IA-5(14): Managing Content of PKI Trust Stores

IA-5(14): managing content of pki trust stores requirement means you must run one organization-wide method to control which Certificate Authorities (CAs) and trust anchors are trusted across every trust store you operate (OS, browsers, apps, network devices) for PKI-based authentication. Operationalize it by standardizing trust-store baselines, distributing them through configuration management, and proving you detect and remediate drift. ¹

Key takeaways:

• Maintain a single authoritative “approved trust store content” baseline and apply it consistently across platforms. ¹
• Build a repeatable process for adding, removing, and validating trusted roots/intermediates across endpoints, servers, and appliances. ¹
• Keep evidence that you can inventory, enforce, and audit trust store content in production. ¹

Trust stores decide which certificates your systems accept as valid. If your trust stores drift, teams silently expand who can authenticate to critical systems, accept man-in-the-middle interception, or break authentication when certificates change. IA-5(14) exists to prevent “trust chaos” by requiring a single, organization-wide methodology for managing PKI trust store content across all platforms that participate in PKI-based authentication. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat trust-store content like a controlled configuration baseline: define what “trusted” means for your environment, assign ownership, enforce it via endpoint and configuration tooling, and generate recurring evidence that proves it stays consistent. You do not need to become a PKI engineer to run this control, but you do need to force clear decisions: which roots/intermediates are allowed, where they must be installed, how exceptions work, and how changes are approved and rolled out without breaking authentication flows.

This page gives requirement-level implementation guidance you can hand to IAM, endpoint, platform, and network teams and then audit with confidence against the ia-5(14): managing content of pki trust stores requirement. ¹

Regulatory text

Requirement (verbatim): “For PKI-based authentication, employ an organization-wide methodology for managing the content of PKI trust stores installed across all platforms, including networks, operating systems, browsers, and applications.” ¹

What the operator must do:

• Define an organization-wide method (policy + procedure + tooling pattern) that controls trust store content wherever PKI-based authentication is used. ¹
• Cover all relevant locations where trust is evaluated: network devices, operating systems, browsers, and applications. ¹
• Ensure the method is consistent and repeatable, not a team-by-team “best effort.” ¹

Plain-English interpretation

You must be able to answer two questions at any moment:

1. Which CAs do we trust for authentication, and why?
2. Can we prove every system that relies on PKI authentication trusts only those CAs (and no others), or that exceptions are approved and monitored? ¹

This control focuses on content of trust stores (which roots/intermediates are present, enabled, and used), not only certificate issuance. If you rely on system defaults (for example, unmanaged browser root stores), you still need an organization-wide method to manage that reality, such as setting enforced configurations, restricting unmanaged endpoints from authenticating, or documenting justified exceptions with compensating controls. ¹

Who it applies to

Entity scope

• Federal information systems and contractor systems handling federal data where NIST SP 800-53 is in scope (for example, via agency requirements or contractual obligations). ²

Operational scope (where you must implement)

• Any environment using PKI-based authentication, including:
  • User or admin authentication with client certificates (mTLS, smart cards, PIV/CAC-like patterns).
  • Service-to-service authentication using certificates.
  • Network access authentication tied to certificates (device onboarding, VPN, Wi-Fi, NAC patterns).
• Platforms explicitly named by the requirement: networks, operating systems, browsers, applications. ¹

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

1) Assign control ownership and define the methodology

Create a short “Trust Store Management Standard” that states:

• Control owner (accountable): typically IAM/PKI, Security Engineering, or Platform Security.
• Operational owners (responsible): Endpoint team, Windows/Linux team, Network team, Application platform owners.
• In-scope trust stores: OS trust stores, browser trust stores, Java keystore(s), container base images, network/security appliances, API gateways, service meshes, etc. ¹

Practical tip: write the methodology as a flow with decision points: “If a platform uses OS trust store, enforce baseline via endpoint management. If it uses embedded trust store (Java/cert bundle), enforce baseline via build pipeline + runtime checks.” That is what auditors mean by “organization-wide methodology.” ¹

2) Build an inventory of trust stores and PKI authentication dependencies

You need an inventory that connects:

• Systems using PKI-based authentication (apps, VPN, admin portals, internal services).
• Where trust is evaluated (which trust store, on which asset class).
• How trust store content is deployed (GPO/MDM, config management, image pipeline, appliance config). ¹

Minimum viable approach:

• Pull endpoint and server populations from your CMDB/asset inventory.
• Enumerate common trust store types by platform (Windows, macOS, Linux distributions, browsers, Java runtimes, containers, major appliances).
• Identify “special cases” where apps ship their own CA bundle. Those are the drift hotspots.

3) Define an approved trust store baseline (and an exception process)

Create a controlled baseline:

• Approved trust anchors (roots) and any required intermediates.
• Explicitly disallowed CAs (removed or distrusted).
• Validity and lifecycle rules (for example, what triggers removal: compromise, deprecation, contract end, or mis-issuance response).
• Exception path with compensating controls (time-bound, owner, business justification, and monitoring). ¹

Keep the baseline in a change-controlled repository (policy portal + version-controlled file). Daydream can help by mapping the requirement to a named owner, a documented procedure, and recurring evidence artifacts so you always have an assessor-ready package rather than a scramble across teams. ¹

4) Implement distribution and enforcement across platforms

Pick enforcement mechanisms per platform type:

Endpoints (OS + browsers)

• Enforce via endpoint management (GPO/MDM/enterprise management tooling).
• Prevent local admin users from silently adding trust anchors where feasible; if not feasible, detect changes and trigger alerts.

Servers and workloads

• Configuration management to enforce CA bundle state.
• For containerized environments, manage CA bundles in base images and validate at build time; scan for unauthorized CA files at runtime.

Applications with embedded trust stores

• Require that applications reference the approved enterprise trust store or ship an approved bundle sourced from the baseline repository.
• Add a release gate: no production deployment if trust store content differs from the approved baseline without an approved exception. ¹

Network/security appliances

• Standardize trust anchors in device configuration templates.
• Include trust store checks in network compliance/backup validation processes. ¹

5) Detect drift and prove ongoing control operation

IA-5(14) fails most often on evidence: teams can describe what they “intend,” but cannot prove current state.

Operationalize drift detection:

• Scheduled collection of trust store content (roots/intermediates) from representative assets across each platform class.
• Comparison against the approved baseline and exceptions list.
• Ticketed remediation workflow with timestamps and approvals. ¹

6) Control changes with a formal add/remove workflow

Define a repeatable change workflow:

• Intake request (business reason, impacted systems, certificate chain details).
• Security review (risk acceptance of CA, scope, and expiry/lifecycle plan).
• Test plan (validate authentication still works).
• Deployment plan (phased rollout and rollback steps).
• Post-change verification (re-collect trust store content and attach results). ¹

Required evidence and artifacts to retain

Keep evidence that ties “methodology” to “real systems”:

1. Trust Store Management Standard / procedure (dated, approved) showing organization-wide methodology and platform coverage. ¹
2. Inventory of in-scope trust stores and which systems depend on PKI authentication.
3. Approved trust store baseline (versioned) and exceptions register (with approvals).
4. Change tickets for baseline updates, including review and implementation evidence.
5. Drift detection reports (snapshots, comparisons, and remediation tickets).
6. Sample configuration proofs per platform (screenshots, exported trust store lists, config management states, or equivalent outputs).

Common exam/audit questions and hangups

Auditors and assessors usually press on these points:

• “Show me your organization-wide methodology. Where is it documented, and who owns it?” ¹
• “Which platforms are included? Do browsers and applications with embedded trust stores follow the same baseline?” ¹
• “How do you know endpoints did not drift since last quarter?” Expect to produce drift evidence.
• “What is your process to remove a CA quickly if it becomes untrusted?” They look for change workflow maturity and proof of execution.
• “Do third-party managed systems follow your baseline or have exceptions?” If a third party manages a platform, you still own the methodology and assurance. ¹

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails IA-5(14)	Fix
Assuming OS default trust stores are “managed”	Default roots change outside your methodology	Define how you govern defaults: enforce enterprise baseline, restrict authentication to managed devices, or document exceptions with monitoring. 1
Managing only Windows endpoints	Requirement includes networks, browsers, apps	Build a platform matrix and assign owners per column. 1
No inventory of apps with embedded CA bundles	Hidden trust stores become permanent exceptions	Add SDLC checks and release gates tied to the baseline.
One-time baseline with no drift detection	You cannot prove ongoing management	Automate collection and comparison; retain reports and tickets.
Exceptions granted informally	Unbounded trust expansion	Use an exceptions register with approvals, expiry triggers, and validation checks.

Enforcement context and risk implications

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

Risk is still concrete:

• Expanded trust increases the chance a malicious or mis-issued certificate is accepted for authentication.
• Inconsistent trust creates outages when one platform trusts a CA chain and another rejects it.
• Third-party software and appliances often ship their own CA stores, creating blind spots that auditors flag under “all platforms” coverage. ¹

Practical 30/60/90-day execution plan

Day 0–30: Establish control shape and inventory

• Name the control owner and operational owners; publish the Trust Store Management Standard draft. ¹
• Build the platform matrix: OS, browsers, key apps, network devices, and where trust is evaluated.
• Identify top PKI-authentication flows (admin access, SSO edge cases, VPN/NAC, service-to-service).

Day 31–60: Baseline and enforce on highest-impact platforms

• Publish v1 of the approved baseline and exceptions register.
• Implement baseline enforcement on the most common endpoint and server platforms first.
• Stand up drift detection reporting for at least one representative population per platform class.

Day 61–90: Expand coverage and prove operations

• Extend enforcement to browsers and applications with embedded trust stores via SDLC controls.
• Add network devices and security appliances via configuration templates and validation checks.
• Run at least one full change cycle (add/remove or exception) and archive the evidence package for assessment readiness.

If you need to operationalize this quickly across many teams, Daydream’s practical control mapping approach (owner + procedure + recurring artifacts) is a good fit for keeping IA-5(14) continuously audit-ready rather than “rebuilt” each assessment. ¹

Frequently Asked Questions

Does IA-5(14) require one single trust store for the entire enterprise?

No. It requires an organization-wide methodology to manage content across trust stores, even if each platform has a different trust store implementation. Your job is consistent governance, not identical technology. ¹

Are browser trust stores really in scope if we only use certificates for internal admin tools?

Yes, if PKI-based authentication depends on browser certificate validation, then browsers are explicitly in scope. Document how you control browser trust anchors on managed endpoints and how you handle unmanaged access. ¹

How do we handle applications that ship their own CA bundle (Java, embedded devices, containers)?

Treat them as separate trust stores that must be governed by the same baseline and change workflow. Add build/release checks that compare shipped CA bundles to the approved baseline or enforce an approved exception. ¹

What evidence is strongest for auditors?

A documented methodology, a versioned baseline, and exported trust store content from real systems showing alignment or approved exceptions. Tie any drift findings to tickets and remediation actions. ¹

Can a third party manage trust stores for systems they operate for us?

They can perform the work, but you still need an organization-wide methodology and assurance that their managed trust stores match your baseline or have approved exceptions. Contractual requirements and attestations help, but you still need operational evidence. ¹

What’s the minimum viable “methodology” if we are early-stage?

Start with an inventory, a baseline list of approved trust anchors, and a change workflow with approvals. Enforce the baseline on your primary endpoint and server platforms, then expand coverage to browsers, apps, and network devices. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5