PM-10: Authorization Process

PM-10 requires you to run a formal authorization process that continuously manages the security and privacy state of each system and its operating environment, not just at launch. Operationalize it by defining who can authorize, what evidence is required, when reauthorization happens, and how you track exceptions and continuous changes across the system lifecycle. ¹

Key takeaways:

• Treat authorization as a lifecycle workflow tied to change management, not a one-time approval. ¹
• Define an authorization boundary, minimum evidence package, and decision rules for approvals, denials, and conditions. ¹
• Keep authorization evidence audit-ready: decisions, sign-offs, risk acceptances, and ongoing monitoring outputs. ¹

PM-10 is a Program Management control in NIST SP 800-53 that pushes organizations to manage system risk through authorization processes, meaning you need a repeatable way to decide whether a system is allowed to operate based on current security and privacy conditions. The practical goal for a CCO, security leader, or GRC lead is straightforward: be able to prove who authorized a system to run, what they reviewed, what risks were accepted, what conditions were attached to the approval, and how you keep that decision current as the system and environment change. ¹

This requirement shows up most visibly in federal information systems and contractor environments handling federal data, where an Authorization to Operate (ATO) or equivalent internal authorization decision is expected. The operational trap is treating authorization as documentation theater. Auditors look for evidence that authorization decisions are grounded in real risk signals (assessment results, open POA&Ms, monitoring outputs) and connected to engineering workflows (change tickets, vulnerability management, asset inventory). ²

Use this page as a build sheet: define scope, set roles, implement the workflow, and standardize the evidence you retain so you can answer exam questions quickly and consistently.

Regulatory text

Requirement (PM-10): “Manage the security and privacy state of organizational systems and the environments in which those systems operate through authorization processes;” ¹

Operator meaning: You must have an authorization process that (1) evaluates a system’s security and privacy posture, (2) results in a documented authorization decision to operate (or not operate), and (3) stays current as the system and its environment change. The “environment” includes hosting platforms, identity services, networks, and connected dependencies that materially affect system risk. ¹

Plain-English interpretation (what PM-10 is asking for)

PM-10 expects a consistent governance mechanism that answers these questions for every in-scope system:

• Is the system allowed to run right now?
• Who made that decision and with what authority?
• What did they review to decide (security and privacy evidence)?
• What risks remain, and who accepted them?
• What events force a reauthorization or an updated decision? ¹

You do not “comply with PM-10” by writing a policy alone. You comply by operating a decision workflow that produces evidence and drives outcomes (approval, conditional approval, denial, or decommission). ²

Who it applies to

Entity applicability

PM-10 is most directly applicable to:

• Federal information systems subject to NIST SP 800-53 control baselines. ²
• Contractor systems handling federal data, where customers often flow down authorization expectations in contracts and security requirements. ²

Operational context (what “systems and environments” means in practice)

Apply your PM-10 workflow to:

• Production systems (apps, APIs, data platforms) and their hosting stacks (cloud accounts, clusters, networks).
• Shared services that materially influence risk (IAM/SSO, SIEM, vulnerability scanners, KMS, CI/CD).
• Major third-party–run components when they are inside your authorization boundary (for example, managed hosting or MSP-managed infrastructure). ²

A clean way to decide scope: if a compromise or privacy failure in that component can cause a material incident for the system, it belongs in the authorization conversation and evidence package.

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

Step 1: Define the authorization model you will run

Pick a model that fits your environment, then document it:

• ATO-style authorization (formal package and authorizing official decision).
• Internal authorization to operate (risk-based approval by a designated executive) with the same core evidence, even if you do not label it “ATO.” ¹

Define decision outputs:

• Approved to operate
• Approved with conditions (explicit conditions and deadlines)
• Denied / blocked from production
• Interim authorization for limited use (with guardrails)

Step 2: Assign accountable roles (RACI, not a list of names)

Minimum roles to define:

• Authorizing Official (AO): single-point authority to accept residual risk.
• System Owner: accountable for remediation and operational readiness.
• Security/Privacy: produces or validates evidence; does not “own” the risk decision.
• Control Owners: provide evidence (logging, IAM, vuln mgmt).
• Change Manager / DevOps: ensures changes trigger reauthorization gates as required. ²

Write down delegation rules. Auditors often challenge “committee approvals” with unclear authority.

Step 3: Define the authorization boundary and inventory linkage

You need a stable identifier and scope for each authorized system:

• System name and owner
• Boundary description (what is in scope, what is out of scope)
• Environment(s): prod, staging, dev
• Key dependencies (platform services, third parties, shared tooling)
• Data types and privacy-relevant processing (if applicable) ¹

Tie this to your asset inventory/CMDB. If the system inventory and the authorized systems list diverge, PM-10 breaks operationally.

Step 4: Standardize the evidence package (minimum viable authorization package)

Create a required evidence checklist. Keep it short enough that teams can comply repeatedly. A practical starting set:

• System description + boundary
• Risk assessment summary (security and privacy)
• Control implementation summary (what controls are in place and where)
• Known gaps and remediation plan (POA&M-style list)
• Vulnerability posture summary and exception list
• Security monitoring approach (what you monitor, who responds)
• Incident response integration (contacts, on-call, playbooks)
• Third-party dependency summary where they impact the environment ²

The point is consistency. Your AO should see the same structure for every system.

Step 5: Implement the decision workflow and gate it into delivery

Put authorization into an operational workflow tool (GRC system, ticketing, or a dedicated approval workflow):

• Intake request (new system, major change, periodic review)
• Evidence submission and validation
• Risk review meeting (optional, based on risk tier)
• AO decision with explicit rationale
• Conditions tracked as actionable tasks with owners
• Closure criteria for conditions and reauthorization triggers ¹

Connect authorization triggers to change management. Common triggers:

• Major architecture changes
• Hosting environment changes (cloud account moves, network segmentation changes)
• Material third-party changes in the boundary
• New sensitive data types or new processing purposes
• Significant control failures or unresolved high-risk findings

Step 6: Operate continuous authorization management

PM-10 language points to “manage the state,” so define how you keep approvals current:

• Periodic reauthorization reviews on a risk-based cadence (set by you)
• Event-driven reauthorization based on the triggers above
• Ongoing monitoring feed into the authorization record (open findings, exceptions, control health)
• Documented risk acceptances that expire or require renewal ²

Step 7: Make it auditable: map ownership, procedure, and recurring evidence

Operationalize PM-10 by explicitly mapping:

• Control owner
• Procedure (SOP) steps and tools
• Recurring evidence artifacts and where they live ¹

Daydream (or any GRC system) becomes the practical resolution when you need this mapping to stay current across many systems, with automated evidence collection prompts and clear audit trails for approvals and exceptions.

Required evidence and artifacts to retain

Retain artifacts per system, in a consistent folder structure or GRC record:

• Authorization decision record (approve/deny/conditional), dated, with approver identity
• Evidence checklist and attachments (or links) actually reviewed
• Risk acceptance memos (who accepted what risk, scope, expiration/conditions)
• POA&M/remediation tracking tied to authorization conditions
• System boundary statement and dependency list
• Change records that triggered reauthorization and the resulting decisions
• Ongoing monitoring summaries used in reviews (dashboards, reports, tickets) ²

Auditors care less about perfect formatting and more about traceability: evidence → decision → follow-through.

Common exam/audit questions and hangups

Expect questions like:

• “Show me the last authorization decision for System X. Who approved it and what did they review?” ¹
• “How do you know your authorization remains valid after major changes?” ²
• “Where are conditions tracked, and how do you prevent ‘permanent conditional approvals’?” ²
• “What is your authorization boundary, and how do third parties and shared services fit into it?” ²
• “What happens if a system cannot meet required controls by go-live?” (you need a documented exception path and AO sign-off)

Hangups typically show up as missing sign-offs, unclear AO authority, or an evidence package that exists but does not match reality (outdated diagrams, stale findings lists).

Frequent implementation mistakes (and how to avoid them)

1. Authorization as a one-time launch checklist. Fix: require reauthorization triggers tied to change management and ongoing monitoring outputs. ¹
2. No clear AO decision authority. Fix: name the role, define delegation limits, and require documented risk acceptance for residual risk. ²
3. Evidence sprawl. Fix: standardize a minimum evidence checklist and enforce a single record of decision with links.
4. Conditions without closure. Fix: treat conditions as tracked obligations with owners, due dates (set by you), and explicit closure criteria.
5. Boundary confusion. Fix: maintain a boundary statement per system and update it on major architecture or hosting changes.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat PM-10 primarily as an assessment and contractual compliance risk driver rather than a standalone enforcement hook. The business risk is still real: weak authorization discipline correlates with operating systems with unknown risk, uncontrolled changes, and undocumented risk acceptances, all of which increase incident impact and slow down audits and customer security reviews. ²

Practical 30/60/90-day execution plan

First 30 days: Stand up the minimum viable authorization process

• Appoint an AO role and define decision authority and escalation.
• Create system authorization record templates: boundary, evidence checklist, decision log.
• Select the workflow system (ticketing or GRC) and implement an “authorization request” intake.
• Pilot on a small set of systems across different risk tiers. ¹

Next 60 days: Integrate with engineering and monitoring

• Define reauthorization triggers and connect them to change management.
• Build a repeatable evidence pipeline: vulnerability summary, monitoring summary, open risk acceptances, POA&M status.
• Train system owners on how to assemble the package and how conditional approvals work.
• Start reporting: authorized systems list vs system inventory reconciliation. ²

By 90 days: Make it durable and audit-ready

• Expand coverage to all in-scope systems.
• Implement periodic review schedules by risk tier (cadence set by you).
• Conduct an internal audit tabletop: pick a system and walk an auditor through evidence → decision → conditions → closure.
• If you are scaling, configure Daydream to map PM-10 to owners, procedures, and recurring evidence artifacts so you can track completeness across systems and avoid missing evidence during assessments. ¹

Frequently Asked Questions

Does PM-10 require an ATO for every system?

PM-10 requires authorization processes that manage system security and privacy state; it does not mandate a specific label like “ATO” in the provided excerpt. In practice, implement an authorization decision with documented evidence and risk acceptance that matches your operating model. ¹

What counts as the “environment” for authorization?

Treat the environment as the infrastructure and shared services that can materially affect security and privacy, such as cloud accounts, networks, IAM, logging, and key dependencies. Document those elements in the system boundary and evidence package. ²

How do we handle systems that cannot meet all control expectations by go-live?

Use conditional authorization with explicit conditions and a tracked remediation plan, plus a documented risk acceptance by the AO for residual risk. Do not allow open-ended conditions without an owner and closure criteria. ²

What evidence do auditors ask for first?

They typically start with the authorization decision record, who approved it, and the evidence that was reviewed. Keep a single decision log with links to the supporting artifacts and current status of conditions. ¹

How do third parties fit into PM-10?

If a third party provides services inside your authorization boundary or materially affects your system environment, reflect that dependency in the boundary and evidence package. Track dependency risks as part of the authorization conditions and ongoing monitoring. ²

We have continuous delivery. How can we avoid reauthorizing for every change?

Define “material change” triggers that require reauthorization and let standard changes flow under continuous monitoring and routine control checks. Document the trigger criteria and show how change management enforces it. ²

Footnotes

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

2. NIST SP 800-53 Rev. 5