MA-3(6): Software Updates and Patches

MA-3(6) requires you to inspect every maintenance tool that can touch production systems (e.g., remote support agents, patch tools, firmware updaters) and verify it has current software updates and patches installed before it’s used. Operationalize it by maintaining an inventory of maintenance tools, defining an inspection cadence and trigger events, and keeping proof of patch status and approvals. ¹

Key takeaways:

• Scope “maintenance tools” broadly: anything used to diagnose, administer, repair, patch, image, or remotely access systems.
• Build a repeatable inspection workflow: inventory → baseline → verify patch state → approve/deny use → retain evidence.
• Auditors look for proof of execution, not just a policy: logs, screenshots/exports, tickets, and exceptions with risk acceptance.

The ma-3(6): software updates and patches requirement is a targeted control enhancement: it is not asking you to patch all systems (that’s covered elsewhere), it is asking you to patch the tools used to perform maintenance. Those tools are high-risk because they often run with elevated privileges, bypass normal user controls, and create a direct path into sensitive environments. If the tool is outdated, the maintenance channel becomes an attacker’s easiest entry point.

For a Compliance Officer, CCO, or GRC lead, the fastest way to make MA-3(6) real is to treat maintenance tools like “privileged supply chain software.” You need: (1) a complete list of tools and where they are installed, (2) a defined inspection method that validates patch/update status, (3) a rule that blocks or removes noncompliant tools, and (4) evidence that the process runs on schedule and before tools are used.

This page gives requirement-level implementation guidance you can hand to IT operations, security engineering, and internal audit, with concrete artifacts to collect and common exam traps to avoid, mapped to NIST SP 800-53 Rev. 5 expectations. ²

Regulatory text

Requirement (excerpt): “Inspect maintenance tools to ensure the latest software updates and patches are installed.” ¹

Operator meaning: You must actively verify that maintenance tools are up to date, and you must be able to prove it. “Inspect” implies more than a written standard; it implies a performed check using a repeatable method, with results captured. “Maintenance tools” includes software and software-enabled devices used to maintain systems (local or remote). “Latest” should be defined in your environment as a measurable standard (for example, vendor-supported version plus current security patches) so teams know what “pass/fail” means.

Plain-English interpretation (what MA-3(6) is really testing)

MA-3(6) tests whether your organization prevents outdated maintenance tooling from becoming a privileged backdoor. In practice, assessors want to see that:

• You know what maintenance tools exist in your environment.
• You verify their patch/update state before they’re used (and periodically thereafter).
• You stop or tightly control tools that are not current.
• You can produce evidence quickly. ¹

Who it applies to

Entity scope

MA-3(6) is most commonly applied in environments aligned to NIST SP 800-53, including:

• Federal information systems
• Contractor systems handling federal data ¹

Operational scope (where the control “lives”)

This requirement typically sits at the intersection of:

• IT Operations (endpoint management, server teams)
• Security Operations / Vulnerability Management
• Identity & Access (because many tools are privileged)
• Third-party risk / supplier management (if external parties bring tools)
• Change management (if tools are updated under change control)

Tool scope (examples you should include)

Build your scope around capabilities, not brand names:

• Remote access/support tools (installed agents, portable executables, jump clients)
• Patch management consoles and deployment agents
• Configuration management tooling
• Imaging and provisioning tools
• Firmware update utilities
• Diagnostic tools used with admin rights
• Maintenance laptops and “break glass” USB toolkits
• Admin browser extensions used for device management
• Third-party field service tools used onsite or over VPN

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

Step 1: Assign ownership and write the control statement (make it auditable)

• Control owner: usually IT Security (vuln management) or IT Ops (endpoint/server platform), with GRC accountable for evidence quality.
• Control statement (example): “The organization inspects all maintenance tools prior to use and on a defined cadence to confirm current vendor updates and patches are installed; noncompliant tools are blocked, updated, or formally excepted with documented risk acceptance.” ¹

Tip: Put the owner, cadence, inspection method, and evidence outputs in the procedure, not just the policy. Auditors ask for the runbook.

Step 2: Create and maintain an inventory of maintenance tools

Minimum fields to track:

• Tool name and type (remote support, patching, imaging, firmware, diagnostics)
• Deployment model (installed agent, portable executable, SaaS console, appliance)
• Locations (which endpoints/servers/admin workstations have it)
• Data/system access level (privileged, standard, read-only)
• Update channel (auto-update on/off; controlled updates; vendor-managed)
• Vendor support status (supported/unsupported)
• Owner and approver

Practical approach: start with what you already have (software asset inventory, EDR application inventory, endpoint management reports) and add the “maintenance tool” classification tag.

Step 3: Define what “latest updates and patches” means in your environment

Because MA-3(6) uses the word “latest,” you need an internal standard that is testable:

• Baseline rule: tool must be on a vendor-supported version and patched per vendor security updates.
• Update expectation: auto-update enabled where feasible; otherwise, update through controlled change.
• Exception rule: unsupported/out-of-date tools require compensating controls and documented approval.

Document this in a one-page standard so inspectors don’t get different answers from different teams. ¹

Step 4: Implement an inspection workflow (the “inspect” part)

Use a workflow that results in artifacts:

1. Trigger the inspection

   • Before first use in a new environment
   • Before use after a period of inactivity
   • After vendor releases a security update (if you track advisories)
   • On a recurring cadence aligned to your patch program

2. Verify patch status

   • For installed software: export version and patch level from endpoint management tooling.
   • For portable tools: validate file hash/version against an approved repository and confirm packaging date.
   • For appliances: check firmware/software version and last update timestamp.

3. Record results

   • Pass/fail, version observed, date/time, inspector, system/tool identifier.

4. Enforce outcome

   • Pass: tool remains approved.
   • Fail: block execution, uninstall, remove access, or quarantine device until updated.
   • Exception: require risk acceptance, time bound it, and require compensating controls (restricted network segment, MFA, session recording, least privilege).

Step 5: Control third-party maintenance tools (where most programs get stuck)

If third parties (field service, managed service providers, software publishers) bring or run tools:

• Require them to use your approved remote access path where possible.
• If they must use their own tool, require evidence of patch status before access is granted (e.g., version proof, attestation plus verification where feasible).
• Contractually require timely updates for maintenance tooling that interfaces with your systems.
• Log and monitor sessions; tie access approval to a ticket.

Step 6: Build evidence collection into the process (so audits are easy)

A clean MA-3(6) program produces evidence by default. If evidence is an afterthought, it will fail under audit pressure.

Daydream fits well here as the system of record for “control mapped to owner, procedure, and recurring evidence artifacts,” so you can assign collection tasks, store exports, and prove operating effectiveness without chasing screenshots at the end of the quarter. ¹

Required evidence and artifacts to retain

Keep artifacts that answer: “What tools exist, how did you inspect, what did you find, what did you do about failures?”

Core artifacts

• Maintenance tools inventory (with owner, location, update method, privilege level)
• Documented inspection procedure/runbook (steps, tools used, pass/fail criteria)
• Inspection records (reports/exports, screenshots, logs) showing version/patch status
• Tickets/changes for updates applied (including approvals where required)
• Exception register for out-of-date tools (risk acceptance, compensating controls, expiry)
• Access logs for third-party maintenance sessions where relevant

Nice-to-have artifacts (make audits faster)

• Approved software list / allowlist entries for maintenance tools
• Configuration evidence that auto-update is enabled where allowed
• EDR/endpoint management policy evidence that blocks unapproved remote tools

Common exam/audit questions and hangups

Auditors and assessors tend to probe the same weak points:

• “Show me your inventory of maintenance tools and how you know it’s complete.”
• “Define ‘latest patches’ for this tool. What is the pass/fail threshold?”
• “Give me three examples of inspections performed, and the evidence.”
• “What happens when a tool fails inspection? Show me one remediation ticket.”
• “Do third parties use their own tools? How do you validate patch status before access?”
• “How do you prevent technicians from running portable tools from USB?”

Hangup to expect: teams present the enterprise patch policy for servers/endpoints and assume it covers MA-3(6). MA-3(6) is narrower and more specific: it targets the tooling used to maintain systems. ¹

Frequent implementation mistakes (and how to avoid them)

1. Mistake: No defined universe of “maintenance tools.”
   Fix: publish a scoped definition and tag tools in your asset inventory.

2. Mistake: Relying on vendor auto-update without verification.
   Fix: keep evidence that auto-update is enabled and collect periodic version exports.

3. Mistake: Portable/technician tools are unmanaged.
   Fix: require tools to come from an approved repository; block execution from removable media where possible; inspect before use.

4. Mistake: Exceptions exist but are not time-bound.
   Fix: require expiry dates, compensating controls, and re-approval.

5. Mistake: Third-party tools bypass internal controls.
   Fix: force third parties through your remote access method and ticketing; treat their toolchain as part of access governance.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. From a risk standpoint, assessors treat outdated maintenance tooling as a credible path to privilege escalation and remote compromise because these tools commonly hold admin credentials, persistent agents, or broad network reach. MA-3(6) reduces that exposure by forcing inspection and hygiene of the tools that can do the most damage if compromised. ¹

Practical 30/60/90-day execution plan

First 30 days (stand up the control)

• Name the control owner and backups; define RACI with IT Ops and Security.
• Publish your “maintenance tool” definition and initial in-scope list.
• Choose inspection methods per tool type (installed vs portable vs appliance vs SaaS console).
• Create evidence templates: inspection log format, exception form, and approval workflow.

Days 31–60 (operate it on real systems)

• Complete the first full inventory sweep and reconcile gaps.
• Run inspections for the highest-privilege tools first (remote access, patch consoles, imaging).
• Remediate obvious failures; open tickets and document outcomes.
• Stand up third-party access guardrails (ticket required, approved tool path, session logging).

Days 61–90 (make it audit-ready and repeatable)

• Expand coverage to the remaining tools and edge cases (field laptops, USB kits, niche diagnostics).
• Test the audit packet: pick sample tools and assemble end-to-end evidence in one place.
• Formalize metrics for internal tracking (counts of inspected tools, failures, exceptions) without turning it into a reporting exercise.
• Move recurring evidence collection into Daydream (or your GRC system) so inspection outputs are captured continuously and mapped to the control owner and procedure. ¹

Frequently Asked Questions

Does MA-3(6) mean every system patch cycle must include maintenance tools?

It means maintenance tools must be inspected to confirm updates and patches are current. Aligning inspections with your patch cycle is a practical way to run it, but you still need tool-specific proof of patch status. ¹

What counts as a “maintenance tool” in an audit?

Treat it as any tool used to administer, diagnose, repair, patch, image, or remotely access systems, especially with elevated privileges. If a technician uses it to “fix systems,” include it unless you have a documented rationale to exclude it. ¹

How do we handle a third party that insists on using their own remote support tool?

Gate access through a ticket and require proof the tool is current before granting connectivity. If you cannot verify patch status credibly, restrict the session with compensating controls or require use of your approved access method. ¹

Is an attestation from IT Ops enough evidence for “inspect”?

Usually not by itself. Keep objective outputs such as endpoint management exports, console screenshots, version reports, or logs that show the tool version/patch state and the inspection date. ¹

What if a maintenance tool can’t be patched because the vendor is end-of-life?

Document an exception with risk acceptance, define compensating controls, and set a replacement plan. Auditors expect to see that you recognized the gap and controlled exposure rather than ignoring it. ¹

How do we prove our inventory of maintenance tools is complete?

Show multiple discovery sources (software inventory, endpoint management, EDR application lists, admin workstation baselines) and a reconciliation process. Then show you review the inventory on a recurring basis and after major environment changes. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5