IA-5(15): GSA-approved Products and Services

To meet the ia-5(15): gsa-approved products and services requirement, you must ensure that every identity, credential, and access management (ICAM) product or service in scope is General Services Administration (GSA)-approved, and you can prove it with procurement and architecture evidence. Operationalize this by building an ICAM inventory, verifying GSA approval status, blocking non-approved options, and documenting exceptions. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Key takeaways:

• Treat this as a procurement-and-architecture control: approval status must be verified before purchase and before deployment. (NIST SP 800-53 Rev. 5 OSCAL JSON)
• Scope includes the whole ICAM stack (IdP, MFA, certificates, PAM, credential services), not just user logins. (NIST SP 800-53 Rev. 5 OSCAL JSON)
• Evidence matters: keep a traceable chain from requirement → approved product/service → implemented configuration → recurring review. (NIST SP 800-53 Rev. 5 OSCAL JSON)

IA-5(15) is a straightforward requirement with a common failure mode: teams buy or implement identity and access tools because they “work,” then scramble to prove those tools were GSA-approved after an assessment starts. The control language is short, but the operational surface area is not. ICAM touches workforce identity, privileged access, customer-facing authentication (in some architectures), service accounts, certificates, and the systems that issue or validate credentials.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to convert IA-5(15) into two enforceable gates: (1) a procurement gate that prevents acquisition of non-approved ICAM products and services, and (2) a change/architecture gate that prevents deployment of non-approved ICAM components even if they were previously purchased. You also need an evidence package that an assessor can follow without interpretation: what is in scope, what is approved, where it’s deployed, and who revalidates approval status over time. (NIST SP 800-53 Rev. 5)

This page gives you requirement-level guidance you can put into a control procedure, a checklist for reviews, and an audit-ready evidence plan. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Regulatory text

Requirement (verbatim): “Use only General Services Administration-approved products and services for identity, credential, and access management.” (NIST SP 800-53 Rev. 5 OSCAL JSON)

What the operator must do:

1. Define which products and services count as ICAM in your environment.
2. For each in-scope ICAM component, verify it is GSA-approved before it is bought, renewed, or deployed.
3. Prevent non-approved ICAM products/services from being introduced through procurement, third-party relationships, or engineering “shadow IT.”
4. Maintain proof of approval and a repeatable review cadence so your “approved” list stays current. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Plain-English interpretation

IA-5(15) requires a hard boundary: if a tool or service performs identity, credential, or access management functions, you cannot use it unless it is GSA-approved. This is less about how strong your authentication is (that’s covered elsewhere in the IA family) and more about whether the government-recognized approval channel has been followed for the specific ICAM products/services you depend on. (NIST SP 800-53 Rev. 5 OSCAL JSON)

In practice, assessors will look for two things:

• A complete ICAM bill of materials (what you use).
• Objective evidence of GSA approval tied to each item, plus a mechanism that prevents drift. (NIST SP 800-53 Rev. 5)

Who it applies to (entity and operational context)

This requirement commonly applies in these contexts:

• Federal information systems implementing NIST SP 800-53 controls as part of their security program. (NIST SP 800-53 Rev. 5)
• Contractor systems handling federal data where NIST SP 800-53 is flowed down contractually or via an authorization boundary that includes contractor-operated components. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Operationally, it applies to functions and teams that can introduce ICAM capabilities:

• IAM/Directory Services owners (IdP, SSO, federation)
• Security Engineering (MFA, risk-based auth, conditional access)
• PKI/certificate services owners (issuing, validating, lifecycle)
• Privileged Access Management (vaulting, session brokering)
• HR/Joiner-Mover-Leaver processes that create/modify identities
• Procurement and third-party risk teams that contract for managed identity services (NIST SP 800-53 Rev. 5)

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

Step 1: Set the scope boundary for “ICAM”

Create an ICAM scope statement that names the categories you treat as in-scope. Use categories that match how your environment is built, for example:

• Identity provider / directory services
• Authentication (MFA, passwordless, OTP, push)
• Federation/SSO components
• Credential issuance and validation (certificates, smart cards, derived credentials)
• Access governance / lifecycle (provisioning, deprovisioning, access reviews)
• Privileged access tooling (vault, elevation workflows, session recording)
• Managed identity services operated by a third party (NIST SP 800-53 Rev. 5 OSCAL JSON)

Deliverable: ICAM Scope Statement mapped to system boundaries and owners.

Step 2: Build an ICAM product-and-service inventory

For each in-scope component, record:

• Product/service name and edition/plan
• Provider (internal, cloud service provider, managed service provider, other third party)
• Where it is deployed (systems, enclaves, tenants)
• What control function it performs (IdP, MFA, PAM, PKI, etc.)
• Procurement record (purchase order, contract, task order) and renewal date
• Control owner and technical owner (NIST SP 800-53 Rev. 5)

Deliverable: ICAM Inventory Register (spreadsheet, GRC system object, or CMDB view).

Step 3: Verify “GSA-approved” status and record proof

IA-5(15) hinges on an attribute: “GSA-approved.” The operational requirement is to verify and retain proof for each ICAM item. Your procedure should require:

• A check performed by procurement/GRC or an assigned control owner before purchase and before deployment
• A recorded evidence artifact tied to the specific product/service and version/plan you are using
• A decision record for edge cases (bundled suites, resellers, managed services) (NIST SP 800-53 Rev. 5 OSCAL JSON)

Deliverable: GSA Approval Evidence Pack per ICAM component (see “Required evidence” section).

Step 4: Put enforcement gates in the workflow (so the control runs itself)

Build two gates that stop non-approved ICAM tools from entering production:

A) Procurement gate

• Update purchasing intake forms: any request that matches ICAM scope must include “GSA-approved?” and attach evidence.
• Route ICAM purchases to a required approver (control owner + procurement).
• Add contract language for third parties providing ICAM functions: they must use only GSA-approved products/services for those functions, and provide evidence on request. (NIST SP 800-53 Rev. 5)

B) Architecture/change gate

• Add an ICAM check to architecture review and change management: “Does this introduce or change an ICAM component? If yes, is it on the approved list with evidence?”
• For CI/CD and IaC, define “restricted technologies” rules where feasible: if an engineering team attempts to deploy a non-approved ICAM service, require explicit exception approval. (NIST SP 800-53 Rev. 5)

Deliverable: Updated procurement SOP + architecture/change checklist referencing IA-5(15).

Step 5: Manage exceptions explicitly (and treat them as time-bound risk)

IA-5(15) is written as “use only,” so exceptions should be rare and defensible. If an exception is unavoidable (legacy contract, urgent mission need), require:

• Documented rationale
• Compensating controls (what reduces risk while you transition)
• A migration plan to a GSA-approved alternative
• Formal sign-off by an accountable risk owner (NIST SP 800-53 Rev. 5)

Deliverable: IA-5(15) Exception Register with status and closure criteria.

Step 6: Revalidate and monitor drift

Build a lightweight recurring review so approval status and inventory stay current:

• Reconfirm the ICAM inventory reflects production reality (new apps often introduce auth components indirectly).
• Revalidate approval evidence upon renewal, major version change, or provider change.
• Validate third-party attestations for managed identity services as part of third-party reviews. (NIST SP 800-53 Rev. 5)

Deliverable: Recurring control operation record (tickets, meeting notes, review sign-offs).

Required evidence and artifacts to retain

Assessors want traceability. Keep artifacts that connect the dots:

Core artifacts (minimum set)

• ICAM Scope Statement (what counts as ICAM in your environment) (NIST SP 800-53 Rev. 5)
• ICAM Inventory Register with owners and deployment locations (NIST SP 800-53 Rev. 5)
• Approved ICAM Products/Services List with review date and approver
• GSA approval evidence per item (file, screenshot, letter, listing reference, or procurement documentation that shows approval status) (NIST SP 800-53 Rev. 5 OSCAL JSON)
• Procurement SOP / intake form showing the approval gate
• Architecture/change checklist showing the deployment gate
• Exception Register with approvals and remediation plan (if any exceptions exist)

Helpful supporting evidence

• System security plan (SSP) excerpts where ICAM components are described
• CMDB exports or cloud inventory screenshots tying products/services to environments
• Third-party contract clauses and third-party due diligence records for managed ICAM services (NIST SP 800-53 Rev. 5)

Common exam/audit questions and hangups

Expect these questions from auditors/assessors:

1. “Show me your ICAM inventory. How do you know it is complete?” (NIST SP 800-53 Rev. 5)
2. “For each ICAM component, show objective evidence it is GSA-approved.” (NIST SP 800-53 Rev. 5 OSCAL JSON)
3. “How do you prevent a team from buying or deploying a non-approved identity tool?” (NIST SP 800-53 Rev. 5)
4. “Do third parties perform any ICAM functions for you? If yes, how do you ensure they only use GSA-approved products/services?” (NIST SP 800-53 Rev. 5)
5. “What happens when the product changes licensing tiers, major versions, or moves to a different hosting model?” (NIST SP 800-53 Rev. 5)

Hangups that slow teams down:

• Unclear definition of “ICAM” leading to under-scoping (for example, forgetting PAM or certificate services).
• “Approval” evidence exists but is not tied to the exact plan/version used.
• Managed services: the provider’s tooling choices are opaque unless the contract forces disclosure. (NIST SP 800-53 Rev. 5)

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	How to avoid it
Treating IA-5(15) as an IAM team-only issue	Procurement and engineering can introduce ICAM components without IAM involvement	Put gates in procurement and change management, not just in IAM runbooks (NIST SP 800-53 Rev. 5)
Keeping a “preferred tools” list without proof	A preference list is not approval evidence	Attach approval evidence per tool and require revalidation on changes (NIST SP 800-53 Rev. 5 OSCAL JSON)
Ignoring third-party ICAM	Managed SSO/MFA or helpdesk identity workflows can fall in scope	Add contract clauses and due diligence checks for ICAM-related third parties (NIST SP 800-53 Rev. 5)
Allowing “temporary” exceptions to live forever	The environment drifts out of compliance	Time-bound exceptions with owners, milestones, and closure requirements (NIST SP 800-53 Rev. 5)

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should assume assessment risk rather than enforcement-driven penalties. The practical risk is authorization friction: if you cannot demonstrate “GSA-approved” status for ICAM components, you can face control findings that delay ATO decisions, renewals, or contract outcomes tied to NIST SP 800-53 alignment. (NIST SP 800-53 Rev. 5)

A practical 30/60/90-day execution plan

Use this as an operator’s rollout sequence. Adjust to your governance model and system boundaries.

First 30 days: Establish control ownership and get inventory coverage

• Assign a control owner (GRC) and technical owner (IAM/security engineering).
• Publish ICAM scope categories and owners.
• Produce the first ICAM inventory from CMDB, cloud consoles, SSO app catalogs, PAM admin consoles, and procurement records.
• Identify unknowns and gaps (items with missing owner, missing evidence, unclear approval status). (NIST SP 800-53 Rev. 5)

By 60 days: Verify approval status and install gates

• Collect and store approval evidence for each in-scope item; flag anything that cannot be proven.
• Stand up the approved ICAM list and require it for new purchases.
• Update procurement intake and approval routing for ICAM-tagged requests.
• Add an IA-5(15) check to architecture review and change control. (NIST SP 800-53 Rev. 5 OSCAL JSON)

By 90 days: Close gaps and operationalize recurring reviews

• Remediate non-approved items: replace, retire, or move under a documented exception with a migration plan.
• Update third-party contracts or statements of work where third parties deliver ICAM functions.
• Run the first recurring review cycle and record results.
• Prepare an assessor-ready evidence package that maps IA-5(15) → inventory → approvals → gates → exceptions. (NIST SP 800-53 Rev. 5)

How Daydream fits (without adding process overhead)

Most teams fail IA-5(15) on evidence consistency, not intent. Daydream can act as the control system of record: map IA-5(15) to a named owner, link the implementation procedure, and schedule recurring evidence collection tied to each ICAM component so you can answer “show me proof” requests quickly. (NIST SP 800-53 Rev. 5 OSCAL JSON)

Frequently Asked Questions

Does IA-5(15) apply to cloud identity services (IdP/MFA) or only on-prem products?

It applies to identity, credential, and access management products and services, regardless of hosting model. Treat SaaS IdP, MFA, PAM, and certificate services as in scope if they perform ICAM functions. (NIST SP 800-53 Rev. 5 OSCAL JSON)

What counts as “GSA-approved” evidence in an audit?

Keep objective documentation that the specific product/service is GSA-approved, tied to the plan/version you use, plus procurement records showing you acquired that specific offering. The key is traceability from the requirement to the deployed component. (NIST SP 800-53 Rev. 5 OSCAL JSON)

If a third party runs our helpdesk and resets passwords, does IA-5(15) apply?

It can, if the third party provides ICAM-related services or operates tools that manage credentials or access. Contract terms should require only GSA-approved ICAM products/services for those functions and allow you to request proof. (NIST SP 800-53 Rev. 5)

We inherited an identity tool that may not be GSA-approved. What’s the least painful path?

Inventory it, confirm approval status, and if you cannot prove approval, open a formal exception with an accountable owner and a migration plan to an approved alternative. Avoid informal “temporary” acceptance without a closure mechanism. (NIST SP 800-53 Rev. 5)

How do we keep the ICAM inventory from going stale?

Tie the inventory to two triggers: procurement intake for anything ICAM-scoped, and change/architecture reviews for any auth, federation, PAM, or credential lifecycle change. Run recurring reviews and store the sign-off. (NIST SP 800-53 Rev. 5)

Can we satisfy IA-5(15) with a policy statement alone?

No. You need operational proof that only GSA-approved ICAM products/services are in use, plus workflow controls that prevent non-approved introductions. Policy is supporting evidence, not the control operation. (NIST SP 800-53 Rev. 5 OSCAL JSON)