of recurring artifacts (tickets, scan outputs, approvals). Many teams manage this mapping and evidence prompts in Daydream to keep the control audit-ready without chasing screenshots during fieldwork. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5