SA-4(3): Development Methods, Techniques, and Practices

SA-4(3) requires you to make your system developer (internal team or third party) prove they follow a defined system development life cycle (SDLC) with documented development methods, techniques, and practices. To operationalize it fast, bind SDLC requirements into contracts and internal standards, then collect repeatable evidence (plans, secure coding standards, reviews, test records) for each release. ¹

Key takeaways:

• Treat SA-4(3) as a “show me the SDLC” requirement: documented process plus proof it was followed. ¹
• Operationalize through SDLC gating: define required methods/practices, require developer demonstration, and verify via artifacts per release.
• Audit readiness hinges on evidence traceability from requirements through design, code, test, and deployment.

For a CCO or GRC lead, SA-4(3): development methods, techniques, and practices requirement is a supply chain control disguised as a documentation control. You are not being asked to write code or pick a specific development methodology. You are being asked to require the developer of a system, component, or service to demonstrate they use an SDLC process with defined practices, then to be able to show an assessor the proof.

This matters most where development is external (SaaS, managed services, integrators, OEM software, open-source-heavy products), but it also applies to internal development teams. The operational trick is to turn “demonstrate the use of an SDLC” into: (1) contractual and policy obligations, (2) release-level gating criteria, and (3) a clean evidence package that can be produced on demand.

Done well, SA-4(3) becomes a predictable checklist tied to your engineering workflow (tickets, pull requests, CI/CD logs, test runs). Done poorly, it becomes a last-minute scramble for screenshots and vague narratives that fail the “demonstrate” standard.

Regulatory text

Requirement excerpt: “Require the developer of the system, system component, or system service to demonstrate the use of a system development life cycle process that includes:” ¹

What the operator must do:
You must (a) set an explicit expectation that the developer follows a defined SDLC process with documented methods/techniques/practices, and (b) obtain proof from that developer that they actually follow it in practice. The control is satisfied by enforceable requirements plus repeatable evidence, not by a one-time statement or marketing description of “secure development.” ¹

Plain-English interpretation

SA-4(3) means: don’t accept software (or software-driven services) from a developer unless they can show how they build it and how they control risk while building it. “Demonstrate” is the operative word. You need tangible artifacts that show the SDLC exists and is used.

A practical way to read this is: for each in-scope system/component/service, you should be able to answer:

• What SDLC does the developer follow?
• What required practices are part of that SDLC (requirements, design, code, test, release, change control)?
• What artifacts prove those steps happened for the current version/release?

Who it applies to

Entities

• Federal information systems and programs adopting NIST SP 800-53 Rev. 5 controls. ²
• Contractors and other third parties building or operating systems that handle federal data, where NIST SP 800-53 controls are flowed down through contracts, SSPs, or agency requirements. ²

Operational context (where SA-4(3) shows up in real life)

• Custom development by a system integrator, app dev shop, or contractor team.
• SaaS and managed services where the provider continuously deploys code that affects your data.
• COTS/OEM components where you rely on the vendor’s development discipline.
• Internal agile teams shipping changes frequently, where evidence must be captured automatically.

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

1) Define “developer” per scope and make a coverage list

Create a simple inventory that lists:

• System / component / service name
• Developer type (internal team, prime contractor, SaaS provider, OEM)
• Release model (continuous, periodic, ad hoc)
• Where SDLC evidence will come from (Jira, Azure DevOps, GitHub, vendor portal, shared repository)

This prevents the common audit failure: having a great SDLC story for one product while other components are unmanaged.

2) Set minimum SDLC demonstration criteria (your acceptance standard)

Write a one-page SDLC Demonstration Standard that states what “demonstrate” means at your organization. Keep it crisp and auditable. Example criteria you can require from any developer:

• Documented SDLC phases and responsible roles
• Secure coding standard or engineering standard
• Peer review expectations (code review / design review)
• Testing expectations (unit/integration/security testing as applicable)
• Defect tracking and remediation workflow
• Change/release management link to deployed versions
• Evidence retention period and access method (shared folder, GRC tool, vendor repository)

You are not forced into a specific SDLC model; you are defining what proof you require.

3) Flow the requirement into contracts and third-party obligations

For third parties, add language to:

• MSAs / SOWs
• Security addenda
• Supplier code of conduct (if used for engineering suppliers)
• Right-to-audit / assessment cooperation clauses

Minimum contract outputs to demand:

• SDLC policy/process documentation
• A sample “release evidence pack” on request
• Notice obligations for material SDLC changes (process changes that reduce controls)

If the third party refuses to share sensitive artifacts (common with SaaS), require a demonstration format: read-only walkthrough, sanitized samples, or independent assessment outputs that map to your SDLC criteria. The key is you can still show an assessor what you reviewed and what decision you made.

4) Build an “evidence map” from SA-4(3) to artifacts, owners, and frequency

Operationalize with a control mapping that names:

• Control owner (usually AppSec, Engineering Enablement, or Vendor Risk; GRC coordinates)
• Evidence producer (DevOps lead, vendor security contact)
• Collection method (automated export, quarterly request, per-release pack)
• Review step (who signs off, where tracked)

This aligns with the recommended operational control: map SA-4(3) to an owner, procedure, and recurring evidence artifacts. ¹

Where Daydream fits naturally: use Daydream to assign ownership, schedule recurring evidence requests from third parties, and store the evidence map and release-level proof in one assessment-ready record. That reduces the “spread across email and tickets” failure mode.

5) Implement SDLC “gates” that produce audit-ready proof

Translate your SDLC Demonstration Standard into release gates. A gate is only as good as its audit trail.

Practical gates:

• Requirements gate: feature has approved requirements and security requirements (where relevant) tied to tickets.
• Design gate: architectural/design review record exists for material changes.
• Build gate: CI pipeline logs show build and checks ran.
• Review gate: pull request approvals / peer review evidence exists.
• Test gate: test run records attached to release.
• Release gate: change record links to deployment/version, rollback plan if required.

For internal teams, these can be enforced in CI/CD and repo settings. For third parties, enforce through acceptance criteria, operational scorecards, and periodic evidence demonstrations.

6) Run a verification cadence (don’t treat it as one-and-done)

Set a recurring operational rhythm:

• Onboarding: confirm SDLC documentation and a sample evidence pack.
• Ongoing: verify for a selected release/change window that artifacts exist and match your standard.
• Material changes: re-verify if the developer changes tooling, outsourcing model, or release practices.

You are building a repeatable proof process, not a binder.

Required evidence and artifacts to retain

Keep evidence in a form an assessor can follow without interpretation. Recommended artifacts:

• SDLC policy/process document (developer-authored)
• Secure coding standard (internal or developer-provided)
• Role definitions (who approves what)
• Sample release evidence pack ¹, containing:
  • Requirements/ticket export or trace list
  • Design review notes (or architecture decision records)
  • Code review logs (PR approvals, review checklist)
  • CI/CD run logs for the release
  • Test results summary (unit/integration; security testing where applicable)
  • Defect list and remediation notes for material issues
  • Release/change record mapping version to deployment date/environment
• Your internal review record:
  • Evidence request, what you received, who reviewed, findings, remediation requests, and closure

Common exam/audit questions and hangups

Auditors and assessors tend to press on “demonstrate” and “includes”:

• “Show me the developer’s SDLC documentation and where you reviewed it.” ¹
• “Show me evidence for a specific release that the SDLC was followed.”
• “How do you ensure third-party developers meet the same expectations as internal developers?”
• “What happens when required artifacts are missing? Who can approve an exception?”
• “How do you handle agile/continuous delivery without drowning in evidence?”

Hangups you can preempt:

• Evidence exists but is not tied to a release/version.
• The organization has an SDLC document but no proof teams follow it.
• Third-party assessments are collected, but they don’t map to SDLC practices you require.

Frequent implementation mistakes and how to avoid them

1. Mistake: Treating a SOC 2 report as SDLC demonstration.
   Fix: Accept it only as supplemental, and still require an SDLC description plus a demonstrable release evidence set aligned to your criteria.

2. Mistake: Writing an SDLC policy that engineering never uses.
   Fix: Make gates real (repo branch protections, CI required checks) and capture logs automatically.

3. Mistake: Evidence sprawl across tools with no index.
   Fix: Maintain an evidence register per system/service: what artifacts exist, where, for which release, and who reviewed.

4. Mistake: Over-collecting sensitive artifacts from third parties.
   Fix: Ask for a demonstration and a curated evidence pack. Document what you reviewed and why it was sufficient.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat SA-4(3) primarily as an assessment and authorization readiness risk. The practical risk is straightforward: if you cannot show a developer’s SDLC discipline, you increase the odds of insecure design, weak testing, and uncontrolled changes entering production, and you may fail control assessments tied to NIST SP 800-53 programs. ³

Practical 30/60/90-day execution plan

First 30 days (establish the standard and scope)

• Name the control owner and backups; document RACI for evidence production and review.
• Build the in-scope system/component/service list and identify each developer.
• Publish the one-page SDLC Demonstration Standard (your acceptance criteria).
• Update third-party intake to request SDLC documentation and a demonstration path.

Days 31–60 (make it enforceable and test it)

• Add SA-4(3) SDLC demonstration language to contract templates and SOW addenda.
• Pilot evidence collection on one internal system and one third-party service.
• Create a repeatable “release evidence pack” template and a review checklist.
• Stand up a single evidence repository and indexing method (GRC system or controlled document store).

Days 61–90 (scale and operationalize)

• Roll the SDLC gates into engineering workflows (repo settings, CI required checks) for internal teams.
• For third parties, schedule recurring demonstrations and integrate evidence requests into vendor governance.
• Track exceptions with documented compensating controls and expiration dates.
• Prepare an assessor-ready packet: standard, scope list, two completed evidence packs, and your review records.

Frequently Asked Questions

Does SA-4(3) force us to adopt a specific SDLC model (waterfall vs agile)?

No. The requirement is that the developer demonstrates use of an SDLC process with defined practices and proof. You can accept agile or iterative models if the artifacts show disciplined requirements, review, testing, and release control. ¹

How do we satisfy SA-4(3) with a SaaS provider that won’t share internal engineering artifacts?

Require a structured demonstration: documented SDLC overview, a walkthrough of their controls, and a sanitized sample of release evidence mapped to your acceptance criteria. Document what you reviewed, any gaps, and your risk decision.

What evidence is “enough” to prove the developer follows their SDLC?

You need artifacts that trace a real change from requirements through review, testing, and release, plus your internal record that you evaluated those artifacts. A policy alone rarely meets the “demonstrate” bar. ¹

Who should own SA-4(3): GRC, engineering, or procurement?

GRC should own control governance and assessment readiness, but engineering/AppSec should own the SDLC standard and internal gates. Procurement or third-party risk should own contract flow-downs and evidence requests for third parties.

How do we handle open-source components under SA-4(3)?

Treat the “developer” as your internal team that selects, integrates, and ships the component. Your SDLC demonstration should show how you evaluate components, track versions, test, and control changes before release.

How can Daydream help without turning this into a paperwork exercise?

Use Daydream to map SA-4(3) to an owner, procedure, and recurring evidence artifacts, then automate evidence collection tasks and store release evidence packs with review notes. That keeps proof tied to the control instead of scattered across tickets and email. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5

3. NIST SP 800-53 Rev. 5; Source: NIST SP 800-53 Rev. 5 OSCAL JSON