SA-5: System Documentation

To meet the sa-5: system documentation requirement, you must obtain or create administrator-facing documentation for each in-scope system (and key components/services) and keep it accurate enough that qualified admins can securely configure, operate, troubleshoot, and maintain it. Operationalize SA-5 by assigning an owner, standardizing a documentation set, and collecting recurring evidence that the docs exist, are current, and are actually used.

Key takeaways:

• SA-5 is about administrator documentation (runbooks, configuration standards, diagrams, procedures), not end-user help.
• Auditors look for coverage and currency: every in-scope system has docs, and updates track system changes.
• The fastest path is to standardize templates, map to owners, and retain change-linked revision evidence.

SA-5 sits in the NIST SP 800-53 “System and Services Acquisition” family, but it functions like a day-to-day operations control: if administrators cannot reliably configure or maintain a system, security controls drift, outages last longer, and recoveries get messy. For a Compliance Officer, CCO, or GRC lead, the practical challenge is never “write documentation once.” It is building a repeatable way to ensure documentation exists for every in-scope system, stays aligned to reality after changes, and can be produced quickly during an assessment.

This page translates SA-5 into an implementation checklist you can run with your engineering and IT operations leads. You will set scope, define what “administrator documentation” means for your environment (cloud, SaaS, on-prem, hybrid), assign ownership, build a minimum documentation baseline, and create evidence that stands up in an audit. The goal is assessment readiness without turning documentation into a bureaucracy that teams ignore.

Regulatory text

Requirement excerpt: “Obtain or develop administrator documentation for the system, system component, or system service that describes:” ¹

What the operator must do: SA-5 requires you to have administrator documentation available for the system and relevant underlying parts (components/services). In practice, that means you either (a) obtain documentation from the provider or integrator, or (b) develop and maintain internal documentation that explains how administrators securely deploy, configure, operate, and maintain the system. ²

Plain-English interpretation

SA-5 is a documentation control with an operational bite: administrators need authoritative, accessible, and current instructions for running the system safely. If the system depends on third-party services (cloud services, managed databases, identity providers), SA-5 still expects you to document your administration model: what you configured, how it should be configured, who can change it, and how you detect and recover from failure.

A useful way to interpret SA-5 for execution:

• “Obtain” means you can rely on third-party documentation only if it matches how you deployed the system and your required security settings.
• “Develop” means you create internal runbooks and configuration standards that reflect your exact environment (accounts, regions, network boundaries, keys, roles, logging destinations).
• “Administrator documentation” means the materials your ops and security admins use, not general product manuals.

Who it applies to (entity and operational context)

SA-5 is commonly applied in:

• Federal information systems and programs that assess against NIST SP 800-53. ³
• Contractor systems handling federal data, including environments built to satisfy federal customer security requirements. ³

Operationally, SA-5 applies anywhere you have administrators who:

• Provision infrastructure (IaC, cloud consoles, hypervisors).
• Configure security services (IAM, SIEM, EDR, key management).
• Maintain applications and data stores.
• Run incident response and disaster recovery.

If your environment is SaaS-heavy, SA-5 still applies. You will document the administrative layer you control: tenant configuration, role design, SSO, logging, data retention, integrations, and operational procedures.

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

1) Define SA-5 scope using your system inventory

Output: a list of in-scope systems, and for each, the “admin surface.”

• Start from your authoritative inventory (CMDB, asset inventory, SSP boundary list).
• For each system, identify key components/services that admins touch: identity, network, compute, storage, CI/CD, monitoring, backup, secrets.
• Decide what “system component or system service” means in your org. Document that scoping logic once so it is consistent across assessments.

2) Assign ownership and establish documentation standards

Output: RACI plus a documentation baseline.

• Name a control owner (usually GRC) responsible for SA-5 governance and evidence.
• Name a system documentation owner for each system (usually the system owner or ops lead).
• Publish a minimum documentation set (template) that every system must have. Keep it short and enforceable.

A practical minimum baseline for administrator documentation:

• System overview & boundary: purpose, environments, dependencies, data types handled, external integrations.
• Architecture diagram(s): network boundaries, trust zones, critical flows (at least one “admin-relevant” diagram).
• Admin access model: roles, MFA/SSO, break-glass accounts, privileged access process.
• Configuration standards: required settings for logging, encryption, key rotation approach, baseline hardening choices.
• Operational runbooks: deploy/redeploy, scaling, routine maintenance, patching approach, certificate/secret renewal, log review pointers.
• Monitoring & alerting: what “good” looks like, key dashboards, alert routes, on-call expectations.
• Backup/restore and recovery: RTO/RPO targets if defined internally, restore steps, validation steps.
• Change control linkages: how changes are requested/approved and how docs are updated as part of change.

3) Build or obtain the documentation, then normalize it

Output: consistent, accessible docs stored in a controlled repository.

• If you “obtain” docs from a third party (cloud/SaaS/provider), add an internal overlay: “Our tenant configuration and admin procedures.”
• Normalize format and location. Pick one system of record (wiki with versioning, Git repo, or a controlled document management platform).
• Add a simple “last reviewed” and “owner” field on every doc page to make audit collection fast.

4) Tie documentation updates to operational workflows

Output: a mechanism that prevents documentation drift.

• Add a step to your change process: “Documentation updated or not required.” Require justification if “not required.”
• For infrastructure-as-code teams, treat docs as part of the repo: README/runbook updates in the same pull request as the change.
• For SaaS administration, tie doc updates to your ticketing workflow (e.g., change tickets must include doc link updates).

5) Prove the docs are controlled, current, and usable

Output: recurring evidence that SA-5 operates.

• Version history: show edits tied to changes.
• Access control: show only authorized maintainers can edit critical runbooks, and readers have appropriate access.
• Review cadence: set an internal review expectation (risk-based). Record reviews even when no changes are needed.

6) Map SA-5 to control operations and evidence (make it auditable)

Output: a control operating procedure that an auditor can follow.

• Create a one-page SA-5 control procedure: scope, owners, required artifacts, where they live, and how updates happen.
• Track coverage: a simple matrix listing systems vs. required documentation artifacts and links.
• If you use Daydream, set SA-5 up as a requirement with assigned owners, link each system’s documentation repository, and schedule evidence requests so you always have current screenshots/exports and change-linked samples ready for assessors.

Required evidence and artifacts to retain

Keep evidence that answers three questions: Does it exist? Is it accurate enough? Is it maintained?

Core artifacts

• System documentation index ¹ with links to each required document/runbook.
• Administrator runbooks and configuration standards (current versions).
• Architecture diagrams and dependency maps.

Operational evidence

• Change records or pull requests showing documentation updated alongside system changes.
• Version history exports (wiki/Git) showing authorship and dates.
• Access control evidence for the documentation repository (role list, permissions screenshots/exports).
• Periodic review records (tickets, attestations, meeting notes) showing review completion and remediation items.

Assessment packaging tip: maintain an “SA-5 evidence folder” per system containing a dated export/PDF of key runbooks plus a short changelog sample tied to a recent change.

Common exam/audit questions and hangups

Expect assessors to probe:

• Coverage: “Show me administrator documentation for System X and its supporting services.”
• Specificity: “Does this describe your configuration, or is it generic vendor documentation?”
• Currency: “How do you ensure docs are updated after changes?”
• Access and control: “Who can edit these runbooks? How do you prevent unauthorized changes?”
• Operational use: “How do admins find the right procedure during an incident?”

Common hangup: teams provide an SSP or policy and call it documentation. SA-5 expects admin-operational documentation that someone can execute.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails SA-5	Fix
Relying only on third-party manuals	Vendor docs rarely reflect your tenant, roles, logging, and integrations	Add an internal “how we run it” overlay per system/service
Documentation exists but is scattered	Auditors can’t confirm completeness; admins can’t find it	Define one repository and an index per system
No link to change management	Docs drift; configuration diverges from baseline	Require doc updates in change tickets/PRs
Runbooks are aspirational	Steps don’t work under pressure	Run a tabletop or admin dry-run and update the procedure
No ownership	Docs rot because “everyone” owns them	Assign a named owner per system with backup

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for SA-5. Treat SA-5 risk as practical and compounding: weak admin documentation increases the likelihood of misconfiguration, inconsistent security settings, and slower recovery during incidents. It also raises assessment risk because SA-5 is easy for auditors to test: they ask for the runbook, then test whether it matches reality.

A practical 30/60/90-day execution plan

First 30 days: establish control design and minimum coverage

• Confirm in-scope systems and define what counts as “system component/service” for documentation purposes.
• Publish SA-5 documentation templates and minimum baseline artifacts.
• Assign owners and build the system-by-system documentation index.
• Collect and centralize what already exists. Flag gaps.

Days 31–60: close gaps and integrate into operations

• Draft missing runbooks and configuration standards for high-risk or high-change systems first.
• Add doc-update checks to change workflows (tickets and/or PR templates).
• Lock down permissions for doc repositories; document who can edit and approve.

Days 61–90: make it sustainable and assessment-ready

• Run a documentation quality review with ops: pick a recent incident or change and validate the runbook would have worked.
• Package evidence: version history samples, change-linked updates, and repository access evidence.
• In Daydream, map SA-5 to the control owner, implementation procedure, and recurring evidence artifacts so evidence stays current without manual chasing. ¹

Frequently Asked Questions

Does SA-5 require documentation for every microservice?

Scope it to what is treated as a “system” in your boundary and inventory, then include admin-relevant components and shared services. If microservices are operated independently with separate admin procedures, document them as separate components or bundles under the parent system.

Can we satisfy SA-5 with vendor documentation links?

Only if the vendor documentation plus your internal notes fully describe how administrators operate your specific deployment. Most teams still need an internal runbook covering tenant-specific settings, access roles, logging, and recovery steps. ¹

What level of detail is “enough” for administrator documentation?

Enough that a qualified admin can safely perform routine operations and recovery without guessing. If your runbook can’t answer “who has access, where logs go, how to rotate secrets, how to restore,” it’s usually too thin.

How do we show documentation is maintained, not shelfware?

Tie doc updates to change records or pull requests, and retain version history plus a small sample of change-linked updates. Auditors accept lightweight review records if they are consistent and traceable.

Our docs are in Confluence and our runbooks are in Git. Is that a problem?

Mixed tooling is fine if you have a clear index that points to the authoritative location for each artifact and you control access and versioning. The audit failure mode is “we think it’s documented, but we can’t find it quickly.”

Who should own SA-5: security or engineering?

GRC or security typically owns the control and evidence process, while engineering/IT owns the content for each system. The clean model is one control owner plus a named documentation owner per system.

Footnotes

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

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

3. NIST SP 800-53 Rev. 5