SA-10(5): Mapping Integrity for Version Control

SA-10(5) requires you to prove that the “master build” description of your current security-relevant hardware, software, and firmware matches the authoritative on-site master copy, and that the linkage between them cannot be tampered with. Operationalize it by controlling where build truth lives, cryptographically protecting mappings, and reconciling every release to the deployed baseline ¹.

Key takeaways:

• Define one authoritative “master build data” source and one authoritative on-site master copy, then lock down who can change either.
• Protect the mapping with integrity controls (hashing/signing, controlled commits, immutable logs) and reconcile it each release.
• Keep audit-ready evidence: baselines, mapping tables, approvals, reconciliation results, and exception handling.

SA-10(5): mapping integrity for version control requirement is a supply chain and build integrity control disguised as paperwork. Examiners read it as a simple question: “Can you prove the version you say you run is the version you actually built and deployed, and can you show the mapping hasn’t been manipulated?” The control is scoped to security-relevant hardware, software, and firmware because those elements define your attack surface and determine whether security fixes are real or performative.

This requirement shows up most often when you rely on a third party developer, integrator, managed service provider, or product team to deliver a system component that your environment depends on. It also matters for internal development teams, because “developer” in practice includes any party that creates builds and provides build metadata to operations.

To implement SA-10(5) quickly, treat “master build data” as an authoritative bill of materials for the current version (what was built), treat the “on-site master copy” as the authoritative record you hold (what you accept and run), and then make the mapping between them verifiable and resistant to unauthorized change ¹.

Regulatory text

Requirement (quoted): “Require the developer of the system, system component, or system service to maintain the integrity of the mapping between the master build data describing the current version of security-relevant hardware, software, and firmware and the on-site master copy of the data for the current version.” ¹

What the operator must do:

1. Identify what “master build data” is for your system/component/service, 2) identify what “on-site master copy” you retain as your authoritative record, 3) define the mapping between them (how you link build identifiers to what you store internally), and 4) enforce integrity controls so the mapping can’t be altered without detection and authorization ¹.

Plain-English interpretation

You need a tamper-evident chain from “this is the build we produced” to “this is the build data we keep on-site for the version we operate.” If the developer claims version X is deployed, you must be able to validate that claim using your own controlled copy of the build metadata and a protected mapping that ties the two together.

This is not only a CI/CD question. It’s also a records, governance, and access control question: who is allowed to update build descriptors, where they’re stored, how operations receives them, and how you detect mismatches.

Who it applies to

Entities

• Federal information systems and contractor systems handling federal data that implement NIST SP 800-53 controls ².
• Any organization flowing this control down to third parties through security requirements, including system developers, component suppliers, and managed service providers.

Operational contexts where SA-10(5) shows up

• You buy software or a managed service and rely on the provider’s release notes/build artifacts to understand what’s running.
• You deploy firmware (network devices, appliances, endpoints, OT/IoT) where version drift is common and rollback paths exist.
• You operate regulated environments where “baseline configuration” and “approved version” must match what is deployed (for example, authorization-to-operate style control sets).

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

Step 1: Define the two authoritative records (“build truth” and “site truth”)

Create a short, written definition for each, per system/component:

• Master build data (developer-owned): build identifiers, source commit/tag, build pipeline run ID, artifact digests, SBOM if you require it, firmware image identifiers, and a list of security-relevant dependencies.
• On-site master copy (your-owned): the copy you store in your controlled environment (secure repository, CMDB attachment store, GRC evidence vault) that represents the accepted “current version” build data.

Operational decision: pick one system of record for on-site master copies and stop scattering evidence across tickets, emails, and chat exports. Scattered storage is a common reason mappings fail integrity review.

Step 2: Specify the mapping format (make it machine-checkable)

Create a mapping record that connects developer build data to your on-site master copy. Keep it simple and auditable. A practical schema:

• System/component name and environment scope
• Version string and unique build ID
• Artifact digest(es) (hash)
• Firmware/hardware identifiers (model + firmware version, where applicable)
• Pointer to on-site master copy location (repository path, evidence ID)
• Approval reference (change ticket, release approval, CAB record)
• Date/time and approver identity

Use a structured file (JSON/YAML) stored in version control, or a controlled database table with audit logs. The key is consistent, repeatable reconciliation.

Step 3: Protect integrity of the mapping (technical + procedural)

SA-10(5) is an integrity requirement. Integrity needs both detection and prevention.

Minimum control set that auditors understand:

• Write controls: restrict who can modify the mapping and on-site master copies (least privilege, break-glass where needed).
• Change control: require peer review/approval for mapping changes (pull request approvals or equivalent).
• Tamper evidence: sign or hash mapping records, or store them in a system with immutable/audited history (for example, signed commits; WORM/immutable logs where feasible).
• Separation of duties: the developer who produces build data should not be the sole party able to update the on-site master copy without independent review.

If you need to operationalize fast, start with signed commits and protected branches in your version control platform plus an audit-logged evidence repository. Then harden over time.

Step 4: Reconcile every release to “what is deployed”

Build a release gate that checks mapping integrity before production promotion:

• Confirm the build artifact digest matches what is being deployed.
• Confirm the on-site master copy is updated to the new “current version” build data.
• Confirm the mapping record points to the right on-site master copy and is approved.
• Confirm production inventory/telemetry (where available) matches the approved version (agent reports, device inventory exports, or deployment tool state).

Document how you handle exceptions (emergency patches, hotfixes, failed deployments, partial rollouts). Auditors will ask what happens when the world isn’t clean.

Step 5: Flow requirements to third parties (if they develop or supply components)

Update contracts/SOWs/security addenda so the developer must:

• Provide master build data with unique build identifiers and integrity metadata (hashes/signatures).
• Support your retention of an on-site master copy for each current version.
• Support investigations: furnish build provenance evidence on request.

Keep the language specific to “master build data,” “on-site master copy,” and “integrity of mapping” so you can test it.

Step 6: Assign ownership and run it as a recurring control

Set clear ownership:

• Control owner: AppSec, platform security, or release engineering.
• Operators: build/release engineering and IT operations/configuration management.
• Second line: GRC validates evidence completeness and tests sampling.

If you use Daydream to manage third-party risk and control evidence, map SA-10(5) to a single owner, a single procedure, and a recurring evidence bundle so you can answer assessor questions without rebuilding the story each time ¹.

Required evidence and artifacts to retain

Keep evidence in a single place per system/component, with clear versioning:

1. Policy/procedure

• Secure SDLC or release management procedure describing master build data, on-site master copy, mapping, approvals, and reconciliation steps.

2. System-specific mapping artifacts

• Mapping table/file for the current version and recent prior versions (to show continuity).
• Proof of integrity controls: signed commits, protected-branch settings screenshots/exports, audit logs, or hash/signature records.

3. Release/change artifacts

• Release approval record (ticket/CAB).
• CI/CD pipeline run record (build ID, artifact digest).
• Deployment record showing what went to production.

4. Reconciliation outputs

• Evidence that deployed versions match the mapping (inventory report, deployment tool output, or attestation with supporting logs).

5. Exception handling

• Emergency change approvals, post-implementation review notes, and remediation actions when mismatches occur.

Common exam/audit questions and hangups

Use these as a pre-audit checklist:

• “Show me the master build data for the current version, and show me your on-site master copy.”
• “Where is the mapping stored, and who can change it?”
• “How do you detect if someone altered the mapping after the fact?”
• “Demonstrate the last production release: build ID, artifact hash, approval, and deployed version evidence.”
• “How do you handle firmware where the ‘developer’ is a manufacturer and you only get release notes?”
• “What happens if the build pipeline is run twice for the same version tag?”

Hangups happen when teams confuse “release notes” with “master build data,” or when on-site master copies are just PDFs attached to tickets with no integrity controls.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails SA-10(5)	Fix
Mapping exists only in a spreadsheet	Easy to alter; no audit trail	Store mapping in version control with approvals and signing, or in a system with immutable audit logs
“On-site master copy” is in a developer-controlled tool	You don’t control integrity or retention	Replicate/export to your controlled repository and define it as authoritative
No link from mapping to approvals	Assessor can’t validate legitimacy	Add change ticket IDs and approver identities into mapping records
Artifact hashes not captured	You can’t verify what was deployed	Record digests for build artifacts/firmware images and reconcile to deployment
Third party provides vague version statements	No objective version evidence	Contractually require build identifiers + integrity metadata, or document compensating controls

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. Treat SA-10(5) as an assessment-readiness and supply chain integrity control: failures commonly surface as audit findings, authorization delays, and incident response friction because you cannot prove what you are running ².

Practical execution plan (30/60/90-day)

These phases are designed for quick operationalization without assuming tool changes.

First 30 days (stabilize “truth sources”)

• Name the systems/components in scope and the “developer” parties for each.
• Define master build data fields and the on-site master copy repository location.
• Implement access controls: restrict write access; require approvals for changes to mappings.
• Create a mapping template and backfill it for the current production version.

By 60 days (make it testable and repeatable)

• Add a release checklist step: mapping update + on-site master copy update is required before production promotion.
• Start capturing artifact hashes/digests and attach them to mapping records.
• Run a reconciliation drill on a recent release and document results and gaps.

By 90 days (harden integrity and expand coverage)

• Add cryptographic integrity: signed commits, signed artifacts, or an immutable log trail for mapping changes.
• Flow requirements to third parties in contract language and onboarding checklists.
• Implement periodic sampling: pick recent releases/firmware updates and prove mapping integrity end-to-end.

Frequently Asked Questions

What counts as “master build data” if we buy a SaaS and don’t build anything?

Treat the provider’s release/build metadata as master build data, then store your on-site master copy as the authoritative record you retain. If the provider can’t supply build IDs or integrity metadata, document compensating controls and contract requirements for future renewals ¹.

Does SA-10(5) require SBOMs?

The text does not explicitly require an SBOM. An SBOM can be part of master build data if you require it, but SA-10(5) focuses on integrity of the mapping between build data and your on-site master copy ¹.

What is the “on-site master copy” in a cloud-first environment?

“On-site” should be interpreted as “under your control” for retention and integrity, even if the storage is cloud-hosted. Use a controlled repository with access controls and audit logs, and define it as the authoritative master copy in your procedure.

How do we handle firmware where we only have vendor release notes and a version number?

Capture the firmware image identifier and a hash of the image you deploy, then store those as your on-site master copy and map them to the supplier’s published version. If you cannot obtain the image hash, document the limitation and implement stronger inventory verification and restricted update processes.

Who should own this control: GRC or engineering?

Engineering (release engineering, platform, or IT operations) should operate the mapping and reconciliation because they control build and deployment. GRC should define evidence expectations, test samples, and track exceptions to closure.

What evidence is most persuasive in an audit?

A single release packet that ties together build ID, artifact hash, mapping record history, approval, and deployed-version verification. Auditors reward traceability and controlled change history more than narrative explanations.

Footnotes

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

2. NIST SP 800-53 Rev. 5