FedRAMP Moderate
SA - System and Services Acquisition

FedRAMP Moderate SA-9: External System Services

Require providers of external system services to comply with security/privacy requirements; document oversight roles.

Maintained by Gerard BlokdykVerified against the published standard Control text last updated

What else in your programme already covers this

This control maps to 94 controls across 30 other frameworks. If you already hold one of them, the evidence you collected for it is the starting point here rather than new work.

Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 · 11 controls

CIS Controls v8 · 7 controls

  • CIS-15.1 Establish and Maintain an Inventory of Service Providers
  • CIS-15.2 Establish and Maintain a Service Provider Management Policy
  • CIS-15.4 Ensure Service Provider Contracts Include Security Requirements
  • CIS-15.5 Assess Service Providers
  • CIS-15.6 Monitor Service Providers
  • CIS-15.7 Securely Decommission Service Providers
  • CIS-8.12 Collect Service Provider Logs

PCI DSS 4.0 · 7 controls

  • 12.8.1 Third-party service provider inventory
  • 12.8.2 Written agreements with TPSPs
  • 12.8.3 TPSP due diligence
  • 12.8.4 TPSP compliance monitored
  • 12.8.5 Responsibility matrix with TPSPs
  • 12.9.2 TPSP supports customer requests for compliance info (SP)
  • 3.7.9 Service provider customer key responsibilities

C5 (Germany) · 6 controls

  • C5-DEV-02 Outsourcing of the development
  • C5-OIS-03 Interfaces and Dependencies
  • C5-PI-02 Contractual agreements for the provision of data
  • C5-SSO-01 Policies and instructions for controlling and monitoring third parties
  • C5-SSO-02 Risk assessment of service providers and suppliers
  • C5-SSO-04 Monitoring of compliance with requirements

ISO 27001:2022 · 6 controls

  • 5.19 Information security in supplier relationships
  • 5.20 Addressing information security within supplier agreements
  • 5.21 Managing information security in the ICT supply chain
  • 5.22 Monitoring, review and change management of supplier services
  • 5.23 Information security for use of cloud services
  • 8.21 Security of network services

APRA CPS 230 Operational Risk Management · 5 controls

  • CPS230-37 Service Provider Management Policy
  • CPS230-45 APRA Access Provisions in Formal Agreements
  • CPS230-46 Ongoing Risk Management of Each Material Arrangement
  • CPS230-50 Formal Agreement Content for Material Arrangements
  • CPS230-P15 Precondition for Reliance on a Service Provider

HIPAA Security Rule · 5 controls

NIST Cybersecurity Framework 2.0 · 5 controls

  • NIST-CSF-DE.CM-06 External service provider activities and services are monitored to find potentially adverse events
  • NIST-CSF-GV.SC-02 Cybersecurity roles and responsibilities for suppliers, customers, and partners are established, communicated, and coordinated internally and externally
  • NIST-CSF-GV.SC-05 Requirements to address cybersecurity risks in supply chains are established, prioritized, and integrated into contracts and other types of agreements with suppliers and other relevant third parties
  • NIST-CSF-GV.SC-07 The risks posed by a supplier, their products and services, and other third parties are understood, recorded, prioritized, assessed, responded to, and monitored over the course of the relationship
  • NIST-CSF-ID.AM-04 Inventories of services provided by suppliers are maintained

APEC Cross-Border Privacy Rules (CBPR) System · 4 controls

ISO 27002:2022 · 4 controls

  • 5.19 Information security in supplier relationships
  • 5.22 Monitoring, review and change management of supplier services
  • 5.23 Information security for use of cloud services
  • 8.21 Security of network services

ISO 27701:2019 · 4 controls

  • 6.12.1 Information security in supplier relationships
  • 6.12.2 Supplier service delivery management
  • 7.2.6 Contracts with PII processors
  • 8.5.7 Engagement of a subcontractor to process PII

CFTC System Safeguards (17 CFR 37, 38, 39, 49) · 3 controls

  • CFTC-SS-26 Own Resources or Contractual Arrangements to Meet the Recovery Objective
  • CFTC-SS-30 Outsourcing with Retention of Complete Responsibility
  • CFTC-SS-5 Systems Development and Quality Assurance Category

NIST SP 800-53 Rev 5 · 3 controls

SOC 2 · 3 controls

  • SOC2-CC2.3 COSO principle 15: Communicates with external parties regarding matters affecting controls
  • SOC2-CC9.2 Risk mitigation activities include assessment of vendor and business partner controls
  • SOC2-P6.4 Obtains privacy commitments from vendors and other third parties who have access to personal information to meet the entity's objectives related to privacy. The entity assesses those parties' compliance on a periodic and as-needed

APRA CPS 234 · 2 controls

  • CPS234-P22 Evaluation of Third Party Control Design
  • CPS234-P28 Assessment of Reliance on Third Party Control Testing

AWS Well-Architected Security Pillar · 2 controls

Azure Security Benchmark · 2 controls

  • AM-2 Use only approved services
  • ASBv3-PA-8 Determine access process for cloud provider support

DORA · 2 controls

ISO/IEC 42001:2023 · 2 controls

ANSSI Guide d'hygiene informatique (42 mesures, v2.0) · 1 control

  • ANSSI-HYG-03 Control the Risks of Outsourced Information System Management

APPI · 1 control

Australia My Health Records Act 2012 · 1 control

Australian Privacy Principles (APPs) · 1 control

  • APP-8 APP 8 - Cross-border disclosure of personal information

GDPR · 1 control

NIS2 Directive · 1 control

  • Art.21.2.d Supply chain security, covering the relationship with each direct supplier and service provider

NIST SP 800-161 Rev 1 · 1 control

NIST SP 800-171 Rev 3 · 1 control

NIST SP 800-218 · 1 control

NIST SP 800-66 Rev 2 · 1 control

  • 164.308(b)(1) Business Associate Contracts and Other Arrangements (Standard)

UK Cyber Essentials · 1 control

Every mapping shown was judged rather than inferred from wording similarity, and the ones that failed review are published too. See the coverage reports and what was rejected.

Other controls in SA - System and Services Acquisition

You are reading one control. How much of FedRAMP Moderate have you already done?

FedRAMP Moderate SA-9 is one control. If you already hold one of the frameworks below, a reviewed crosswalk already says how much of FedRAMP Moderate your existing evidence covers. Hold ISO 27002:2022 and 182 of 323 FedRAMP Moderate controls already carry evidence.

If you hold ISO 27002:202256.3% covered · 141 gapsIf you hold PCI DSS 4.051.1% covered · 158 gapsIf you hold ISO 27001:202249.8% covered · 162 gapsIf you hold NIST SP 800-171 Rev 345.5% covered · 176 gapsIf you hold C5 (Germany)37.2% covered · 203 gapsIf you hold CMMC 2.035% covered · 210 gaps

Each report names every control your existing framework evidences, every one it does not, the reasoning behind each claim, and the claims that were argued against and rejected. 348 were rejected on the ISO 27002:2022 pair alone.

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Query this from an agent

The graph holds this control, the 94 it maps to, and the evidence behind each claim, over MCP and REST.

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