SA-11(3): Independent Verification of Assessment Plans and Evidence

Compliance teams often accept developer test results at face value because they arrive packaged as “assessment evidence.” SA-11(3) forces a harder posture: you need an independent party to validate that the developer followed the security and privacy assessment plan as written and that the evidence produced is trustworthy. This is a quality-control requirement applied to security engineering work, not a paperwork exercise.

For a CCO, GRC lead, or Compliance Officer, the fast path is to treat SA-11(3) like an “independent verification gate” in your system development life cycle (SDLC) and your third-party/supplier intake. You define what independence means for your environment, appoint an independent verifier that meets your organization’s criteria, and require a verification report that ties back to the plan and underlying raw evidence.

Operationally, SA-11(3) reduces the risk of misplaced assurance: teams passing an assessment based on incomplete test execution, weak sampling, or evidence that cannot be reproduced. It also improves audit readiness because it standardizes what “credible assessment evidence” looks like across internal developers and third parties providing systems, components, or services. ¹

Requirement overview (SA-11(3))

Target keyword: sa-11(3): independent verification of assessment plans and evidence requirement

SA-11(3) is an enhancement to SA-11 (Developer Testing and Evaluation). It requires an independent agent to verify:

1. the correct implementation of developer security and privacy assessment plans, and
2. the evidence produced during testing and evaluation.

This is not the same as running the tests for the developer. Your obligation is to ensure an independent check exists and is effective.

Regulatory text

NIST’s control enhancement states: “Require an independent agent satisfying {{ insert: param, sa-11.03_odp }} to verify the correct implementation of the developer security and privacy assessment plans and the evidence produced during testing and evaluation; and” ²

What the operator must do:

• Designate an independent agent (internal or external) that meets your organization’s independence criteria for the system and context.
• Require that agent to verify plan execution (tests performed as planned, scope honored, methods appropriate, deviations documented and approved).
• Require that agent to verify evidence integrity (results are attributable, complete, reproducible or re-performable where feasible, and traceable to requirements and fixes).
• Retain a verification package that a third-party assessor or federal authorizing official can review without relying on verbal explanations.

Plain-English interpretation

If the developer says, “We tested security and privacy controls and here are the results,” SA-11(3) says: “Prove it through an independent verifier.” The verifier checks that the testing followed the approved plan and that the supporting artifacts are real, complete, and tied to what was actually built and deployed for the assessed configuration.

Who it applies to

Entities

• Federal agencies operating federal information systems.
• Contractors and service providers handling federal data or operating systems on the government’s behalf (including cloud/service providers in federal scopes). ¹

Operational contexts

• New system development and major releases where security/privacy testing is part of authorization or release gating.
• Supplier-delivered components (COTS, SaaS, managed services, embedded software) where developer testing is presented as assurance.
• High-assurance environments where test evidence must withstand independent assessor scrutiny.

Where teams get stuck: defining “independent” for internal engineering functions and for third parties whose “independent testing” is still performed by a related affiliate.

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

1) Define “independent agent” for your environment

Create a short standard that answers:

• Organizational independence: verifier does not report into the dev team’s management chain for the scoped work.
• Financial/goal independence: verifier is not compensated based on release outcomes or “passing” results.
• Role independence: verifier did not author the assessment plan and did not execute the primary testing they are validating (sampling-based re-performance is fine).
• Competence: verifier has security/privacy testing competence relevant to the tech stack and test methods.

Write this into your SDLC policy or your assessment procedure so it is repeatable.

2) Set the verification scope (what must be checked)

At minimum, require verification of:

• Assessment plan version and approval status.
• Coverage mapping: plan aligns to required security/privacy requirements and system scope.
• Test execution evidence: tests performed, dates, environments, tools, configurations.
• Exceptions/deviations and approvals.
• Evidence integrity: raw outputs exist, are attributable, and match summarized findings.

Practical tip: define minimum sampling rules (qualitative if you cannot standardize yet). For example, require deeper validation for high-risk controls, internet-facing components, identity flows, and encryption boundaries.

3) Implement an “independent verification gate” in your lifecycle

Make independent verification a required gate for:

• Authorization package readiness (if applicable).
• Release approval for major changes.
• Supplier acceptance for systems/components where developer evidence is used to support your control posture.

Avoid informal gates. Put it in your change management workflow with an explicit approval record.

4) Run verification: validate plan execution and evidence

Your independent agent should produce a workpaper trail showing:

• They reviewed the plan and confirmed test steps were executed or deviations were approved.
• They traced a sample of results back to raw evidence (logs, tool outputs, screenshots, test scripts, tickets).
• They confirmed the assessed configuration matches the reported configuration (versions, settings, environment).
• They checked defect handling: findings tracked, remediated, and re-tested where required.

If the verifier re-performs any testing, keep that as supporting evidence, but the core SA-11(3) deliverable is verification that the developer plan and evidence are reliable.

5) Record outcomes and required remediation

Operationalize “fail conditions” for verification, such as:

• Missing raw evidence for a material claim.
• Unapproved deviations from the plan.
• Evidence from the wrong environment or configuration.
• Findings that were “closed” without proof of fix and retest.

Route remediation into engineering ticketing and require the verifier to sign off on closure.

6) Package evidence for assessors and auditors

Create a standard “SA-11(3) package” per release or assessment event:

• Independence attestation + verifier qualification summary.
• Verification checklist mapped to plan sections.
• Traceability matrix (requirements → tests → results → defects → fixes).
• Verification report with exceptions and closures.

If you use Daydream in your GRC workflow, set SA-11(3) up as a requirement with an assigned owner, a repeatable procedure, and recurring evidence tasks so the verification package is produced consistently across teams and third parties.

Required evidence and artifacts to retain

Keep artifacts in a controlled repository with retention aligned to your system’s audit/authorization needs:

Independence + authorization

• Independent agent appointment letter/engagement statement
• Independence statement (conflict-of-interest disclosure)
• Verifier qualifications (role, relevant experience)

Plan and execution

• Approved security/privacy assessment plan (versioned)
• Test schedule and environment description
• Tool configurations and versions where relevant
• Documented deviations and approvals

Evidence integrity

• Raw test outputs (scanner exports, logs, console output, script results)
• Evidence index (what exists, where stored, hashes if your program uses them)
• Traceability matrix tying evidence to requirements and to the assessed configuration baseline

Verification results

• Independent verification report (findings, exceptions, recommendations)
• Management responses and remediation tickets
• Closure evidence and retest confirmation

Common exam/audit questions and hangups

Expect assessors to probe these areas:

1. “Who is the independent agent, and why are they independent?”
   Common hangup: internal security team reviewed evidence but sits under the same VP as engineering with shared objectives.

2. “Show me the assessment plan and prove it was followed.”
   Hangup: plan exists, but execution evidence is scattered, and deviations were handled informally in chat.

3. “Can you trace this claim to raw evidence?”
   Hangup: only summarized reports exist (PDF exports) without underlying data or context.

4. “Was the evidence produced for the right system version and environment?”
   Hangup: tests run in a staging environment that differs materially from production, without documented equivalence.

Frequent implementation mistakes and how to avoid them

• Mistake: Treating independence as “someone from security signed it.”
  Fix: document independence criteria and enforce management-chain separation for the verification role.

• Mistake: Verifying the plan exists, but not verifying execution quality.
  Fix: require sampling-based trace checks against raw artifacts and configuration baselines.

• Mistake: Accepting third-party attestations without validating scope and evidence.
  Fix: require the third party to provide an evidence index and allow your independent agent to validate a sample.

• Mistake: No linkage between findings and remediation.
  Fix: enforce ticket linkage in the verification report and require closure evidence plus retest proof for material issues.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat SA-11(3) primarily as an assurance and auditability expectation under NIST SP 800-53. The practical risk is programmatic: if an assessor cannot rely on developer evidence, you may face authorization delays, expanded testing scope, or costly re-testing cycles because assurance claims are not defensible. ¹

Practical 30/60/90-day execution plan

First 30 days (stand up the minimum viable control)

• Assign an owner (GRC or security assurance) and name the independent verifier pool (internal audit, security assurance separate from dev, or a qualified external firm).
• Publish independence criteria and a one-page SA-11(3) procedure.
• Create templates: independence attestation, verification checklist, verification report, evidence index.

Next 60 days (operationalize across SDLC and third parties)

• Add an SA-11(3) gate to change/release management for major releases.
• Pilot on one system and one third-party delivered component.
• Standardize traceability: requirements → tests → evidence → remediation tickets.

By 90 days (scale and make it audit-ready)

• Roll out to all in-scope systems/releases where developer testing supports compliance claims.
• Build an evidence library organized by system and release.
• In Daydream, map SA-11(3) to the control owner, the operating procedure, and the recurring evidence artifacts so the verification package is created the same way every cycle.

Frequently Asked Questions

Can the independent agent be internal, or must it be an external assessor?

SA-11(3) allows an independent agent; independence is the key property, not whether the person is external. Document why the internal verifier is independent from the developer organization and how conflicts are prevented. ¹

What does “verify the correct implementation of the assessment plan” mean in practice?

The verifier checks that planned tests were actually executed for the approved scope and configuration, and that any deviations were documented and approved. They also confirm the methods and environments match what the plan claimed. ²

We get SOC 2 reports from a SaaS provider. Does that satisfy SA-11(3)?

A SOC 2 report can support assurance, but SA-11(3) is about verifying developer assessment plans and testing evidence for your needs and scope. If you rely on provider testing evidence, your independent agent should validate that the evidence covers your implementation context and risk areas.

How deep does the verifier need to go into raw evidence?

Deep enough to confirm summarized results are accurate and attributable, using a documented sampling approach tied to risk. Auditors usually challenge situations where only polished summary reports exist without underlying artifacts.

What’s the cleanest way to prove independence to an auditor?

Keep an independence attestation, org chart or reporting-line explanation, and a conflict-of-interest disclosure for the verifier. Pair that with a verification report that shows real testing trace work, not a rubber stamp.

How do we handle agile releases where testing evidence changes weekly?

Treat SA-11(3) as a release gate for defined release trains or major increments, and keep verification packages tied to the version baseline you ship. For continuous delivery, define thresholds for when independent verification is required based on change risk and scope.

Footnotes

1. NIST SP 800-53 Rev. 5

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