CM-8(7): Centralized Repository

CM-8(7) requires you to maintain your system component inventory in a single, centralized repository so stakeholders can reliably find, query, and govern what exists in your environment. To operationalize it quickly, pick an authoritative system of record, define required data fields and ownership, integrate feeds from discovery/procurement/cloud, and run a repeatable reconciliation process with audit-ready evidence. ¹

Key takeaways:

• A “centralized repository” means one authoritative system of record for inventory, not scattered spreadsheets and tool-specific lists. ¹
• Your fastest path is governance plus integrations: define fields/owners, connect data sources, then reconcile exceptions on a schedule you can defend. ¹
• Auditors look for operational proof: access controls, change history, reconciliation results, and demonstrated completeness for the system boundary. ¹

The cm-8(7): centralized repository requirement is a deceptively small sentence with big operational consequences: “Provide a centralized repository for the inventory of system components.” ¹ If you cannot point to a single authoritative inventory, you will struggle to prove the basics during an assessment: what you own, where it runs, who manages it, and whether security controls apply consistently across the system boundary.

For most organizations, the inventory already exists in fragments: endpoint management, cloud consoles, virtualization, procurement, CI/CD, service desks, and third-party SaaS admin portals. CM-8(7) pushes you to consolidate that reality into one governed record that teams can trust for risk decisions, incident response scoping, vulnerability exposure, patch targeting, and configuration management.

This page is written for a Compliance Officer, CCO, or GRC lead who needs requirement-level guidance you can assign, track, and audit. It focuses on choosing a system of record, defining what “inventory” must include, integrating data sources, and retaining evidence that shows the repository is centralized, current, and used in operations. ²

Regulatory text

Requirement (CM-8(7)): “Provide a centralized repository for the inventory of system components.” ¹

Operator interpretation (what you must do):

• Stand up (or designate) one authoritative repository that holds the inventory for in-scope system components. ¹
• Make that repository the place auditors and operators go to answer: “What components exist in this system?” and “What changed?” ¹
• Ensure the repository is operationally maintained, not a one-time export. Your implementation must be demonstrable with evidence. ¹

Plain-English interpretation (what “centralized repository” really means)

A centralized repository is a single system of record for inventory. “Centralized” does not require one monolithic tool that discovers everything by itself; it requires one place where inventory data is consolidated, governed, and reportable for the system boundary. ¹

Practical translation:

• You can keep specialized sources (EDR, MDM, cloud, hypervisor) for operations, but you still need one authoritative consolidated inventory.
• A SharePoint folder of spreadsheets is rarely defensible because it lacks controlled ingestion, deduplication, lifecycle state, and audit trails unless you build those features around it.
• Centralization also implies standard fields and consistent naming so you can reconcile duplicates and prove completeness.

Who it applies to (entity and operational context)

CM-8(7) is typically applied in:

• Federal information systems and organizations assessed against NIST SP 800-53. ²
• Contractor systems handling federal data where 800-53 controls (or derived requirements) are flowed down via contract, ATO, or agency policy. ²

Operational contexts where this control becomes urgent:

• You have multiple hosting planes (on-prem plus one or more clouds).
• You rely on third parties for critical components (managed security services, SaaS platforms, data processors) and need to represent those components in your system inventory.
• You are preparing for an assessment where scoping disputes are common. A centralized inventory reduces arguments about what is “in” the system.

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

Treat this as an implementation you can hand to an owner and verify.

Step 1: Define the system boundary and component categories

1. Confirm the system boundary for the assessment (what’s in-scope vs out-of-scope).
2. Define “system component” categories you will track in the repository. Common categories:
   • Servers (physical/virtual), endpoints, network devices
   • Cloud resources (accounts/subscriptions/projects, compute, storage, managed databases)
   • Applications and services (internally developed, COTS, containers, serverless)
   • Supporting platforms (identity providers, logging/SIEM, vulnerability scanners)
   • Key third-party services that are part of the system’s function

Deliverable: an inventory scope statement that aligns to your SSP/system description language. ²

Step 2: Pick the authoritative centralized repository (system of record)

Select one of:

• CMDB / ITSM asset module
• Dedicated asset inventory platform
• A governed data store with workflow (if you can enforce controls, history, and access)

Minimum acceptance criteria for the repository:

• Unique identifiers per component
• Lifecycle state (planned/active/decommissioned)
• Ownership fields (system owner, technical owner)
• Change traceability (who changed what, when)
• Exportable reporting for assessors

If you are a GRC lead, document the decision and the rationale so auditors don’t treat it as ad hoc.

Step 3: Define required fields (data standard) and ownership

Create a required field set that supports security operations and assessment. Example baseline fields:

• Component name, type/category, environment (prod/non-prod)
• Unique ID, hostname/resource ID, IPs (where applicable)
• Location (cloud region/site), account/subscription/project
• Owner (team), custodian (ops), business service mapping
• Data sensitivity or system impact tags (as your program defines)
• Source of truth(s) and last seen/last updated timestamps
• Dependencies (optional but helpful for scoping incidents)

Assign:

• Control owner (accountable for CM-8(7) operation)
• Data stewards by domain (endpoint, cloud, network, app)
• Approvers for exceptions (unknown owner, disputed scope, unsupported assets)

Step 4: Integrate inventory sources and ingestion rules

Build repeatable ingestion from systems that already know what exists:

• Endpoint/MDM/EDR for corporate devices
• Cloud provider inventories and org/account structures
• Virtualization platforms
• Network discovery (where approved)
• Procurement and contract records for third-party services and hardware
• CI/CD or container registries for runtime artifacts (if those are in scope)

Define ingestion rules:

• Deduplication logic (match by serial number, instance ID, resource ARN, etc.)
• Conflict resolution (which source wins for owner, state, location)
• Exception workflow (unknown assets, unapproved components)

Step 5: Reconcile, remediate, and record exceptions

Centralization fails when the repository has data but no operational loop.

Run a reconciliation process that:

• Identifies components “seen in discovery but missing in repository”
• Flags components “in repository but not seen” (stale or decommission candidates)
• Requires owners to attest or remediate (assign owner, correct state, remove from scope with justification)

Track exceptions with:

• Justification, risk acceptance (if applicable), expiration/review date, and approver.

Step 6: Control access and prove operational use

Your repository becomes sensitive because it describes your environment.

Implement:

• Role-based access (read vs write vs admin)
• Restricted export where needed
• Logging of changes and administrative actions

Then prove that teams use it:

• Link vulnerability scans, patch groups, or incident scoping queries back to inventory records.
• Show sample outputs used in change management or risk reviews.

Step 7: Map CM-8(7) to owners, procedures, and recurring evidence (assessment readiness)

Create a control implementation record that ties:

• Control statement (CM-8(7))
• Tooling (repository name)
• Procedure (ingestion, reconciliation, exception handling)
• Evidence cadence (what you produce and retain)

Daydream can help here by turning CM-8(7) into an assignable control with named owners, documented procedures, and recurring evidence requests, so you are not rebuilding the same audit packet each cycle.

Required evidence and artifacts to retain

Keep artifacts that prove both design (the repository exists and is governed) and operation (it stays current).

Evidence checklist:

• Inventory policy/standard naming the centralized repository as system of record
• Data dictionary: required fields and definitions
• System boundary/scope statement aligned to the system authorization package language
• Role/ownership matrix for inventory stewardship
• Screenshots or exports showing:
  • Inventory repository structure
  • Sample component records with required fields populated
  • Change history / audit log entries
• Integration documentation (connectors, feeds, or job schedules)
• Reconciliation reports and tickets (unknown assets, stale assets, exceptions)
• Periodic management review artifacts (meeting notes, approvals, exception sign-offs)

Common exam/audit questions and hangups

Expect these and prep direct, artifact-backed answers:

1. “Show me the centralized repository.”
   Be ready to demonstrate access, search, exports, and record history.

2. “How do you know it’s complete for the system boundary?”
   Provide your source list (cloud org, EDR population, network segments) and reconciliation outputs.

3. “How do updates happen, and how quickly do changes appear?”
   Explain ingestion mechanisms and your reconciliation workflow. Avoid claiming a specific frequency unless you can show job logs and timestamps.

4. “Who is accountable for inventory quality?”
   Name the control owner and domain stewards; show how issues are assigned and closed.

5. “How do third-party components show up?”
   Show entries for in-scope third-party services or managed components, with owners and contract references where appropriate.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Multiple “official” inventories across teams	Auditors treat this as non-centralized	Declare one system of record and map all other sources as inputs
Inventory records without owners	No accountable remediation path	Require owner fields and enforce via workflow validation
One-time import for audit	Inventory goes stale quickly	Establish ingestion + reconciliation + exception handling
Ignoring cloud-native components	Material gaps in modern environments	Include org/accounts/projects and key managed services in the component model
No audit trail for changes	You cannot prove control operation	Enable logging/versioning and retain change logs as evidence

Risk implications (why assessors care)

A weak centralized inventory increases the likelihood of:

• Missed patch/vulnerability exposure because assets are unknown or misclassified
• Incident response scope errors (you cannot rapidly enumerate affected systems)
• Control inheritance and scoping failures across the authorization boundary
• Inconsistent hardening because assets fall outside management tooling

CM-8(7) is often treated as a “table stakes” control. If it fails, assessors may question the reliability of multiple other controls that depend on asset completeness.

Practical 30/60/90-day execution plan

Use these phases as an operational plan you can track in a GRC ticketing backlog.

First 30 days (foundation and decision)

• Name the CM-8(7) control owner and domain data stewards.
• Define the system boundary and component categories.
• Select the centralized repository and document it as the system of record.
• Publish the required field standard and ownership rules.
• Identify source systems for ingestion and prioritize by coverage (endpoint, cloud, network, apps, third party).

Days 31–60 (integrate and normalize)

• Implement initial connectors/feeds for your highest-value sources.
• Build deduplication and conflict rules; test with real data.
• Stand up exception workflows (unknown asset, no owner, disputed scope).
• Populate the repository to a baseline state that supports assessment walkthroughs.
• Start producing reconciliation reports and closing tickets.

Days 61–90 (operate, evidence, and prove reliability)

• Run recurring reconciliation cycles and show improvement trends qualitatively (fewer unknowns, fewer stale records).
• Validate access controls, logging, and change history retention.
• Perform an internal audit-style walkthrough: “show repository, show ingestion, show reconciliation, show exceptions.”
• Package evidence artifacts for assessors and map them to CM-8(7) in your control narrative.
• Optional: Configure Daydream workflows to assign evidence collection and generate a consistent audit packet for CM-8(7).

Frequently Asked Questions

What qualifies as “centralized” if different tools discover different assets?

Centralized means one authoritative repository holds the consolidated inventory, even if multiple tools feed it. Keep specialized tools, but make one place the system of record with governance and reporting. ¹

Can our CMDB be the centralized repository?

Yes, if it is the authoritative system of record for in-scope components and you can show ownership, lifecycle state, and operational updates. Assessors will expect evidence of ingestion and reconciliation, not just a populated table. ¹

Do we have to include SaaS and other third-party services in the inventory?

If the third-party service is part of the system boundary or materially supports system function, represent it as a system component record with an owner and lifecycle state. Document your scoping rationale where a service is explicitly out of scope. ²

What’s the minimum evidence to pass an audit walkthrough for CM-8(7)?

Be able to show the repository, sample records with required fields, how updates occur, and at least one reconciliation or exception-handling example. Add access control and change log evidence to show the repository is governed. ¹

How do we handle ephemeral assets like containers or short-lived cloud compute?

Decide what “inventory” means for ephemeral assets in your component model, such as tracking the controlling service, cluster, account/project, and images/templates rather than every short-lived instance. Write the rule and apply it consistently in the centralized repository. ²

Who should own CM-8(7): Security, IT Ops, or GRC?

IT Ops or a platform/asset management function usually owns inventory operations, while GRC owns oversight and assessment readiness. Document the RACI so assessors see clear accountability for data quality and exceptions. ²

Footnotes

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

2. NIST SP 800-53 Rev. 5