SA-3(3): Technology Refresh

SA-3(3) requires you to plan, fund, and execute a technology refresh schedule for each system across its full SDLC so components do not age into unsupported, insecure, or unmaintainable states. Operationalize it by defining refresh triggers, mapping them to assets and roadmaps, and producing recurring evidence that refresh work is tracked to completion. ¹

Key takeaways:

• You need a system-specific refresh schedule tied to lifecycle events, not an informal “we upgrade sometimes” practice. ¹
• Auditors will look for traceability: refresh plan → asset inventory → funding/roadmap → completed changes → exceptions with approvals.
• The fastest path is to assign one owner per system and one enterprise standard for refresh triggers, evidence, and reporting cadence.

The sa-3(3): technology refresh requirement is an engineering-and-governance control that fails most often for one reason: teams treat “refresh” as a discretionary IT modernization effort instead of a planned SDLC obligation with audit-ready artifacts. SA-3(3) is explicit: you must plan for and implement a technology refresh schedule for the system throughout the system development life cycle. ¹

For a Compliance Officer, CCO, or GRC lead, the operational goal is simple: make refresh predictable, budgetable, and provable. That means (1) defining what “refresh” covers in your environment (hardware, OS, middleware, libraries, managed services, build pipelines), (2) setting refresh triggers (end-of-support, critical vulnerabilities, performance/capacity constraints, contract renewal), and (3) enforcing a workflow where refresh work becomes tracked change with documented closure.

This page gives requirement-level guidance you can hand to system owners and IT leadership. It focuses on governance mechanics, evidence, and exam questions, not modernization theory. Citations are limited to the provided NIST sources. ²

Regulatory text

Requirement (excerpt): “Plan for and implement a technology refresh schedule for the system throughout the system development life cycle.” ¹

Operator interpretation:
You must do two things, continuously, for each in-scope system:

1. Plan a refresh schedule (documented, owned, and aligned to the system’s SDLC).
2. Implement the refresh schedule (refresh work is executed, tracked, and evidenced).
   The schedule must persist through the SDLC, so it cannot be a one-time project plan that goes stale after go-live. ¹

Plain-English meaning (what auditors expect)

A system that runs on aging components will eventually cross predictable risk thresholds: end-of-support, lack of security patches, dependency conflicts, and operational fragility. SA-3(3) expects you to prevent that outcome by building refresh into normal system lifecycle management, with accountability and proof. ¹

Who it applies to

Entities:

• Federal information systems and organizations implementing NIST SP 800-53. ³
• Contractors operating systems that handle federal data where NIST SP 800-53 controls are flowed down or used as the assessment baseline. ³

Operational scope (what “system” means in practice):

• Business applications (custom and COTS), platforms, data services, and supporting infrastructure where you can define boundaries, owners, and architecture.
• Cloud-hosted systems still count. “Managed” does not remove your responsibility to plan refresh for your configurations, dependencies, and service versions.

Where it lives operationally:
SA-3(3) is usually owned jointly by:

• System Owner / Product Owner (accountable for lifecycle plan and risk acceptance)
• IT Operations / Platform Engineering (executes refresh work)
• Security / GRC (sets minimum refresh expectations, monitors evidence, and manages exceptions)

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

Step 1: Define refresh scope and triggers (enterprise standard)

Create a one-page standard that answers:

• What components are in scope (examples: OS, DB engines, container runtime, Kubernetes versions, VM templates, network appliances, build agents, key libraries).
• What counts as “refresh” (upgrade, replacement, re-platform, retirement, contract migration).
• Trigger events that require action (end-of-support, end-of-life announcements, inability to patch, recurring incidents tied to aging tech, third-party contract sunsets).

Deliverable: Technology Refresh Standard (enterprise-level).

Step 2: Build a system-level refresh schedule template

For each system, require a schedule format that includes:

• System name, boundary, criticality, owner.
• Component list (or reference to CMDB/asset inventory).
• Planned refresh windows by component category (for example: “OS baseline refresh aligned to platform baseline,” “database major version upgrades planned with vendor support windows”).
• Dependencies and constraints (maintenance windows, downtime tolerances, freeze periods).
• Budget/funding source (even if “run” budget) and approval path.
• Exception path (what happens if refresh cannot occur as planned).

Deliverable: System Technology Refresh Schedule per system. ¹

Step 3: Tie the schedule to the SDLC and change management

Make the refresh schedule a required artifact at these SDLC checkpoints:

• Architecture/design reviews (does the design assume components with known support horizons?)
• Release planning (are refresh epics/stories in the backlog?)
• Change control (are refresh changes tracked as normal changes with testing/rollback?)
• Operations (does patching, versioning, and dependency management align to the refresh plan?)

Deliverable: SDLC gating checklist referencing the refresh schedule. ¹

Step 4: Establish a refresh governance rhythm

Set a recurring governance touchpoint where system owners attest to:

• Upcoming refresh items due in the next planning cycle
• Items completed since the last review
• Exceptions requested, with risk acceptance and compensating controls

Use a simple RAG status (Green/Amber/Red) per system based on whether refresh items are on track, overdue, or blocked. Avoid subjective labels without criteria; define “overdue” and “blocked” in your standard.

Deliverable: Refresh status report and meeting notes/action log.

Step 5: Implement and evidence the work (the part auditors test)

For each refresh item, you need traceability:

• Planned item exists (schedule/backlog)
• Change is approved
• Change is executed
• Testing and rollback criteria are documented
• Post-change validation and monitoring are performed
• Old components are retired and removed from inventory (or isolated with documented compensating measures)

Deliverable: Change tickets, release notes, test results, updated architecture/diagrams, updated inventory/CMDB entries.

Step 6: Manage exceptions as first-class compliance objects

Some refresh work will slip. That is normal. What breaks SA-3(3) is silent drift. Define an exception process with:

• Business justification
• Risk statement (what exposure exists due to the delay)
• Compensating controls (extra monitoring, segmentation, WAF rules, restricted access)
• Expiration date and re-approval requirement
• Executive risk acceptance for higher-risk systems

Deliverable: Technology Refresh Exception Register with approvals.

Step 7: Map control ownership, procedure, and recurring evidence (assessment readiness)

Create a control record that documents:

• Control owner
• Procedure steps (where artifacts live)
• Evidence produced each cycle
• Tools/systems of record (CMDB, ticketing, CI/CD, vulnerability management)

This is where Daydream fits naturally: teams often have the work spread across Jira/ServiceNow, CMDB, and cloud consoles. Daydream helps you map SA-3(3) to a named owner, a repeatable procedure, and a consistent evidence pack so you can answer assessor questions without assembling artifacts from scratch. ¹

Required evidence and artifacts to retain

Keep evidence system-by-system. Auditors sample systems.

Core artifacts (minimum set):

• Technology Refresh Standard (enterprise)
• System Technology Refresh Schedule ^{1 1}
• Asset inventory/CMDB export showing in-scope components and versions (point-in-time snapshots)
• Roadmap/backlog items for refresh work (epics/stories)
• Change records for refresh implementations (approvals, implementation notes)
• Test/validation evidence (release verification, smoke tests, monitoring checks)
• Exception register entries with approvals and expiry
• Periodic governance report (status and overdue items)

Nice-to-have artifacts (increase audit confidence):

• Dependency maps (SBOM outputs where available)
• End-of-support tracking log (vendor notices attached)
• Post-implementation review notes for major upgrades

Common exam/audit questions and hangups

Auditors tend to probe three failure modes: no plan, plan not implemented, plan not tied to SDLC. Expect questions like:

• “Show me the technology refresh schedule for this system and where it is maintained.” ¹
• “How do you know you are not running unsupported versions?”
• “How are refresh decisions funded and prioritized?”
• “Show evidence of a completed refresh activity from plan through change closure.”
• “What is your exception process, and who approves delays?”

Hangups that slow audits:

• Refresh work is mixed with general feature work and cannot be identified or reported.
• Inventory is incomplete, so you cannot prove scope coverage.
• Cloud managed services are assumed to be “refreshed by the provider,” but your configuration/version choices are not tracked.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Treating patching as the whole refresh program.
   Fix: Keep patching in your vulnerability/maintenance program, but define refresh as including major version upgrades, platform migrations, and retirement activities that patching cannot solve.

2. Mistake: No “system owner” accountability.
   Fix: Assign a named owner per system responsible for maintaining the refresh schedule and signing exceptions.

3. Mistake: Inventory and schedule don’t match.
   Fix: Require the schedule to reference the system inventory source of truth and reconcile routinely.

4. Mistake: Exceptions without expiry.
   Fix: Every exception needs an expiration and a re-approval trigger; otherwise, it becomes permanent technical debt with no governance.

5. Mistake: Refresh is planned but never implemented.
   Fix: Build refresh items into the roadmap/backlog and track completion with the same rigor as other changes. SA-3(3) explicitly requires implementation. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source material for this requirement, so you should treat SA-3(3) as an assessment and authorization readiness risk rather than a control with direct published penalty examples in this packet. ²

Practically, weak refresh governance increases:

• Exposure to unpatched or unpatchable vulnerabilities (end-of-support components).
• Outage risk from fragile, obsolete dependencies.
• Delivery bottlenecks when upgrades become emergency work rather than planned work.

Practical 30/60/90-day execution plan

First 30 days (stand up governance and scope)

• Name control owner and system owner roles; document RACI.
• Publish the Technology Refresh Standard (scope, triggers, exception rules).
• Identify in-scope systems and choose the system-of-record for inventory and change tickets.
• Create the system schedule template and require it for a pilot set of systems.

Days 31–60 (produce schedules and close obvious gaps)

• Build refresh schedules for the highest-risk systems first (externally exposed, mission-critical, data-sensitive).
• Reconcile each schedule to inventory; fix missing component/version data.
• Create the exception register and start logging any known end-of-support or blocked upgrades.
• Run the first refresh governance review and publish a status report.

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

• Execute at least one refresh item per pilot system (or document approved exceptions if blocked).
• Package evidence: schedule, backlog item, change ticket, validation results, updated inventory.
• Roll out the process to remaining systems and embed it into SDLC gates.
• Configure recurring evidence collection in Daydream (or your GRC tool) so each cycle produces an audit-ready control packet aligned to SA-3(3). ¹

Frequently Asked Questions

Does SA-3(3) require specific refresh intervals (e.g., annual hardware replacement)?

No interval is stated in the provided requirement text. SA-3(3) requires that you plan and implement a refresh schedule throughout the SDLC; you set the timing based on your environment and support constraints. ¹

We are fully in the cloud. Can we claim the cloud provider handles technology refresh?

You can rely on the provider for their underlying infrastructure, but you still need a schedule for your system components you control (service versions, images, configurations, dependencies) and evidence that refresh work is planned and completed. ¹

Is patch management enough to satisfy sa-3(3): technology refresh requirement?

Patching supports lifecycle health, but refresh typically includes upgrades and replacements that patching cannot address (major version changes, platform retirement). Your evidence should show a forward-looking refresh schedule and implemented refresh activities. ¹

What’s the minimum evidence an auditor will accept?

Keep a system refresh schedule, proof it is reviewed, and at least one example of refresh implementation traced through change management, plus a controlled exception process for deferred items. The requirement includes both “plan” and “implement.” ¹

How do we handle third-party products (COTS/SaaS) where we cannot control upgrade timing?

Document the dependency, track the provider’s support and upgrade policy, and reflect it in your schedule and exception process. If the provider cannot meet your lifecycle needs, record the risk decision and any compensating controls. ¹

Who should approve refresh exceptions?

Set an approval path that matches system criticality; higher-risk systems should require senior risk acceptance. Auditors mainly test that exceptions are explicit, time-bounded, and governed rather than informal. ¹

Footnotes

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

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

3. NIST SP 800-53 Rev. 5