PL-9: Central Management

To meet the pl-9: central management requirement, you must define which security and compliance capabilities are centrally managed and prove you actually run them through centralized services, tooling, and governance rather than ad hoc, system-by-system administration. Operationalize PL-9 by scoping the “things to centrally manage,” assigning owners, standardizing configurations, and retaining evidence of centralized control execution. ¹

Key takeaways:

• PL-9 is a design-and-operations control: centralize management of defined security/compliance parameters, then show it works in practice. ¹
• The hard part is scoping “what” is centrally managed (the PL-9 organization-defined parameters) and preventing exceptions from becoming the default.
• Evidence needs to show control, not intent: centralized configurations, enforced baselines, and repeatable change records beat a policy PDF.

PL-9: Central Management requires you to centrally manage specific, organization-defined items, but the control text is intentionally parameterized. That means your first job is not tooling. It is deciding, documenting, and approving what “centrally manage” means for your environment and which assets and functions are in scope, then running those functions through a consistent control plane. ¹

For a CCO, Compliance Officer, or GRC lead, PL-9 becomes an assessment readiness problem quickly: assessors will ask what is centrally managed, who owns it, how it is enforced, what exceptions exist, and how you can prove centralized execution across the system boundary. This is especially relevant for federal information systems and contractor systems handling federal data because “central management” reduces drift, supports consistent implementation of other controls, and makes monitoring and change governance testable. ¹

This page gives requirement-level implementation guidance: scoping decisions, step-by-step operational tasks, evidence to retain, audit questions you will get, and a practical execution plan you can run as a control owner or program lead.

Regulatory text

Control requirement (excerpt): “Centrally manage {{ insert: param, pl-09_odp }}.” ¹

What the operator must do

Because PL-9 uses organization-defined parameters, you must:

1. Define the PL-9 parameters (what you will centrally manage) in writing.
2. Implement a centralized management approach for those parameters (central services, central tooling, central governance).
3. Operate it continuously with change control, monitoring, and exception handling.
4. Produce evidence that management is actually centralized and consistently applied. ¹

A practical reading: PL-9 is asking you to replace “every system team does it their own way” with “we manage it once, consistently, and can prove it.”

Plain-English interpretation (what PL-9 means in practice)

“Centrally manage” means a defined set of security-relevant configurations, policies, and processes are controlled through a shared mechanism with standardization and oversight, rather than being left to local admins on each system.

Common examples of PL-9 parameters you might choose to centrally manage (pick what fits your environment and authorization boundary):

• Identity and access management policy enforcement (SSO, MFA, conditional access)
• Endpoint configuration baselines (device encryption, EDR, host firewall rules)
• Central logging and audit policy (log sources, retention configuration, forwarding)
• Vulnerability management configuration (scan schedules, authenticated scanning settings)
• Configuration management standards (gold images, hardened baselines, desired state)
• Network security policy (DNS, web filtering, firewall policies)
• Asset inventory rules (required attributes, discovery cadence, tagging standards)

PL-9 does not require one specific tool. It requires centralized control and demonstrable consistency.

Who it applies to

Entity types

PL-9 commonly applies to:

• Federal information systems operated by an agency.
• Contractor systems handling federal data (including cloud-hosted systems) where NIST SP 800-53 is part of the security requirements. ¹

Operational context (where it shows up)

You will feel PL-9 most in environments with:

• Multiple teams administering systems (platform, app, IT, SOC).
• Rapid change (CI/CD, infrastructure as code).
• Hybrid estates (SaaS + IaaS + on-prem).
• Third parties that administer parts of your stack (managed service providers, SaaS admins, outsourced SOC).

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

Step 1: Define the PL-9 scope (your organization-defined parameters)

Create a short “PL-9 Central Management Scope” statement that lists:

• Items to centrally manage (the parameters).
• In-scope assets (systems, environments, endpoints, network segments).
• Central management mechanism(s) for each item.
• Allowed exceptions and who can approve them.

Deliverable: a one-page control implementation summary you can drop into your SSP/control narrative. ¹

Step 2: Assign ownership and RACI

For each centrally managed item, name:

• Control owner (accountable).
• Operators (platform/SOC/IT).
• Approvers (security architecture, change advisory, CISO delegate).
• Evidence steward (who maintains the artifacts for audits).

If you use Daydream for control operations, map PL-9 to a named owner, an implementation procedure, and recurring evidence artifacts so the control does not degrade into a one-time documentation exercise. ¹

Step 3: Standardize the central control plane

Implement (or confirm) the mechanisms that make “central” true. Typical patterns:

• Policy-as-code / desired state for configurations (where feasible).
• Central IAM for user lifecycle and privileged access paths.
• Centralized logging pipeline with controlled onboarding and field standards.
• Central endpoint management with enforced baselines and drift reporting.
• Central change control for changes to baselines/policies.

Your goal: a small number of places where changes are made, reviewed, and rolled out, with traceability.

Step 4: Build a baseline and a controlled change process

For each centrally managed item:

• Define the baseline (what “compliant” looks like).
• Define how changes are requested (ticket, pull request, CAB).
• Define how changes are approved (who signs off).
• Define how changes are deployed (automated rollout vs manual).
• Define how drift is detected (reports, alerts, configuration checks).
• Define how rollback works (versioned configs, emergency change path).

Audit reality: “We centrally manage X” fails if teams can bypass the central baseline without detection.

Step 5: Handle exceptions explicitly (do not let them accumulate silently)

Create an exception workflow that includes:

• Business justification
• Risk acceptance owner
• Compensating controls (if any)
• Expiration and review trigger
• Evidence of implementation (what is different and why)

Keep a single exception register for PL-9-related deviations so you can answer “how many exceptions exist and are they time-bound?”

Step 6: Prove ongoing operation (continuous evidence)

Central management is operational. Set up recurring evidence capture:

• Screenshots/exports of baseline policies (versioned)
• System reports showing enforcement coverage and drift status
• Change records for baseline modifications
• Access reviews for the central admin roles
• Incident/problem records tied to configuration drift, with corrective actions

Daydream can help by turning PL-9 into a scheduled evidence checklist with owners, due dates, and a clean audit trail of uploads and approvals, instead of a scramble before the assessor arrives. ¹

Required evidence and artifacts to retain

Keep evidence that is (a) attributable, (b) time-bound, and (c) reproducible.

Minimum artifact set (practical)

• PL-9 control narrative / implementation statement defining the organization-defined parameters and central mechanisms. ¹
• Central management architecture diagram (even a simple diagram) showing the control plane(s) and in-scope assets.
• Baseline definitions (configuration documents, policy exports, hardened standards).
• Access control lists / role assignments for central admin functions (who can change the baseline).
• Change records (tickets or pull requests) showing review/approval for baseline changes.
• Enforcement/drift reports (from endpoint management, IAM, logging platform, configuration checks).
• Exception register with approvals and expirations.

Common exam/audit questions and hangups

Expect these questions, and prepare crisp answers with evidence pointers:

1. “What exactly do you centrally manage under PL-9?”
   Hangup: vague scope. Fix by listing parameters and mapping each to a mechanism. ¹

2. “Show me how you enforce it across all in-scope assets.”
   Hangup: partial coverage. Fix by maintaining coverage reports and onboarding procedures.

3. “Who can change the baseline, and how do you know changes were approved?”
   Hangup: shared admin accounts, informal Slack approvals. Fix with RBAC + ticket/PR approvals.

4. “How do you detect and correct drift?”
   Hangup: central config exists but no monitoring. Fix with scheduled compliance checks and documented remediation.

5. “How do exceptions work, and are they time-bound?”
   Hangup: exceptions with no expiry. Fix with expirations and periodic review.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Writing a policy that says “central management” without defining the PL-9 parameters.
  Avoidance: publish a scoped list of centrally managed items tied to tools and owners. ¹

• Mistake: Treating central management as a single tool purchase.
  Avoidance: assessors test outcomes. Prove standardized baselines, controlled change, and coverage reporting.

• Mistake: Allowing local admins to override baselines with no detection path.
  Avoidance: restrict privileges, monitor drift, and require exception tickets.

• Mistake: No evidence trail for baseline changes.
  Avoidance: require tickets/PRs for baseline edits; store exports with timestamps.

• Mistake: “Central” varies by environment (prod vs dev) with undocumented differences.
  Avoidance: explicitly document environment differences and treat deviations as exceptions.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for PL-9, so you should treat this as an assessment and authorization risk rather than tying it to a specific penalty narrative. ¹

Operationally, weak central management increases:

• Configuration drift and inconsistent control implementation across systems.
• Audit failures due to inability to prove consistency and oversight.
• Incident blast radius when local changes bypass standards.

For regulated or federal-aligned programs, the risk is straightforward: if you cannot demonstrate central management for your defined parameters, you create gaps across multiple dependent controls and raise the likelihood of findings.

Practical 30/60/90-day execution plan

First 30 days: Define scope, owners, and proof points

• Draft PL-9 scope: list centrally managed parameters and the central mechanism for each. ¹
• Assign control owner and operators; document RACI.
• Inventory current central tooling and where “local” management still exists.
• Define the evidence set you will collect (baseline exports, drift reports, change records).
• Stand up an exception register and approval workflow.

Day 31–60: Implement or tighten central enforcement

• Publish baselines for each parameter (version-controlled).
• Restrict who can modify central baselines (RBAC, admin role hygiene).
• Implement change control for baseline edits (ticket/PR + approval).
• Start recurring drift/coverage reporting and route results to owners.
• Onboard remaining in-scope assets into central management where feasible.

Day 61–90: Operationalize and make it audit-ready

• Run a mini internal assessment: sample assets and prove central enforcement end-to-end.
• Close gaps found in drift monitoring, exception hygiene, and evidence completeness.
• Package artifacts into an assessor-ready folder structure mapped to PL-9.
• If you use Daydream, set recurring evidence tasks and automated reminders so evidence stays current and attributable. ¹

Frequently Asked Questions

What counts as “centrally managed” for PL-9?

“Central” means a shared mechanism controls configuration or policy consistently across in-scope assets, with controlled change and traceable administration. Your organization defines the exact items to centrally manage and must document them. ¹

Do we have to centralize everything in the environment?

No. PL-9 is parameterized, so you define what is centrally managed, but assessors will expect your chosen scope to be risk-based and consistently enforced. Document exclusions and treat deviations as exceptions. ¹

Can we meet PL-9 in a multi-cloud or hybrid environment?

Yes, if you standardize the management approach across environments (or document differences) and can prove consistent enforcement and change governance. The evidence burden increases when each platform has different control planes.

How do we handle third parties that administer parts of our systems?

Put third-party administrative actions behind your central governance where possible (for example, your ticketing and approval process, your privileged access controls, and your baseline standards). Retain the change records and access logs that show oversight.

What is the minimum evidence an auditor will accept?

Expect to provide a defined scope statement, baseline artifacts, proof of restricted administrative access, change approvals for baseline edits, and drift/coverage reports. If any of those are missing, PL-9 often turns into a “designed but not operating” finding.

We have central tools, but teams also make local changes. Are we noncompliant?

Not automatically, but you need governance and detection: local changes must be prevented, detected and corrected, or handled through approved, time-bound exceptions. If local overrides are invisible, central management is not credible.

Footnotes

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