MA-4(3): Comparable Security and Sanitization

MA-4(3) requires you to ensure any nonlocal (remote) maintenance or diagnostic work is performed from a system with security capabilities comparable to the system being serviced, so the maintenance path does not become the weakest link. Operationalize it by approving remote-maintenance methods, enforcing hardened support endpoints, and collecting evidence that each session used an approved, comparable-security setup. ¹

Key takeaways:

• Treat remote maintenance as a privileged access pathway and require “comparable security” on the supporting device, not just on the target system. ¹
• Write an enforceable standard for approved remote-maintenance endpoints, tools, and session controls, then map it to recurring evidence. ²
• Audit readiness depends on session-level proof: who accessed what, from where, with what security posture, and what changed. ²

Remote maintenance is a normal operating need: OEM support, MSP troubleshooting, cloud provider break-glass, and third-party diagnostics. It is also a reliable way to bypass your defenses if you do not control the security of the system performing the maintenance. MA-4(3) exists to close that gap by requiring the maintenance origin (the remote system used by support staff) to have security capability comparable to the system being serviced. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path to implementation is to stop debating “comparable” in the abstract and define it for your environment as a concrete baseline: identity strength, device security posture, encrypted admin channels, logging, and session oversight. Then enforce that baseline through architecture (jump hosts, privileged access management, conditional access), contracts (third-party maintenance requirements), and operations (change control, ticketing, evidence capture). ²

This page gives requirement-level guidance you can hand to IT operations, security engineering, and third-party risk management (TPRM) so they can build a defensible, auditable process quickly.

Requirement: ma-4(3): comparable security and sanitization requirement (what it means)

MA-4(3) is a control enhancement under Maintenance (MA) that addresses nonlocal maintenance and diagnostic services. The requirement is straightforward: if a third party (or internal staff) performs maintenance remotely, the system they use to connect must implement security capability comparable to the system they are servicing. ¹

“Comparable” is intentionally flexible. Your job is to define what comparable means for each maintenance scenario, then enforce it consistently.

Regulatory text

“Require that nonlocal maintenance and diagnostic services be performed from a system that implements a security capability comparable to the capability implemented on the system being serviced; or” ¹

Operator translation: if an admin is remoting into a high-security production system, they cannot do it from an unmanaged laptop, a personal device, or an unknown support workstation. The origin device and the remote access path must meet a baseline that is comparable to the target’s protections. ²

Plain-English interpretation (what auditors expect)

Auditors typically look for three things:

1. A defined standard for remote maintenance origins
   Document what security capabilities the remote maintenance system must have (for example: MFA, managed endpoint controls, logging, patching, encryption, restricted admin tools). ²

2. A technical pattern that enforces the standard
   Common enforceable patterns include: a managed jump host, a PAM tool with device posture checks, or a vendor support portal that meets your baseline and is contractually required. ²

3. Evidence that sessions followed the pattern
   You need artifacts showing that remote maintenance happened through approved methods and from compliant systems, plus what was done. ²

Who it applies to (entity and operational context)

This requirement applies anywhere you run systems aligned to NIST SP 800-53, including:

• Federal information systems and the organizations operating them. ²
• Contractor systems handling federal data, including third parties providing IT services, managed security, or product support into those systems. ²

Operational contexts where MA-4(3) becomes “real”:

• OEM/manufacturer remote diagnostics into appliances, medical devices, OT/ICS components, or network gear.
• Managed service provider (MSP) remote admin to servers, directories, endpoints, or cloud tenants.
• SaaS or IaaS support “break-glass” troubleshooting.
• Internal admins performing after-hours remote support from nonstandard devices.

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

Use this as an implementation runbook.

Step 1 — Inventory all nonlocal maintenance paths

Create a simple register with:

• System being serviced (asset/service name, environment, owner)
• Who performs remote maintenance (internal team vs third party)
• Tool/path used (VPN, remote desktop gateway, PAM, vendor tool)
• Authentication method
• Logging location
• Typical maintenance actions (patching, config change, diagnostics)

Deliverable: “Remote Maintenance Path Register” owned by Security/GRC with system-owner attestations.

Step 2 — Define “comparable security” as an enforceable baseline

Write a standard that states minimum controls for the remote maintenance system (the originating endpoint/jump environment). Keep it capability-based so it maps to your environment.

A practical baseline matrix:

Capability area	Minimum expectation for remote maintenance origin	How to enforce
Identity	Strong authentication and role-based admin access	SSO + MFA; PAM check-out
Device trust	Managed device or managed jump host only	Conditional access; VDI/jump host
Channel security	Encrypted administrative channels	Approved remote protocols; TLS; VPN where needed
Hardening	Secure configuration, no local admin by default	Endpoint management baseline
Patch/vuln hygiene	Patching SLAs aligned to the target’s criticality	Patch compliance reporting
Malware defense	EDR/AV on the originating system	EDR policy + reporting
Logging	Session logs and command/audit trails retained centrally	SIEM ingestion; PAM session recording
Data handling	Controls to prevent data exfiltration during support	Clipboard/file transfer controls on remote tools

Deliverable: “Remote Maintenance Comparable Security Standard” approved by IT/Security leadership and referenced in third-party contracts. ²

Step 3 — Choose one or two approved technical patterns (reduce variance)

Pick patterns you can enforce and audit. Typical options:

• Managed jump host / bastion: third parties connect to a controlled jump environment that meets your baseline, then access targets.
• PAM with session recording: access is brokered, time-bound, and logged.
• Vendor support portal with restrictions: only if you can validate comparable security through contract and evidence.

Deliverable: Architecture standard + list of “Approved Remote Maintenance Methods.”

Step 4 — Update third-party requirements and onboarding

For any third party that performs remote maintenance, add contractual and operational requirements:

• Only use approved remote maintenance methods
• Maintain comparable endpoint controls (mapped to your baseline)
• Provide evidence upon request (device management attestation, access logs, session records)
• Notify you of tooling changes (remote agent updates, new support platforms)

Deliverable: Contract addendum / security schedule and a TPRM control check that gates onboarding and renewal. ²

Step 5 — Gate access with workflow (ticket + approval + time box)

Make it hard to “just hop on a box.”

• Require a ticket with business justification and scope.
• Approve access for a defined window.
• Require named accounts (no shared vendor logins).
• Tie session logs to the ticket ID.

Deliverable: SOP for “Remote Maintenance Authorization & Monitoring.”

Step 6 — Monitor sessions and close out with evidence

Minimum operational closure:

• Confirm session used an approved method.
• Review logs/recordings for privileged actions.
• Capture changes into change management.
• Revoke access when the window closes.

Deliverable: ticket closure checklist with attached logs and approvals.

Step 7 — Operationalize evidence collection (make audits easy)

This control fails most often due to missing proof. Build recurring evidence pulls (monthly or per-session, depending on risk) from:

• PAM reports
• Jump host access logs
• VPN/remote gateway logs
• Conditional access/device posture logs
• Ticketing/change records

If you use Daydream to run your control operations, map MA-4(3) to a single owner, a single procedure, and a recurring evidence bundle so you can answer assessor questions quickly without rebuilding history each time. ²

Required evidence and artifacts to retain

Keep artifacts tied to both design and operation:

Design evidence (policy/standard)

• Remote Maintenance Comparable Security Standard
• Approved Remote Maintenance Methods list
• Remote Maintenance Path Register
• Third-party contractual language requiring comparable security (or internal policy if internal-only)

Operational evidence (proof it ran)

• Access request tickets with approvals and time windows
• Authentication evidence (SSO/MFA logs where available)
• PAM checkout records and session recordings (if implemented)
• Jump host logs and admin session logs
• Change records linked to maintenance sessions
• Exception register for any nonstandard support method, with compensating controls and approvals

Common exam/audit questions and hangups

Expect these questions and prepare answers with artifacts:

• “Define comparable security.” Provide your baseline matrix and show how it is enforced for each maintenance path. ²
• “Show me a remote maintenance session end-to-end.” Pull one ticket and attach: approval, session logs/recording reference, and change record.
• “Do third parties use shared accounts?” If yes, you need a remediation plan and interim compensating controls.
• “How do you prevent maintenance from unmanaged endpoints?” Show conditional access, jump host requirements, or PAM gating.
• “Where is the evidence retained and for how long?” Answer with your retention standard and demonstrate retrieval.

Frequent implementation mistakes (and how to avoid them)

1. Writing a policy that is not enforceable
   Fix: define approved tools and patterns; block everything else at the network/identity layer.

2. Focusing only on the target system controls
   Fix: the requirement is explicit about the system performing the maintenance. Document and enforce posture for the origin system. ¹

3. Allowing “temporary” vendor agents with no governance
   Fix: treat remote agents as software deployment with approval, logging, and removal requirements tied to the ticket.

4. No session-level evidence
   Fix: require session logs tied to a ticket ID; record privileged sessions where feasible.

5. Over-scoping “comparable” so implementation stalls
   Fix: start with a minimum baseline for all remote maintenance, then add higher tiers for high-impact systems.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this specific enhancement, so treat it as an assessment-readiness and breach-resilience control rather than a “named penalty” item. ²

Risk-wise, MA-4(3) addresses a predictable failure mode: a high-security environment accessed from a lower-security support endpoint. That gap can bypass network segmentation, endpoint hardening, and monitoring if remote sessions are not brokered and logged. The operational implication is simple: remote maintenance must look like privileged access, with comparable endpoint controls and strong audit trails. ²

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

Use staged phases without promising exact outcomes.

First 30 days (Immediate stabilization)

• Appoint a control owner (Security/GRC) and operators (IAM/PAM, IT Ops, Network).
• Build the Remote Maintenance Path Register for top critical systems first.
• Freeze new remote-maintenance methods: require approval until standards are set.
• Draft the Comparable Security Standard and Approved Methods list.

By 60 days (Enforcement begins)

• Implement at least one enforceable access pattern (jump host or PAM) for highest-risk paths.
• Update third-party contract language and onboarding checklists for maintenance-capable third parties.
• Add ticket workflow requirements: approval, time box, named accounts, closure checklist.

By 90 days (Audit-ready operations)

• Expand approved patterns to remaining maintenance paths.
• Stand up recurring evidence collection (reports and spot checks).
• Run a tabletop test: pick a recent maintenance session and prove end-to-end evidence retrieval.
• Formalize exception handling with compensating controls and expiration dates.

Frequently Asked Questions

What counts as “nonlocal maintenance” under MA-4(3)?

Any maintenance or diagnostics performed remotely over a network, including third-party support sessions, remote admin by internal staff, or OEM troubleshooting. The key is that the maintenance originates from a separate system outside the local console context. ¹

How do we define “comparable security” without overengineering?

Define a baseline around identity strength, device management, encrypted admin channels, and logging, then require all remote maintenance to use approved patterns that enforce it. Keep a higher tier for your most sensitive environments. ²

Do we have to force third parties to use our managed jump host?

No single architecture is mandated, but you must be able to show the remote system used for maintenance has comparable security to the system being serviced. A jump host is often the simplest way to make that claim defensible with evidence. ¹

What evidence is usually hardest to produce in an audit?

Session-level proof: who accessed what, from where, under what approval, and what they changed. If your tools cannot bind logs to a ticket or named identity, fix that first. ²

How do we handle emergency “break-glass” support from a third party?

Pre-define an emergency method that still routes through an approved, controlled pathway (for example, a brokered access method) and requires after-action review with preserved logs. Document the exception and close it promptly with access revocation. ²

Can we meet MA-4(3) with policy only?

Policy helps, but auditors expect enforcement and operational evidence. If you cannot technically restrict remote maintenance origins, you will struggle to prove that comparable security was actually in place for each session. ²

Footnotes

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

2. NIST SP 800-53 Rev. 5