SA-10(3): Hardware Integrity Verification

SA-10(3) requires you to contractually require the system or component developer (including your hardware OEM/ODM and key integrators) to enable hardware integrity verification, then operate a repeatable process to verify hardware hasn’t been altered across manufacturing, shipping, installation, and lifecycle changes ¹. Do this by defining technical verification methods, gating acceptance, and retaining objective evidence.

Key takeaways:

• Put the obligation on the developer: integrity verification must be enabled, not “best effort” ¹.
• Treat this as a supply chain + operations control: verify at receipt, during maintenance, and after changes.
• Auditors look for enforceable contract language plus verifiable artifacts (test results, attestation, acceptance records).

The sa-10(3): hardware integrity verification requirement is a practical “make it provable” control. You are not being asked to believe a supplier’s quality program. You are being asked to require the developer of a system, system component, or system service to enable integrity verification of hardware components and to be ready to demonstrate that you can actually perform (or obtain) that verification ¹.

For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing SA-10(3) is to treat it like a procurement-and-acceptance gate backed by a runbook: (1) define what “hardware integrity verification” means for your environment, (2) embed it into contracts and purchase orders, (3) verify at defined lifecycle points, and (4) retain evidence that a third party enabled verification and that you performed it.

This page focuses on requirement-level implementation you can hand to procurement, engineering, and IT operations without rewriting it into theory. It also flags the common audit hangups: “enabled” is vague unless you translate it into concrete methods, acceptance criteria, and evidence.

Regulatory text

Requirement (verbatim): “Require the developer of the system, system component, or system service to enable integrity verification of hardware components.” ¹

Operator meaning: You must impose a requirement on the developer (often a third party) that hardware integrity verification is possible in practice. “Enable” means the hardware and supporting processes must provide a feasible way to verify integrity (for example, supported mechanisms, documentation, and access to verification outputs), not a promise that the hardware is “secure.”

What an assessor will expect you to show:

• A binding requirement in contracts/POs/SOWs for covered hardware and integrators.
• A defined verification method (what you check and how you check it).
• Evidence you performed verification at the points you claim (receipt, deployment, break/fix, RMA, firmware changes).
• A control owner and a repeatable evidence pack ².

Plain-English interpretation

SA-10(3) is a supply chain integrity control focused on hardware. Your goal is to prevent (and detect) tampering, substitution, unauthorized modifications, and counterfeit components by ensuring that the developer/manufacturer provides the hooks and documentation needed to verify hardware integrity. If integrity can’t be verified, you either (a) don’t accept the hardware for the in-scope system, or (b) implement compensating controls and document the exception rationale.

Who it applies to

Entities

• Federal information systems and organizations aligning to NIST SP 800-53 requirements ².
• Contractors handling federal data or building/operating systems for federal customers where NIST SP 800-53 is contractually flowed down ².

Operational contexts (where this shows up)

• Data centers, network infrastructure, endpoint fleets, OT/IoT deployments.
• Cloud-connected appliances with vendor-managed hardware/firmware.
• Any environment where you procure hardware components, appliances, or managed hardware services and must defend against supply chain manipulation.

Typical in-scope “developers”

“Developer” is broader than your internal engineers. In practice it includes:

• OEM/ODM hardware manufacturers
• Appliance vendors
• System integrators and VARs that configure/modify systems before delivery
• Managed service providers that supply hardware as part of a service

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

1) Assign control ownership and define scope

1. Name a control owner (often Supply Chain Security, Security Engineering, or IT Asset Management).
2. Define covered hardware categories (e.g., network gear, servers, secure endpoints, specialized appliances).
3. Define lifecycle events requiring verification: receiving, initial deployment, after maintenance/RMA, after firmware updates, after custody changes.

Output: SA-10(3) control statement + scope note in your control library ².

2) Translate “integrity verification” into concrete acceptance criteria

Create a short standard that answers:

• What signals prove integrity? (e.g., device identity, component authenticity, firmware integrity state, measured boot logs, tamper-evident features, serial/part number validation)
• What tools collect those signals? (vendor tooling, platform attestation, secure boot status outputs, inventory reconciliation)
• What fails acceptance? (missing attestation support, unverifiable supply chain custody, mismatched identifiers, unsupported integrity checks)

Tip: Keep this as a one-page “Hardware Integrity Verification Standard” you can attach to contracts.

3) Flow requirements down to the developer (contracting)

Add contract language requiring the developer to:

• Provide integrity verification capability and documentation.
• Provide verification outputs/attestations on request.
• Notify you of hardware/firmware changes that affect verification.
• Support audits or provide evidence packages.

Practical clause checklist (use as a template):

• “Supplier shall enable integrity verification of hardware components delivered under this agreement…” ¹
• “Supplier shall provide procedures and tooling to verify authenticity and integrity upon receipt and after service events.”
• “Supplier shall provide an attestation letter describing the integrity verification mechanisms supported by the delivered models.”

Where Daydream fits: Daydream can track SA-10(3) as a requirement with a mapped owner, implementation procedure, and recurring evidence artifacts, so you can show a consistent control story across suppliers and systems ¹.

4) Build an operational verification runbook (receiving + lifecycle)

Minimum runbook sections:

• Receiving inspection: packaging/tamper checks, serial capture, model/part validation, custody documentation.
• Technical verification: execute the defined integrity checks (secure boot state, firmware signature validation where supported, inventory/identity checks).
• Quarantine workflow: if verification fails or is unavailable, hold in a quarantine state pending security review.
• Exception handling: document compensating controls and risk acceptance where verification can’t be enabled.

5) Gate acceptance and production deployment

Make verification a deployment prerequisite:

• “No production deployment without integrity verification evidence attached to the asset record.”
• Integrate with ITAM/CMDB so each device has integrity verification status and date.

6) Monitor changes that can invalidate verification

Create triggers for re-verification:

• RMA/repair returns
• Firmware/BIOS updates
• Hardware swaps
• Chain-of-custody breaks (shipment reroutes, storage provider changes)

7) Assess and improve

Perform periodic sampling-based reviews:

• Sample asset records for evidence completeness.
• Review supplier performance against contract requirements.
• Track exceptions and drive them down through procurement changes.

Required evidence and artifacts to retain

Keep evidence tied to the specific hardware model and asset identifiers.

Contracting artifacts

• Contract/SOW/PO language requiring integrity verification enablement ¹
• Supplier attestation letter or technical statement describing supported integrity verification mechanisms
• Supplier documentation links and versioned copies where practical

Operational artifacts

• Receiving logs: serial numbers, part numbers, shipment identifiers, custody notes
• Integrity verification outputs: command outputs, screenshots, logs, attestation reports, secure boot state evidence
• Acceptance record: ticket or approval showing pass/fail decision
• Exception records: risk acceptance, compensating controls, and expiration/review date
• Change records: maintenance/RMA tickets triggering re-verification

Control governance artifacts

• Control procedure/runbook
• Control owner assignment and RACI
• Evidence collection schedule and storage location mapping (Daydream can track the evidence set and due dates) ².

Common exam/audit questions and hangups

Assessors tend to probe these areas:

1. “Who is the developer, and how did you require enablement?”
   They will want to see explicit contract terms or equivalent binding requirements ¹.

2. “Define integrity verification for your environment.”
   “We trust the OEM” is not a control. Show your standard and acceptance criteria.

3. “Show me evidence for a sample of devices.”
   Expect request for asset IDs, verification logs, and acceptance tickets.

4. “What happens when verification is not possible?”
   They will look for a quarantine/exception process with documented approvals.

5. “How do you handle lifecycle events?”
   If you only verify at receipt, your story breaks after the first RMA.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Treating SA-10(3) as a policy-only statement	“Enable” implies technical capability and evidence	Define methods, runbook, and artifact list
Contract language says “reasonable efforts”	Not enforceable; supplier can decline evidence	Use “shall provide” / “shall enable” and specify outputs
Only verifying packaging tamper seals	Doesn’t prove component/firmware integrity	Add technical verification evidence where supported
Evidence not tied to specific assets	Auditors can’t trace controls to inventory	Store outputs in CMDB/ITAM record per serial
No process for RMAs and repairs	Integrity status becomes stale	Trigger re-verification on service events

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not list enforcement examples.

Operationally, SA-10(3) addresses supply chain risks that matter to mission and regulated operations: counterfeit parts, tampered firmware, unauthorized component substitution, and loss of device trust. Integrity verification enablement reduces your dependence on supplier assurances and gives incident response a defensible baseline (“known good” versus unknown state).

Practical 30/60/90-day execution plan

First 30 days (foundation)

• Assign control owner and publish SA-10(3) control statement and scope.
• Draft the “Hardware Integrity Verification Standard” (acceptance criteria + methods).
• Update procurement templates with required clauses for integrity verification enablement ¹.
• Choose evidence repository locations and naming conventions; configure Daydream tracking for owner, procedure, and recurring artifacts ².

Days 31–60 (pilot and integration)

• Pilot the runbook on one hardware category (for example, network appliances) and one supplier.
• Integrate verification gating into receiving and deployment workflow (ticketing + CMDB).
• Build exception workflow: quarantine, escalation, compensating controls, approval.

Days 61–90 (scale and stabilize)

• Expand to additional hardware categories and suppliers.
• Run an internal assessment: sample devices, validate evidence traceability, test re-verification triggers (RMA, firmware change).
• Report metrics qualitatively to leadership: where verification is supported, where exceptions remain, and procurement actions needed.

Frequently Asked Questions

Does SA-10(3) mean we have to design our own hardware integrity tooling?

No. The requirement is to require the developer to enable integrity verification and to be able to perform or obtain verification results ¹. You can use vendor-provided mechanisms if they produce auditable evidence.

Who counts as the “developer” for COTS hardware?

The OEM/ODM is commonly the developer, but integrators and appliance vendors that modify configuration or firmware before delivery can also be developers for your purposes. Your contract should bind the party delivering the system/component to provide the enablement and evidence.

What if a supplier refuses to provide integrity verification outputs?

Treat it as a procurement risk decision. Either select a supplier that can meet the requirement, negotiate stronger terms, or document an exception with compensating controls and an exit plan tied to your risk governance ².

Is packaging inspection enough to satisfy SA-10(3)?

Packaging checks help, but SA-10(3) focuses on enabling integrity verification of hardware components, which usually requires technical verification or verifiable provenance beyond box condition ¹.

How do we show this control is operating, not just designed?

Maintain a sample-ready evidence pack: a contract clause, the verification standard, and per-asset verification outputs with acceptance records. Daydream can keep the owner/procedure/artifact mapping current so you can answer evidence requests quickly ².

What systems should we prioritize first?

Start with systems that handle federal data, high-impact workloads, and hardware with higher substitution/tampering exposure (network perimeter, authentication infrastructure, critical appliances). Expand after you have a repeatable receiving and re-verification workflow.

Footnotes

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

2. NIST SP 800-53 Rev. 5