IA-8(3): Use of FICAM-approved Products

To meet the ia-8(3): use of ficam-approved products requirement, you must ensure any identity authentication for non-organizational users that relies on FICAM (for example, PIV/CAC-derived trust paths) uses FICAM-approved products and you can prove it with procurement, configuration, and system evidence mapped to the control. ¹

Key takeaways:

• Scope the authentication paths where FICAM applies, then standardize on FICAM-approved components for those paths. ¹
• Operationalize through architecture decisions, procurement controls, and configuration baselines, not just policy language. ²
• Evidence is the failure point; retain product approval proof plus implementation traces tied to the systems in scope. ¹

IA-8 is the NIST SP 800-53 family area that covers Identification and Authentication (Non-Organizational Users). Enhancement IA-8(3) focuses narrowly on a practical expectation: if your system supports authentication methods governed by the Federal Identity, Credential, and Access Management (FICAM) approach, you must rely on FICAM-approved products for the pieces that perform that authentication.

For a CCO or GRC lead, the fastest path is to treat IA-8(3) like a “controlled bill of materials” requirement for identity: (1) identify where FICAM-relevant authentication is offered or accepted, (2) lock the technology choices to approved products, and (3) produce assessment-ready evidence that the deployed products and configurations match what you claimed.

This page is written to help you operationalize the ia-8(3): use of ficam-approved products requirement quickly: ownership, scoping, build-and-buy decisions, implementation steps, and the artifacts auditors ask for. Control intent and wording come from NIST SP 800-53 Rev. 5. ²

Regulatory text

Requirement: “NIST SP 800-53 control IA-8.3.” ¹

Operator interpretation of the text: IA-8(3) is the enhancement titled “Use of FICAM-approved Products.” In practice, this means: when you implement identification and authentication for non-organizational users in a way that depends on FICAM expectations, you select and deploy products that are recognized as FICAM-approved for that function, and you can demonstrate that selection and deployment during an assessment. ¹

What examiners are looking for is not a generic statement like “we support PIV.” They want evidence that the products in the authentication chain (issuance/validation, certificate path validation, middleware, gateways, IdP components, or cryptographic modules as applicable) are approved where FICAM approval is required, and that your system actually uses them. ²

Plain-English interpretation (what this requires)

You must not build a custom or ad-hoc FICAM-integrated authentication flow with unapproved components. If your system accepts FICAM-style credentials or trust relationships for external users, your architecture must anchor on products that meet the FICAM approval bar for the relevant role, and your change/procurement processes must prevent drift. ¹

A practical way to say it internally:

• “If we claim FICAM alignment, then the authentication products we deploy for that path must be FICAM-approved.”
• “If we don’t use FICAM at all for non-org users, we document that decision and keep the boundary clear.”

Who it applies to (entity and operational context)

IA-8(3) commonly applies to:

• Federal information systems implementing NIST SP 800-53 controls. ²
• Contractor systems handling federal data where 800-53 is flowed down via contract, ATO boundary, or agency requirement. ²

Operational contexts where this shows up in real programs:

• Public-facing or partner-facing systems where non-employees authenticate.
• Systems that accept federated identity from government or other external identity providers.
• Any environment where a team claims support for PIV/CAC or FICAM-aligned authentication as a compliance feature.

If you are a SaaS provider, the boundary question matters: do you authenticate non-org users directly, or do you rely on an upstream IdP owned by a customer agency? Your responsibilities differ, but assessors will still ask what products you operate and whether those products are approved for the role you play. ²

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

1) Assign a control owner and define scope boundaries

• Owner: Usually Identity & Access Management (IAM) lead or Security Architecture; GRC coordinates evidence.
• Systems in scope: List applications/APIs where non-org users authenticate, including admin portals and support access.
• Authentication paths in scope: Interactive login, API auth, step-up auth, remote access, and federation endpoints.

Deliverable: a short “IA-8(3) scope statement” that names the systems and the auth methods accepted. ²

2) Identify where FICAM approval is required in your architecture

Create an authentication architecture map and label the components:

• Credential types accepted (for example, smart card-based credentials if applicable)
• Trust anchors / certificate validation services
• IdP / federation services
• MFA services, if tied to the FICAM path
• Cryptographic modules used in the validation chain, if relevant to your design

Your goal is to isolate the components that must be “FICAM-approved products” for the claim you are making. ¹

3) Build an approved product list and lock procurement to it

Create a governed list:

• Product name, version, and role (IdP, gateway, validation service, middleware)
• Proof the product is FICAM-approved (record the authoritative proof your program relies on)
• Internal owner and lifecycle status (approved, deprecated, replacement planned)

Then implement a procurement gate:

• Security review required for any new authentication product
• Contract language that requires maintaining approval status (where applicable)
• Third party due diligence package for the identity provider or managed service

This is where Daydream fits naturally: use Daydream to map IA-8(3) to an owner, an implementation procedure, and a recurring evidence list so you can show consistent operation across systems and renewals. ¹

4) Implement configuration baselines that demonstrate actual use

Policy is not enough. You need deployment proof:

• Configuration standards for federation endpoints and certificate validation settings
• Baseline templates (IaC where possible) that instantiate the approved product configuration
• Change control requiring security sign-off if the auth chain changes

Practical check: in the running system, can you show the component that performs the FICAM-relevant validation and prove it is the approved product you declared? ²

5) Add continuous controls to prevent drift

Embed checks into operations:

• CMDB/asset inventory tagging of authentication components
• Quarterly (or event-driven) review of IdP/auth components against the approved list
• Monitoring alerts for configuration changes to federation/certificate validation settings
• Vendor/third party reassessment triggers when versions or service delivery models change

6) Document compensating boundaries (when you do not operate the FICAM component)

If the customer agency handles the IdP and you only consume assertions:

• Document the shared responsibility boundary
• Document what you control (SP configuration, allowed IdPs, certificate pinning/trust configuration)
• Document what you do not control and how you obtain assurance (contract terms, customer attestations, integration test evidence)

Assessors usually accept shared-responsibility narratives only if you can show a clean system boundary and operational controls around it. ²

Required evidence and artifacts to retain

Keep evidence tied to each system in scope:

Governance & design

• IA-8(3) control implementation statement (system-specific)
• Authentication architecture diagram with components labeled
• Approved product list with ownership and review cadence

Procurement & third party

• Purchase records or contracts showing the selected product/service
• Third party due diligence packet for managed identity services (SOC reports, security addenda, change notification clauses), as applicable

Technical implementation

• Configuration exports or screenshots for federation/certificate validation settings
• Build pipeline artifacts (IaC repos, deployment manifests) showing the product/version
• System inventory/CMDB entries mapping hosts/services to the approved product

Operations

• Change tickets for auth-related changes with security approval
• Periodic review logs confirming continued use of approved products
• Exceptions register (if any) with risk acceptance and remediation plan

The most common gap is having a policy statement but no system-level traceability from “approved product” to “running configuration.” ¹

Common exam/audit questions and hangups

Expect these questions:

1. “Show me which non-organizational users exist and how they authenticate.”
   Have a user population matrix: public users, partners, contractors, customers, support personnel.

2. “Which products are FICAM-approved in your flow?”
   Have the approved list and your proof package ready, plus the architecture map.

3. “Prove the deployed system uses that product/version.”
   Bring config exports, inventory data, and deployment records tied to the environment under assessment.

4. “What happens when the product changes, gets upgraded, or the service provider changes?”
   Point to change control, reassessment triggers, and a review record. ²

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Treating IA-8(3) as a policy-only control	Assessors test operational reality	Pair policy with config evidence and inventory mapping 2
No clear scope for “non-organizational users”	You can miss partner/admin access paths	Maintain a population-based auth matrix per system
Approval evidence lives in email	Evidence gets lost at renewal/ATO	Store approval proof in your GRC evidence repository with ownership
Product is approved, but configuration breaks the intended trust model	“Approved product” is not the same as “approved implementation”	Add baseline configs, change gates, and periodic checks 2
Shared-responsibility claims without boundary controls	“Customer handles it” is not evidence	Document boundaries and keep SP-side controls and test records

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. ¹

Practical risk to manage anyway:

• ATO and contract risk: If you claim FICAM alignment but cannot show approved products and operational evidence, you risk audit findings, delayed authorizations, or contractual noncompliance outcomes tied to control failures. ²
• Security risk: Non-approved or poorly governed authentication components can weaken external identity assurance and increase exposure to impersonation or assertion forgery in federated flows.

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

Use phases so you can move without inventing schedule guarantees.

Immediate (stabilize scope and ownership)

• Assign control owner and named backup.
• Identify systems where non-org users authenticate.
• Produce a one-page architecture map per system showing the auth chain.
• Start an evidence folder per system (policy statement + initial diagrams). ²

Near-term (standardize products and lock procurement/change)

• Build the approved product list and require it for new work.
• Update procurement/security review checklists to include IA-8(3) approval checks.
• Implement configuration baselines for the authentication chain.
• Add change-control hooks for auth and federation changes. ¹

Ongoing (operate and prove)

• Schedule periodic reviews of deployed components versus the approved list.
• Refresh evidence after upgrades and renewals.
• Track exceptions with expiration dates and remediation owners.
• Use Daydream (or your GRC system) to keep IA-8(3) mapped to owner, procedure, and recurring evidence so audits become a retrieval task, not a scramble. ¹

Frequently Asked Questions

Does IA-8(3) apply if only employees use the system?

IA-8 is scoped to non-organizational users, so if your system truly has no external/partner/customer users, document that and keep evidence of the user population and access model. If any external access exists (including admin support), reassess scope. ²

What counts as a “FICAM-approved product” for IA-8(3)?

IA-8(3) requires using products that meet FICAM approval expectations for the role they play in authentication. Operationally, keep the authoritative approval proof you rely on and tie it to the deployed product/version in each system boundary. ¹

We use a third-party identity provider. Are we still responsible?

Yes, for what you operate and for how you govern third parties in your authentication chain. If the IdP is external, document the shared responsibility boundary, retain third party assurance artifacts, and keep configuration evidence for your service-provider (SP) side. ²

Is enabling PIV/CAC login enough to satisfy IA-8(3)?

Not by itself. You must show that the products in the validation/federation chain are FICAM-approved where required and that the running system uses those products as configured. ²

What evidence do assessors typically reject?

Vague policy statements, screenshots without system identifiers, and “approval” claims without durable proof tied to a specific product and version. Provide traceability from requirement → product selection → deployment configuration → operations/change records. ¹

How do we handle exceptions if an approved product is not available for a legacy system?

Put the exception in a formal register with an owner, rationale, compensating controls, and a remediation plan. Keep it system-specific and re-review it on a defined cadence through your governance process. ²

Footnotes

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

2. NIST SP 800-53 Rev. 5