CM-8(3): Automated Unauthorized Component Detection

The cm-8(3): automated unauthorized component detection requirement is an operations problem disguised as a documentation problem. Auditors will ask for both: proof your environment detects unauthorized components, and proof people act on the findings consistently. CM-8(3) is an enhancement to configuration management inventory expectations in NIST SP 800-53 Rev. 5. It focuses on detection of “unauthorized” components, which forces a concrete definition of what “authorized” means for your environment and your mission.

This control matters most in messy reality: inherited assets, shadow IT, emergency changes, developer tooling, third-party agents, and firmware that quietly changes during device servicing. The fastest path to meeting CM-8(3) is to connect your authoritative inventory to automated discovery, define detection logic (what counts as unauthorized), route findings into incident/change workflows, and retain clean, assessor-ready evidence.

If you’re running a federal information system or you’re a contractor handling federal data, you should treat CM-8(3) as a baseline expectation for system integrity and supply chain hygiene. ¹

Regulatory text

Control excerpt (CM-8(3)): “Detect the presence of unauthorized hardware, software, and firmware components within the system using [organization-defined mechanisms and organization-defined frequency/conditions]; and” ²

What the operator must do

1. Pick automated mechanisms that can discover hardware, software, and firmware components across your defined system boundary (endpoints, servers, network, cloud workloads, appliances).
2. Define what “unauthorized” means (the authorization criteria and source of truth for approvals).
3. Run detection on a defined cadence or under defined conditions (for example, continuously, daily scans, on network join, on image deploy, on patch cycles, on privileged software install events).
4. Prove it works with retained evidence: detection outputs, alerts, investigation notes, and closure artifacts. ²

Plain-English interpretation of the requirement

CM-8(3) expects your environment to “notice” when something shows up that you did not approve: a new device on the network, a new agent on a server, a rogue browser extension, an unapproved container base image, or firmware that does not match your approved baseline. It is not enough to have an inventory spreadsheet. The requirement is detection, run by automation, tied to a definition of authorization, with a trail that shows response.

Who it applies to

Entity scope

• Federal information systems implementing NIST SP 800-53 Rev. 5 controls. ¹
• Contractor systems handling federal data where NIST SP 800-53 control alignment is contractually required (common in federal programs and flows). ¹

Operational context (where teams get tripped up)

• Hybrid environments: endpoints + on-prem servers + cloud workloads.
• Managed devices and unmanaged devices: BYOD, third-party support laptops, lab equipment, OT/IoT-like devices.
• Rapid change surfaces: CI/CD pipelines, ephemeral containers, auto-scaling groups.
• Firmware visibility gaps: network appliances, laptops with vendor tools, servers with BMC/iDRAC/iLO, embedded device firmware.

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

Step 1: Set a crisp “authorized component” definition

Create a short standard that states:

• What classes of components are in scope: hardware, software, firmware (explicitly list typical examples in your environment).
• What makes a component authorized: approved catalog entry, approved image, approved package repository, approved device enrollment, signed/verified vendor firmware, or documented exception.
• Who can authorize and how approval is recorded (change ticket, security exception, procurement record).

Practical tip: if authorization cannot be expressed in a system (CMDB, MDM, EDR policy, SCCM/Intune catalog, cloud image registry), detection becomes subjective and hard to audit.

Step 2: Define the “system boundary” you will monitor

Write down the boundary in the same terms your tooling uses:

• Network segments/VPCs/subscriptions/accounts
• Endpoint fleet groups
• Server groups and critical applications
• SaaS tenant scope where agents or plugins run

Align this with your SSP/system description so assessors can map “what you monitor” to “what you claim is the system.”

Step 3: Select automated detection mechanisms (by component type)

Use a coverage matrix so you can show intent and gaps.

Component type	Automated detection examples	Typical outputs you’ll retain
Hardware	NAC discovery, network scans, MDM enrollment status, EDR sensor inventory	New device alerts, device inventory deltas, quarantine actions
Software	EDR/software inventory, MDM app inventory, server config management, package inventory, application allowlisting	Unapproved software detections, install events, allowlist violations
Firmware	Vendor management tools, endpoint posture checks, vulnerability scanners that read firmware versions, attestation where supported	Firmware version drift reports, noncompliant device lists, remediation evidence

CM-8(3) does not force a specific product. It forces automation that works at your scale and supports auditability. ²

Step 4: Define detection cadence and triggers (make it enforceable)

Document the organization-defined frequency/conditions referenced in the control text. Examples that stand up in audits:

• On device join to domain/MDM
• On new workload deploy (golden image verification)
• Scheduled discovery scans
• On privileged installation events
• On EDR sensor heartbeat (continuous inventory refresh)

Write this as a control procedure: “Tool X performs discovery under conditions Y; alerts route to queue Z.”

Step 5: Build the unauthorized detection logic (the “diff”)

Detection is a comparison:

• Discovered components (what is present)
  vs.
• Authorized baseline (what is approved)

Operationalize the baseline:

• Approved software list per asset group (servers vs endpoints)
• Approved firmware versions per model class
• Approved device types and ownership status
• Approved cloud images/AMIs/container base images

Where teams fail: they define “authorized” as “anything purchased by IT.” That does not map cleanly to runtime detection.

Step 6: Route findings into a workflow with deadlines and outcomes

Your workflow needs three standard outcomes:

1. Remove the component (uninstall, isolate device, rollback firmware).
2. Authorize it through formal approval (with risk review, if needed).
3. Exception it with compensating controls and expiration.

Connect alerts to:

• Incident management (if malicious/suspicious)
• Change management (if legitimate but unapproved)
• Asset management (if inventory gap)
• Third-party risk intake (if a third party introduced the component)

Step 7: Prove control operation with recurring evidence

Build an “assessment packet” that you can regenerate on demand:

• Inventory snapshots and deltas
• Alert samples showing unauthorized detections
• Triage notes and tickets to closure
• Exception register entries with approvals and expiry
• Meeting notes or metrics showing review of trends

Daydream fit (earned mention): many teams have tooling, but evidence is scattered. Daydream can be used to map CM-8(3) to a named control owner, a single operating procedure, and a recurring evidence checklist so you can reproduce proof without rework. ²

Required evidence and artifacts to retain

Keep artifacts that show design + operation:

Design artifacts

• CM-8(3) control narrative (mechanisms, cadence/conditions, scope) ²
• Authorized component standard (what counts as authorized; who approves)
• System boundary statement aligned to your SSP/system inventory

Operational artifacts

• Tool configuration exports (policies, scan schedules, allowlists)
• Discovery outputs (inventories, component lists, firmware reports)
• Alert/event logs for unauthorized detections
• Tickets with remediation actions and closure notes
• Exception approvals, compensating controls, and expiry dates
• Evidence of periodic review (dashboards, reviews, sign-offs)

Retention duration should follow your program’s record retention rules; CM-8(3) mainly cares that evidence is complete, consistent, and reproducible.

Common exam/audit questions and hangups

• “Show me how you define unauthorized for software and firmware. Where is that documented?”
• “Which systems are in scope, and how do you know discovery covers them?”
• “Demonstrate detection: provide recent examples of unauthorized component alerts and the resulting actions.”
• “How do you prevent an ‘unauthorized’ item from becoming silently accepted over time?”
• “What is your process for third-party introduced agents/tools on endpoints or servers?”
• “How do you handle ephemeral assets (containers/auto-scaling) without losing evidence?”

Typical hangup: teams can show an inventory, but cannot show unauthorized detection events plus closed-loop handling.

Frequent implementation mistakes (and how to avoid them)

1. Inventory without enforcement

   • Mistake: “We have a CMDB” equals compliance.
   • Fix: show automated diffing and alerts against an approved baseline.

2. Only endpoint coverage

   • Mistake: ignoring network appliances, servers, cloud images, and firmware.
   • Fix: create a coverage matrix and document compensating controls for gaps.

3. No exception discipline

   • Mistake: permanent exceptions with no owner or expiry.
   • Fix: require exception owner, justification, compensating controls, and expiration.

4. Authorization happens in email

   • Mistake: approvals cannot be queried or audited.
   • Fix: force approvals into a system of record (ticketing, GRC workflow).

5. Alert fatigue equals noncompliance

   • Mistake: tools generate alerts, but nobody triages them consistently.
   • Fix: define severity criteria, routing, and escalation paths; sample closures during evidence collection.

Risk implications (why assessors care)

Unauthorized components are a common path for:

• Malware persistence (rogue agents, scheduled tasks, unauthorized binaries)
• Data exfiltration routes (unauthorized remote tools, browser plugins)
• Supply chain compromise (tampered firmware, unverified updates)
• Control bypass (unmanaged devices outside EDR/MDM scope)

CM-8(3) reduces these risks by making drift visible and actionable through automation. ¹

Practical execution plan (30/60/90-day)

Your plan should be milestone-based, not calendar-promises.

First 30 days (control design locked)

• Assign a single control owner and backups.
• Publish the “authorized component” standard (hardware/software/firmware).
• Define system boundary and in-scope asset groups.
• Build the coverage matrix; identify tooling gaps and compensating controls.
• Document cadence/conditions for detection in the control procedure. ²

Days 31–60 (automation producing findings)

• Configure discovery feeds (EDR/MDM/NAC/scanners/cloud inventory).
• Establish baselines (approved lists) for at least critical asset groups first.
• Turn on unauthorized detection rules with a tuning period.
• Wire alerts into ticketing with required fields (asset, component, disposition, approver).

Days 61–90 (evidence-ready operations)

• Run a recurring review (trend + exceptions + stale assets).
• Test the control: introduce a known unapproved item in a safe test group and verify detection + ticket closure.
• Build the assessment packet: screenshots/exports, sample alerts, closed tickets, exception register.
• Use Daydream to keep owner, procedure, and evidence checklist synchronized so the next audit does not become an evidence hunt. ²

Frequently Asked Questions

Does CM-8(3) require real-time detection?

CM-8(3) requires automated detection using organization-defined frequency/conditions; it does not prescribe real-time. Document your cadence and show the automation runs as designed. ²

What counts as “firmware components” in practice?

Treat firmware broadly: BIOS/UEFI, device controller firmware, network appliance firmware, and embedded firmware in managed hardware. Your evidence should show you can detect versions and flag drift from approved baselines.

We have an EDR inventory. Is that enough to meet the requirement?

It can be enough for software detection on covered endpoints, but CM-8(3) also calls out hardware and firmware. Close the gap with NAC/MDM for hardware and a firmware visibility approach appropriate to your asset classes. ²

How do we handle ephemeral cloud assets and containers?

Define authorization at the image and pipeline level (approved AMIs/base images, signed artifacts), then detect runtime drift through cloud inventory and workload security telemetry. Retain evidence as reports and tickets, not per-instance screenshots.

What do auditors want to see as proof of “unauthorized” detection?

They usually ask for recent examples of unauthorized component alerts plus the associated investigation and closure. Keep a small, well-curated sample set with clear disposition and approvals.

Can third parties install software agents on our systems?

Yes, but treat that as a controlled authorization path: require documented approval, validate the agent against your authorized list, and ensure your detection flags any unapproved installation attempt.

Footnotes

1. NIST SP 800-53 Rev. 5

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