CM-9(1): Assignment of Responsibility

CM-9(1): Assignment of Responsibility requires you to assign responsibility for developing the configuration management (CM) process to personnel who are independent from system development, so the process is governed without developer conflicts of interest. Operationalize it by naming an independent CM process owner, documenting the independence rationale, and retaining evidence that the CM process is defined and maintained outside the development chain. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Key takeaways:

• Put CM process design ownership with an independent function (security, IT operations, risk, or quality), not the development team. (NIST SP 800-53 Rev. 5 OSCAL JSON)
• Document both the assignment and why the assignee is not directly involved in system development. (NIST SP 800-53 Rev. 5 OSCAL JSON)
• Auditors look for proof in org charts, RACI, role descriptions, and change governance records showing independence in practice. (NIST SP 800-53 Rev. 5)

CM-9(1): assignment of responsibility requirement is a governance control with a simple intent: the people who build the system should not be the people who define the rules for how configuration is managed. That separation reduces self-approval risk, narrows the chance of undocumented exceptions, and makes your configuration management process more resilient when delivery pressure spikes.

For a Compliance Officer, CCO, or GRC lead, the work is mostly about role design and evidence design. You need a clear “owner” for the configuration management process (the process definition, standards, oversight, and updates), and you need to show that this owner is not directly involved in system development. “Not directly involved” is the phrase that drives debates in assessments, so you should define it for your environment and document where your independence boundary sits.

This page gives you requirement-level implementation guidance you can execute quickly: who should own the CM process, how to document independence without slowing engineering, what artifacts to retain, and how to avoid common audit failures where organizations assign a name but cannot prove real separation of duties. (NIST SP 800-53 Rev. 5)

Regulatory text

Requirement (verbatim): “Assign responsibility for developing the configuration management process to organizational personnel that are not directly involved in system development.” (NIST SP 800-53 Rev. 5 OSCAL JSON)

Operator interpretation: You must designate a role (or roles) responsible for creating and maintaining the organization’s configuration management process, and that role cannot sit in the direct system development function for the system(s) in scope. This is about who defines the CM process, not who executes individual configuration changes day-to-day. (NIST SP 800-53 Rev. 5 OSCAL JSON)

What an assessor expects to see: a formal assignment (policy/RACI/charter), evidence the assignee is independent of development, and evidence the CM process exists and is maintained by that independent owner (for example, periodic updates, approvals, governance meeting minutes, and controlled documents). (NIST SP 800-53 Rev. 5)

Plain-English meaning (what CM-9(1) is really asking)

CM-9(1) is a separation-of-duties requirement applied to the design and governance of configuration management. The rule-maker for configuration management cannot be the same team that has delivery incentives to weaken it (for example, redefining approvals to “move fast,” lowering baseline rigor, or normalizing undocumented changes). (NIST SP 800-53 Rev. 5 OSCAL JSON)

In practice, this means:

• Development can propose improvements, standards, and tooling.
• An independent owner decides what becomes the official CM process, documents it, and controls changes to the process documentation.
• Independence must be real enough to withstand scrutiny when incidents occur or when engineering leadership wants exceptions. (NIST SP 800-53 Rev. 5)

Who it applies to (entity + operational context)

This requirement is commonly assessed for:

• Federal information systems implementing NIST SP 800-53 controls. (NIST SP 800-53 Rev. 5)
• Contractor systems handling federal data where NIST SP 800-53 is flowed down contractually or used as the governing control baseline. (NIST SP 800-53 Rev. 5)

Operationally, it applies wherever you have:

• A defined SDLC (Agile, DevOps, waterfall).
• Any meaningful configuration surface area (cloud infrastructure, SaaS settings, network configs, endpoints, CI/CD pipelines, container platforms).
• A need to show that CM governance is not self-attested by the people writing code. (NIST SP 800-53 Rev. 5)

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

Use the steps below as an implementation checklist for cm-9(1): assignment of responsibility requirement.

1) Define the independence boundary for “not directly involved”

Write a short definition you can defend in an audit, such as:

• “Directly involved in system development” includes engineers, engineering managers responsible for delivery, and DevOps roles embedded in the product team for the in-scope system.
• It excludes centralized security governance, IT operations/platform governance, risk management, and quality functions that oversee process standards across systems.

Document the definition in your CM policy or CM process standard so it is not an informal interpretation. (NIST SP 800-53 Rev. 5 OSCAL JSON)

2) Assign a CM process owner outside development

Pick one accountable owner (person) and one owning function (team). Common patterns that satisfy the intent:

• Information Security Governance (GRC) owns the CM process documentation; IT/Platform Ops administers the tooling.
• Central IT Operations owns the CM process for enterprise platforms; development follows it for application configuration.
• A Quality/Process Assurance function owns the CM process in highly regulated environments.

Avoid placing the CM process owner inside the same reporting chain as the system development lead for the in-scope system. (NIST SP 800-53 Rev. 5 OSCAL JSON)

3) Document the assignment in a durable control artifact

Create or update at least one of the following:

• CM Policy or CM Standard with named roles and responsibilities.
• RACI matrix for configuration management process governance.
• Security program charter / governance memo signed by an executive sponsor.

Minimum content:

• Role title and named owner.
• Scope (systems, environments).
• Responsibilities (develop/maintain CM process, approve process changes, arbitrate exceptions).
• Independence statement (why the owner is not directly involved in system development). (NIST SP 800-53 Rev. 5)

4) Separate “process development” from “process execution” roles

This control fails most often when organizations conflate “developing the CM process” with “doing configuration changes.”

Set clear lines:

• CM process developer (independent): authors/maintains CM procedures and standards; defines required approvals; defines baseline and documentation requirements; maintains exception process.
• Change implementers (often engineering/ops): perform approved configuration changes; propose updates to the CM process; provide evidence.

Write this separation into your RACI to prevent “everyone owns it,” which usually means no one does. (NIST SP 800-53 Rev. 5 OSCAL JSON)

5) Establish a process-change mechanism controlled by the independent owner

Create a lightweight mechanism for changing the CM process itself, such as:

• Controlled document repository with version history and approver fields.
• A governance ticket type for “CM Process Change” where the independent owner is the required approver.
• A periodic review cadence owned by the independent function.

Evidence should show that the CM process is maintained by the independent owner, not parked and forgotten. (NIST SP 800-53 Rev. 5)

6) Prove independence in practice (not just on paper)

Assessors will test whether the CM owner can be overruled by development without documented governance.

Add at least one operational guardrail:

• CM process changes require independent owner approval in the document control workflow.
• Exceptions to CM requirements route to the independent owner (or a governance body where development is not the sole decision-maker).
• Meeting minutes or decision logs show independent oversight.

If your organization uses Daydream to track controls, map CM-9(1) to a specific control owner, implementation procedure, and recurring evidence artifacts so independence is provable and repeatable across audits. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Required evidence and artifacts to retain

Keep artifacts that prove (1) assignment, (2) independence, and (3) ongoing ownership.

Assignment artifacts

• CM policy/standard that names the CM process owner and responsibilities. (NIST SP 800-53 Rev. 5 OSCAL JSON)
• RACI for CM governance, with “Accountable” outside development. (NIST SP 800-53 Rev. 5)

Independence artifacts

• Current org chart showing reporting lines.
• Job description/role description for the CM process owner.
• Statement of independence in the CM policy or governance memo (one paragraph is enough if it is explicit). (NIST SP 800-53 Rev. 5 OSCAL JSON)

Operational proof artifacts

• Version history for the CM process document with approvers.
• Change governance tickets for CM process updates (not system config changes), showing independent approval.
• Exception log (if you allow exceptions) showing independent review/decision. (NIST SP 800-53 Rev. 5)

Common exam/audit questions and hangups

Expect auditors to probe ambiguity around “not directly involved” and “developing the process.”

Common questions:

1. Who is accountable for developing and maintaining the CM process? Show where that is documented. (NIST SP 800-53 Rev. 5 OSCAL JSON)
2. How do you know that person is not directly involved in system development for the in-scope system? Provide org evidence. (NIST SP 800-53 Rev. 5)
3. How do changes to the CM process get approved? Show workflow and independent approval. (NIST SP 800-53 Rev. 5)
4. How do engineering teams request exceptions or urgent changes? Show independence in exception handling. (NIST SP 800-53 Rev. 5)

Hangups you can prevent:

• A “security engineer” embedded in the product team is often viewed as directly involved. Document why the owner is independent, or pick a different owner. (NIST SP 800-53 Rev. 5 OSCAL JSON)
• If CM documentation lives only in an engineering wiki with open edit rights, you may have trouble proving independent control over the CM process. (NIST SP 800-53 Rev. 5)

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails CM-9(1)	Fix
Assigning CM process ownership to the head of engineering	Direct development incentive conflict	Move accountability to security governance, IT ops governance, or quality; keep engineering as consulted/informed. (NIST SP 800-53 Rev. 5 OSCAL JSON)
Naming an owner but no controlled process documentation exists	You can’t show “developing the CM process” happened	Maintain a controlled CM policy/standard with versioning and approvals. (NIST SP 800-53 Rev. 5)
“Everyone owns CM”	No accountable owner; audits stall	Use a RACI with a single accountable owner outside development. (NIST SP 800-53 Rev. 5 OSCAL JSON)
Confusing CM tool admin with CM process governance	Tooling ≠ governance	Split roles: tool admin can sit in ops; process governance stays independent from development. (NIST SP 800-53 Rev. 5)
Independence is implied but not documented	Assessors need explicit evidence	Add a short independence statement and attach org artifacts to the control record. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Risk implications (why auditors care)

If development controls CM process definition, you increase the chance of:

• Weak approval gates for high-risk configuration changes.
• Informal “temporary” changes that become permanent.
• Inconsistent baselines across environments.

The compliance risk is straightforward: failing CM-9(1) usually reads as a control design gap (no independence) or an evidence gap (independence exists but cannot be proven). Either result can expand assessment scope and drive compensating-control requests. (NIST SP 800-53 Rev. 5)

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

Use these phases as a workable rollout path without inventing hard timelines for your environment.

First 30 days (Immediate setup)

• Select the independent CM process owner and executive sponsor. (NIST SP 800-53 Rev. 5 OSCAL JSON)
• Draft/update CM policy/standard sections: roles, responsibilities, independence definition. (NIST SP 800-53 Rev. 5)
• Build the evidence binder structure: org chart, RACI, role description, document control method. (NIST SP 800-53 Rev. 5)

Days 31–60 (Operationalize governance)

• Implement controlled workflow for CM process document updates with independent approval. (NIST SP 800-53 Rev. 5)
• Train engineering/ops leads on: who owns the CM process, how to request changes, how exceptions are handled. (NIST SP 800-53 Rev. 5 OSCAL JSON)
• Start a decision log for CM process changes and exceptions, owned by the independent function. (NIST SP 800-53 Rev. 5)

Days 61–90 (Prove it works under pressure)

• Run a tabletop: simulate an urgent production configuration issue and test whether the CM process governance and exception path work with independence intact. (NIST SP 800-53 Rev. 5)
• Perform an internal control check: can you show assignment, independence, and recent evidence of CM process maintenance in a single packet? (NIST SP 800-53 Rev. 5 OSCAL JSON)
• In Daydream (or your GRC system), map CM-9(1) to the control owner, implementation procedure, and recurring evidence artifacts so evidence collection becomes routine instead of scramble-driven. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Frequently Asked Questions

Does CM-9(1) mean developers cannot make configuration changes?

No. It restricts who develops the configuration management process, not who performs approved changes. Developers can execute changes if the CM process requires proper approvals and documentation set by an independent owner. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Who is a good CM process owner if we are a small organization?

Choose someone outside the development reporting chain, such as a security/GRC lead, IT operations manager, or quality lead. If one person wears multiple hats, document the independence boundary and add compensating governance such as independent approval from a separate manager. (NIST SP 800-53 Rev. 5)

Can a DevOps or platform engineering team own the CM process and still be “not directly involved”?

It depends on whether that team is part of the system development function for the in-scope system. If platform engineering is a centralized ops function serving multiple teams, it may qualify; document the rationale and reporting lines. (NIST SP 800-53 Rev. 5 OSCAL JSON)

What is the minimum evidence auditors will accept for independence?

A named owner in a CM policy/RACI plus an org chart or role description showing they are outside development is the baseline. Add proof of independent approval for CM process document changes to show the separation works in practice. (NIST SP 800-53 Rev. 5)

We outsource development to a third party. Who should own the CM process?

Your organization still needs an internal, independent owner to define and govern the CM process that applies to the system. The third party can follow the process and propose changes, but they should not be the accountable process designer for your program. (NIST SP 800-53 Rev. 5 OSCAL JSON)

How do we map CM-9(1) in a GRC tool without creating busywork?

Create one control record with a single owner, attach the policy/RACI/org chart, and define recurring evidence as “CM process document revision history” and “CM process change approvals.” Daydream supports this approach by tying the requirement to an owner, procedure, and evidence set you can re-use across assessments. (NIST SP 800-53 Rev. 5 OSCAL JSON)