MA-3: Maintenance Tools

MA-3 sits in the Maintenance (MA) control family in NIST SP 800-53 Rev. 5 and focuses on a common failure path: powerful maintenance tools get installed broadly, shared casually, and executed without strong oversight. In practice, “maintenance tools” includes endpoint admin utilities, remote support agents, infrastructure automation modules, hypervisor tools, firmware update utilities, database admin tools, and network device management suites. These tools are often privileged by default, and they can bypass normal change control if you do not design guardrails.

The control’s core expectation is operational: you can show which tools are approved, prove you restrict their use to authorized personnel and authorized systems, and demonstrate you monitor and review activity. Assessors typically test this by picking a few tools (for example, remote admin agents and patching tools), tracing approvals, validating technical controls (least privilege, MFA, segmentation, allowlisting), and sampling logs to confirm monitoring and follow-up.

This page gives requirement-level implementation guidance you can execute quickly: scoping, ownership, step-by-step rollout, evidence to retain, and the audit questions you will get. Primary sources: NIST SP 800-53 Rev. 5 and the OSCAL catalog entry for MA-3. ¹

Regulatory text

Requirement excerpt: “Approve, control, and monitor the use of system maintenance tools; and” ²

What the operator must do

You must implement a control system where:

1. Approve: maintenance tools are explicitly authorized before use (not “whoever needs it can install it”).
2. Control: technical and administrative controls prevent unapproved tools or unauthorized users from performing maintenance.
3. Monitor: you record and review maintenance tool activity so you can detect misuse and show accountability.

Treat “approve, control, monitor” as three separate testable outcomes. If you only have a policy statement but cannot show enforcement and logs, MA-3 will fail during an assessment. ¹

Plain-English interpretation of the requirement

Maintenance tools are the “keys to the kingdom.” MA-3 expects you to decide which keys exist, who can hold them, and how you will notice if someone uses them in the wrong place or at the wrong time.

A practical interpretation you can operationalize:

• You keep an allowlist of approved maintenance tools for each system boundary.
• You block or tightly restrict everything else via endpoint controls, application allowlisting, privileged access management, and configuration management.
• You log and review tool use (execution, sessions, commands where feasible) and tie activity back to an individual, a ticket/approval, and a business purpose.

Who it applies to (entity and operational context)

MA-3 commonly applies where NIST SP 800-53 is in scope, including:

• Federal information systems implementing NIST SP 800-53 controls. ³
• Contractor systems handling federal data, where 800-53 controls are flowed down contractually or used as the control baseline. ³

Operationally, MA-3 matters most for:

• Systems administered by central IT, SRE, platform engineering, and security operations.
• Environments with third-party maintenance (MSPs, data center support, OEM field engineers).
• Cloud and hybrid estates where maintenance is performed via agents, API keys, and automation pipelines.

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

Step 1: Define scope and ownership (make it assessable)

Create a one-page “MA-3 control sheet” for each system boundary (or for a shared services boundary), covering:

• Control owner (IT Ops, Security Engineering, or Platform team)
• In-scope platforms (endpoints, servers, network devices, cloud accounts)
• In-scope tool categories (remote access, patching, config management, DB admin, network admin)
• How approvals work and where evidence lives

This mapping step is a fast way to prevent the most common gap: “we do it, but can’t prove it.” ²

Step 2: Build an approved maintenance tools inventory (allowlist)

Create and maintain a register with, at minimum:

• Tool name, publisher, and versioning approach
• Tool purpose and supported platforms
• Who may use it (roles/groups)
• Where it may run (system groups, subnets, management network)
• Approval date, approver, and review cadence
• Logging sources (SIEM index, EDR telemetry, tool-native logs)

Operational tip: separate “approved for enterprise” from “approved for this system boundary.” A tool can be approved in general but prohibited on regulated enclaves.

Step 3: Put approval into a workflow (ticket-based)

Implement a workflow that produces durable evidence:

• Request includes business justification, systems, access level, and time window
• Security review for elevated tools (remote admin, credential dumping risk, firmware tools)
• Approval recorded in a system of record (ITSM or GRC)
• Tool installation and access provisioning tied back to the ticket

If you need an emergency path, define it explicitly (who can authorize, what logs are required, and post-approval review expectations).

Step 4: Enforce control technically (don’t rely on policy)

Match the enforcement pattern to the environment:

Endpoints and servers

• Application allowlisting / execution control to block unapproved binaries and scripts
• EDR policy to flag “dual-use” admin tools
• Privileged access via just-in-time group membership, MFA, and strong identity proofing
• Disable local admin by default; use role-based admin

Network and infrastructure

• Admin access only from a management network or hardened jump host
• Separate admin accounts; no shared credentials
• Restrict admin tool protocols (SSH, WinRM, RDP) to authorized sources
• Protect automation credentials (vaulting, scoped tokens)

Third-party maintenance

• Contractual requirement: only approved tools, approved versions, and approved remote access methods
• Named accounts and MFA
• Session recording where feasible
• Time-boxed access with explicit approvals

The test to apply: “Can an unapproved tool run, or an unauthorized person use an approved tool, without being blocked or detected?” If the answer is yes, tighten controls.

Step 5: Monitor and review maintenance tool use (make it observable)

Monitoring should answer three questions: who, what, where/when.

Minimum monitoring design:

• Centralize logs for privileged logins, remote sessions, tool execution events, and configuration changes
• Alert on new tool installation, new services, new scheduled tasks, and unusual remote admin patterns
• Periodically review a sample of maintenance sessions and match them to tickets/changes

Make the review output concrete: a dated review record with findings and follow-ups. Assessors look for evidence that someone actually reviews activity, not just that logs exist.

Step 6: Validate control operation (continuous, not one-time)

Build recurring checks into normal operations:

• Quarterly (or your chosen cadence) review of the approved tools list for deprecations and unauthorized additions
• Access recertification for admin groups that can run maintenance tools
• Verification that logging is still enabled after upgrades or migrations
• Tabletop for third-party maintenance access failures and emergency maintenance

Step 7: Use Daydream to keep MA-3 evidence “always ready” (optional but practical)

Many teams fail MA-3 due to scattered evidence (ITSM approvals in one place, EDR screenshots in another, SIEM queries in someone’s notes). Daydream can act as the system to:

• Map MA-3 to a named control owner and a written implementation procedure
• Define recurring evidence artifacts (tool allowlist export, access review records, SIEM log samples)
• Track due dates and maintain an audit-ready evidence trail aligned to MA-3 expectations ²

Required evidence and artifacts to retain

Use this as your MA-3 evidence checklist:

Evidence artifact	What it proves	Good enough for audits/exams
Approved maintenance tools inventory (allowlist)	“Approve” is real and bounded	Export with date, owner, approvals
Tool approval tickets/records	Formal authorization	Ticket IDs, approver, scope, date
Access control configuration	“Control” is enforced	IAM group mappings, PAM policies, jump host rules
Installation/deployment records	Controlled distribution	Software deployment logs, CMDB entries
Logging configuration + sample logs	“Monitor” exists	SIEM queries + screenshots or exported events
Periodic review records	Ongoing oversight	Dated review notes, findings, remediation tickets
Third-party access documentation	External maintenance is controlled	Contracts/clauses, access requests, session logs

Common exam/audit questions and hangups

Expect these questions:

1. “Show me the approved maintenance tools list for this system.”
   Hangup: you have a generic enterprise list, not system-scoped.

2. “How do you prevent unapproved tools from being installed or executed?”
   Hangup: relying on “only admins can install” without execution control or monitoring.

3. “Prove that maintenance tool activity is monitored and reviewed.”
   Hangup: logs exist, but no review cadence, no reviewer, no retained outputs.

4. “How do you manage third-party maintenance tools and remote access?”
   Hangup: vendors use their own remote tools without documented approval.

5. “How do you ensure accountability?”
   Hangup: shared admin accounts or shared remote access credentials.

Frequent implementation mistakes and how to avoid them

• Mistake: Treating patching tools as “not maintenance tools.”
  Fix: include patching, configuration management, and remote support agents in scope; document why anything is excluded.

• Mistake: Approving a tool once and never reviewing versions/agents.
  Fix: record versioning approach (auto-update vs pinned) and add a recurring review.

• Mistake: Allowlisting tools but not controlling execution paths.
  Fix: pair the allowlist with EDR execution controls or application allowlisting, plus least privilege.

• Mistake: Monitoring only authentication events, not tool actions.
  Fix: collect tool-native logs where possible and correlate sessions to tickets.

• Mistake: Third parties bypass your standards.
  Fix: contract language plus technical enforcement (jump hosts, MFA, named accounts, time-boxed access).

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for MA-3, so this page does not cite enforcement actions.

Operational risk remains straightforward:

• Maintenance tools can enable unauthorized change, data access, persistence, and lateral movement if misused.
• Weak approvals and missing monitoring create an “invisible admin channel,” which drives incident response cost and complicates forensic timelines.
• Auditors commonly treat MA-3 gaps as control operation failures because evidence is easy to test: tool lists, access, and logs.

Practical 30/60/90-day execution plan

First 30 days (stabilize and define)

• Name a control owner and publish an MA-3 procedure for the in-scope environment.
• Inventory maintenance tools already present (agents, remote tools, admin utilities).
• Stand up an approved tools register with initial approvals for what is already deployed.
• Identify “highest-risk” tools (remote support, domain admin tooling, firmware utilities) for immediate tightening.

Days 31–60 (enforce and instrument)

• Implement technical blocks for unapproved tools where feasible (EDR policy or allowlisting).
• Move privileged maintenance access behind MFA and a jump host for sensitive systems.
• Centralize logs for privileged sessions and maintenance actions into the SIEM.
• Implement a ticket workflow for new tools and for elevated maintenance sessions.

Days 61–90 (prove operation and make it repeatable)

• Run the first formal review: sample maintenance events, match them to approvals/tickets, record findings.
• Complete access recertification for admin groups that can run maintenance tools.
• Add third-party maintenance controls (named accounts, time-boxed access, session logging) and document approvals for their tools.
• Put evidence collection on a calendar and assign backups so the control survives staff changes.

Frequently Asked Questions

What counts as a “maintenance tool” under MA-3?

Any tool that can administer, diagnose, repair, configure, or update systems in a way that could change security posture or system state. That includes remote admin agents, patching/config management tools, hypervisor consoles, database admin tools, and network management utilities.

Do we need to block every unapproved tool technically, or is a policy enough?

MA-3 requires you to “control” use, so policy-only approaches are fragile in assessments. Pair policy with technical enforcement (least privilege, allowlisting/EDR controls, jump hosts) and monitoring evidence. ²

How do we handle emergency maintenance without breaking MA-3?

Define an emergency approval path with a clear approver, a ticket created at the time of action (or immediately after), and post-event review with retained logs. Document the exception process so the emergency path still produces evidence.

We allow a third party to maintain a system. Do their tools fall under MA-3?

Yes. If a third party performs maintenance in your environment, you still need approved tools, controlled access, and monitoring. Handle this with contract terms plus technical controls like named accounts, MFA, and jump hosts.

What evidence is most persuasive to an auditor for “monitor”?

A dated log review record tied to SIEM queries or exported events, plus a short list of investigated items and resulting tickets. Auditors want to see that logs are reviewed and acted on, not just collected.

How can we keep MA-3 evidence from becoming a quarterly scramble?

Standardize the artifact list (tool register export, access review output, SIEM log samples) and assign owners with recurring tasks. Tools like Daydream help by mapping MA-3 to owners, procedures, and recurring evidence artifacts in one place. ²

Footnotes

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

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

3. NIST SP 800-53 Rev. 5