CM-7(9): Prohibiting The Use of Unauthorized Hardware

“Unauthorized hardware” is rarely a single problem. It shows up as personal USB storage, rogue Wi‑Fi access points, unapproved IoT gear in offices, contractor laptops plugged into production networks, or replacement components added during urgent repairs. CM-7(9) is the control enhancement that forces you to stop debating edge cases and run a consistent rule: hardware must be explicitly approved before it can connect, enumerate, or function in your environment.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to translate CM-7(9) into three operator-friendly outcomes: (1) you know what hardware is present, (2) you can distinguish authorized from unauthorized, and (3) you can technically prevent unauthorized devices from working, with a documented exception path. Your assessment success depends less on the wording of the policy and more on whether you can produce evidence that the blocking and response process runs the same way every time.

This page focuses on requirement-level implementation for cm-7(9): prohibiting the use of unauthorized hardware requirement, with concrete steps, evidence lists, and audit-ready talking points tied back to NIST SP 800-53 Rev. 5. ¹

Regulatory text

Control excerpt: “Identify {{ insert: param, cm-07.09_odp.01 }};” ²

What the operator must do with this text

The excerpt is parameterized in the catalog, but the operational expectation is stable: you must identify unauthorized hardware in your environment and run the program so unauthorized hardware cannot be used (connected, recognized, or functionally active) without explicit authorization. For most organizations, “identify” must be backed by (a) a known-good inventory/allowlist and (b) discovery/detection that finds deviations quickly enough to stop use, not just record it. ³

Plain-English interpretation

CM-7(9) means: Only approved hardware is allowed to connect to or operate on your systems. If a device is not approved, it must be blocked automatically or removed promptly under a defined process. You also need to prove the control works in practice, not just on paper. ¹

Who it applies to

Entity scope

• Federal information systems and contractor systems handling federal data that have adopted NIST SP 800-53 controls, including environments supporting federal contracts and regulated programs that inherit or map to 800-53. ¹

Operational scope (what environments)

Apply CM-7(9) wherever hardware can be introduced:

• End-user endpoints (laptops, desktops, VDI thin clients)
• Servers and infrastructure (on-prem, colocation, lab)
• Network edges (switch ports, wireless, VPN concentrators, NAC)
• Physical sites (conference rooms, kiosks, manufacturing floors)
• Third-party touchpoints (managed services, field support, contractors)

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

Step 1: Define “unauthorized hardware” in one page

Create a tight definition that operators can apply without debate:

• Authorized hardware: devices or components that are recorded in the approved inventory/allowlist, have an owner, a business purpose, and an approved connection method.
• Unauthorized hardware: anything not on the allowlist, anything that bypasses standard onboarding, or anything explicitly prohibited (for example, consumer storage media).
• Hardware categories to cover: removable media, peripheral devices, network devices (including rogue APs), compute devices, IoT/smart devices, and replacement components.

Deliverable: “Unauthorized Hardware Standard” (policy/standard) that names the system(s) of record and who approves exceptions.

Step 2: Assign control ownership and an operating cadence

CM-7(9) breaks down unless it has a real owner:

• Control owner: typically Endpoint Engineering or Security Engineering.
• Process owners: IT Service Management (exceptions), Network team (NAC), SOC (detections).
• GRC role: define evidence expectations and run periodic control check-ins.

Practical tip: Put the evidence artifacts on a recurring schedule so you can answer audits without a scramble.

Step 3: Establish an allowlist and an inventory you trust

You need two views:

• Approved allowlist (what is allowed): device identifiers, models, serial numbers where feasible, corporate asset tag, owner, location, approval date, and allowed connection types.
• Observed inventory (what is present): what your tools see connected or enumerated.

Reconcile them. The gap between “approved” and “observed” is your unauthorized hardware population.

Step 4: Put technical blocks in place (default-deny where possible)

Auditors will look for more than detection. Prioritize controls that prevent use:

Endpoint controls

• Device control policies to block USB mass storage by default, with scoped exceptions.
• Driver and peripheral restrictions for high-risk device classes.
• Endpoint agent-based discovery of newly connected hardware and automatic quarantine actions.

Network controls

• Network Access Control (NAC) or equivalent to restrict unknown MAC addresses and enforce device posture.
• Switch port security and wireless controls to prevent rogue infrastructure.
• Segmentation for environments where hardware introduction is likely (labs, conference rooms, OT-like spaces).

Data center / server room

• Physical access gates and maintenance procedures to ensure component swaps are authorized and recorded.
• “No ad hoc” policy for KVMs, removable media, and out-of-band modems.

Decision rule to document: which environments are “block by default” vs “detect and respond,” and why.

Step 5: Create a fast exception workflow that does not become a loophole

You will need exceptions. Make them controlled:

• Request requires business justification, device identifiers, data access scope, and end date.
• Security review checks: malware scanning, encryption requirements, logging enabled, and least-privilege connectivity.
• Approval authority: named role(s), not a shared mailbox.
• Expiration and re-approval: exceptions must end or be renewed with updated risk acceptance.

Output: a ticket type in your ITSM tool with required fields and an approval record.

Step 6: Monitoring, response, and removal (what “identify” looks like)

Define what happens when unauthorized hardware is detected:

1. Alert created (endpoint or network detection).
2. Triage within your SOC/IT workflow.
3. Containment action (block, isolate, disable port, remove device).
4. Root cause (why it was connected; training gap, missing process, malicious attempt).
5. Corrective action (policy update, technical control tightening, disciplinary process if needed).
6. Closure evidence (screenshots/logs + ticket notes).

Make sure the process includes third parties: contractors and on-site support must follow the same rules.

Step 7: Map CM-7(9) to owners, procedures, and recurring evidence

This is the easiest compliance win and the most common gap. Maintain a simple control sheet that ties:

• requirement → control owner → tooling → procedure → evidence → review frequency.

If you use Daydream, this mapping becomes a living control record with evidence prompts so teams attach the same artifacts every cycle and you can answer assessor questions quickly without rewriting narratives.

Required evidence and artifacts to retain

Keep evidence that shows both design (you planned it) and operation (it ran):

Governance

• Unauthorized Hardware Policy/Standard (approved, versioned)
• Roles and responsibilities (RACI or equivalent)
• Exception procedure and risk acceptance template

Technical configuration evidence

• Device control policy exports (endpoint management screenshots/exports)
• NAC / port security configurations (high-level settings + enforcement mode)
• Allowed hardware lists (export with timestamps)

Operational evidence

• Hardware discovery reports showing connected devices over time
• Samples of alerts for unauthorized devices and their disposition
• Incident/ticket records showing containment and removal actions
• Exception tickets with approvals and expiration handling
• Training/communications for staff and third parties (where hardware rules are communicated)

Audit packaging tip

Prepare a short “evidence index” that points an auditor to: policy, allowlist, a discovery report, and three closed cases (one benign mistake, one exception, one forced removal).

Common exam/audit questions and hangups

Assessors tend to push on these areas ¹:

• Definition clarity: “What counts as unauthorized hardware here?”
• Default deny: “Do you block, or only detect?”
• Coverage: “Does this apply to laptops, servers, conference rooms, and third parties?”
• Allowlist integrity: “Who updates it, and how do you prevent stale approvals?”
• Exceptions: “Show me an exception and prove it expired or was reapproved.”
• Evidence freshness: “Show recent proof the control operated, not last year’s screenshots.”

Frequent implementation mistakes and how to avoid them

1. Relying on policy alone. Fix: pair policy with enforced endpoint and network controls plus ticketed response.
2. Allowlist exists but no owner. Fix: name an accountable role and require monthly reconciliation between observed and approved.
3. Exceptions become permanent. Fix: enforce expirations in ITSM and require reapproval with updated justification.
4. Ignoring “weird” areas. Fix: explicitly cover conference rooms, labs, printers, IoT, and contractor gear in scope statements and monitoring.
5. No evidence trail for removals. Fix: require tickets for each unauthorized device event with before/after proof (blocked, port disabled, device removed).

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this specific enhancement. Practically, CM-7(9) failure shows up as an incident driver: unmanaged devices can introduce malware, create covert network paths, or enable data exfiltration through removable media. Your risk narrative should tie unauthorized hardware controls to preventing unauthorized access paths and reducing uncertainty in asset and configuration management. ¹

Practical 30/60/90-day execution plan

First 30 days (Immediate)

• Publish the one-page definition of authorized vs unauthorized hardware and prohibited categories.
• Assign control and process owners; confirm tooling owners for endpoint and network enforcement.
• Build a first-pass allowlist/inventory baseline from existing asset management + endpoint management exports.
• Turn on discovery reporting (even if enforcement starts in monitor mode).

By 60 days (Near-term)

• Implement endpoint device control rules for the highest-risk categories (commonly removable storage).
• Implement network controls for unknown devices in at least one high-value segment (pilot).
• Launch the exception workflow in ITSM with required fields and an approval chain.
• Run your first reconciliation: observed vs authorized, then remediate top findings with tickets.

By 90 days (Stabilize and prove operation)

• Expand enforcement coverage to remaining segments and user groups based on pilot results.
• Produce an audit packet: policy, allowlist export, discovery report, and several closed unauthorized-hardware cases.
• Add KPIs to governance: volume of detections, time to containment, exception aging, and recurring root causes (qualitative is fine if you lack mature metrics).
• Formalize recurring evidence collection in your GRC system so the same artifacts are captured each cycle.

Frequently Asked Questions

Does CM-7(9) require blocking all USB devices?

CM-7(9) requires prohibiting unauthorized hardware, which often leads to blocking high-risk device classes by default and allowing only approved devices. If you allow USB peripherals, document the allowlist and the exception path, and show enforcement evidence. ¹

How do we handle third-party technicians who need to connect diagnostic gear?

Treat third-party equipment as hardware that must be authorized before use, with a time-bound exception and documented approvals. Require supervision, segmentation, and a ticket that captures device identifiers and removal confirmation.

What’s the minimum evidence an auditor will accept?

Expect to provide a policy/standard, proof of an allowlist, proof of technical enforcement or blocking, and a few real tickets showing unauthorized hardware detection and remediation. Keep exports/screenshots time-stamped and tied to the in-scope system boundary. ¹

We can detect rogue devices but can’t block them everywhere. Is that a fail?

It depends on your risk decision and system context, but you should be ready to justify why blocking is not feasible and show compensating controls plus rapid response and removal. Document the decision explicitly and show consistent operations.

How do we define “authorized” if we don’t have good asset management?

Start with an interim allowlist sourced from endpoint management and network records, assign owners, and reconcile regularly until asset management is reliable. Auditors usually accept a phased maturity path if you can show controls operate and gaps are actively reduced.

How should we document CM-7(9) in our control library?

Map the requirement to a named owner, specific technical safeguards (endpoint control, NAC/port security, discovery), and a recurring evidence set (allowlist export, discovery report, sample tickets). Daydream can hold this mapping and prompt teams for the same evidence every cycle. ²

Footnotes

1. NIST SP 800-53 Rev. 5

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

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