CA-7 Continuous Monitoring

Guidance: draftPolicy clause: draftWhat these mean

Baselines	Implementation level	Enhancements
Low, Moderate, High, Privacy	Organization	5 (2 in a baseline)

Related controls: AC-2, AC-6, AC-17, AT-4, AU-6, AU-13, CA-2, CA-5, CA-6, CM-3, CM-4, CM-6, CM-11, IA-5, IR-5, MA-2, MA-3, MA-4, PE-3, PE-6, PE-14, PE-16, PE-20, PL-2, PM-4, PM-6, PM-9, PM-10, PM-12, PM-14, PM-23, PM-28, PM-31, PS-7, PT-7, RA-3, RA-5, RA-7, RA-10, SA-8, SA-9, SA-11, SC-5, SC-7, SC-18, SC-38, SC-43, SI-3, SI-4, SI-12, SR-6

Control statement

Develop a system-level continuous monitoring strategy and implement continuous monitoring in accordance with the organization-level continuous monitoring strategy that includes:

a. Establishing the following system-level metrics to be monitored: [Assignment: organization-defined system-level metrics];
b. Establishing [Assignment: organization-defined frequencies] for monitoring and [Assignment: organization-defined frequencies] for assessment of control effectiveness;
c. Ongoing control assessments in accordance with the continuous monitoring strategy;
d. Ongoing monitoring of system and organization-defined metrics in accordance with the continuous monitoring strategy;
e. Correlation and analysis of information generated by control assessments and monitoring;
f. Response actions to address results of the analysis of control assessment and monitoring information; and
g. Reporting the security and privacy status of the system to [Assignment: organization-defined personnel or roles] [Assignment: organization-defined frequency].

NIST discussion

Continuous monitoring at the system level facilitates ongoing awareness of the system security and privacy posture to support organizational risk management decisions. The terms “continuous” and “ongoing” imply that organizations assess and monitor their controls and risks at a frequency sufficient to support risk-based decisions. Different types of controls may require different monitoring frequencies. The results of continuous monitoring generate risk response actions by organizations. When monitoring the effectiveness of multiple controls that have been grouped into capabilities, a root-cause analysis may be needed to determine the specific control that has failed. Continuous monitoring programs allow organizations to maintain the authorizations of systems and common controls in highly dynamic environments of operation with changing mission and business needs, threats, vulnerabilities, and technologies. Having access to security and privacy information on a continuing basis through reports and dashboards gives organizational officials the ability to make effective and timely risk management decisions, including ongoing authorization decisions.

Automation supports more frequent updates to hardware, software, and firmware inventories, authorization packages, and other system information. Effectiveness is further enhanced when continuous monitoring outputs are formatted to provide information that is specific, measurable, actionable, relevant, and timely. Continuous monitoring activities are scaled in accordance with the security categories of systems. Monitoring requirements, including the need for specific monitoring, may be referenced in other controls and control enhancements, such as AC-2g, AC-2(7), AC-2(12)(a), AC-2(7)(b), AC-2(7)(c), AC-17(1), AT-4a, AU-13, AU-13(1), AU-13(2), CM-3f, CM-6d, CM-11c, IR-5, MA-2b, MA-3a, MA-4a, PE-3d, PE-6, PE-14b, PE-16, PE-20, PM-6, PM-23, PM-31, PS-7e, SA-9c, SR-4, SC-5(3)(b), SC-7a, SC-7(24)(b), SC-18b, SC-43b , and SI-4.

Control enhancements

CA-7(1) Independent Assessment

Baselines: Moderate, High

Employ independent assessors or assessment teams to monitor the controls in the system on an ongoing basis.

Discussion and assessment objectives for CA-7(1)

Organizations maximize the value of control assessments by requiring that assessments be conducted by assessors with appropriate levels of independence. The level of required independence is based on organizational continuous monitoring strategies. Assessor independence provides a degree of impartiality to the monitoring process. To achieve such impartiality, assessors do not create a mutual or conflicting interest with the organizations where the assessments are being conducted, assess their own work, act as management or employees of the organizations they are serving, or place themselves in advocacy positions for the organizations acquiring their services.

Determine if independent assessors or assessment teams are employed to monitor the controls in the system on an ongoing basis.

Examine: Assessment, authorization, and monitoring policy; organizational continuous monitoring strategy; system-level continuous monitoring strategy; procedures addressing continuous monitoring of system controls; control assessment report; plan of action and milestones; system monitoring records; impact analyses; status reports; system security plan; privacy plan; other relevant documents or records.

Interview: Organizational personnel with continuous monitoring responsibilities; organizational personnel with information security and privacy responsibilities.

CA-7(3) Trend Analyses

Baselines: Not in a baseline

Employ trend analyses to determine if control implementations, the frequency of continuous monitoring activities, and the types of activities used in the continuous monitoring process need to be modified based on empirical data.

Discussion and assessment objectives for CA-7(3)

Trend analyses include examining recent threat information that addresses the types of threat events that have occurred in the organization or the Federal Government, success rates of certain types of attacks, emerging vulnerabilities in technologies, evolving social engineering techniques, the effectiveness of configuration settings, results from multiple control assessments, and findings from Inspectors General or auditors.

Determine if:

CA-07(03)[01] trend analysis is employed to determine if control implementations used in the continuous monitoring process need to be modified based on empirical data;
CA-07(03)[02] trend analysis is employed to determine if the frequency of continuous monitoring activities used in the continuous monitoring process needs to be modified based on empirical data;
CA-07(03)[03] trend analysis is employed to determine if the types of activities used in the continuous monitoring process need to be modified based on empirical data.

Examine: Organizational continuous monitoring strategy; system-level continuous monitoring strategy; assessment, authorization, and monitoring policy; procedures addressing continuous monitoring of system controls; privacy controls; assessment report; plan of action and milestones; system monitoring records; impact analyses; status reports; system security plan; privacy plan; other relevant documents or records.

Interview: Organizational personnel with continuous monitoring responsibilities; organizational personnel with information security and privacy responsibilities.

Test: Mechanisms supporting trend analyses.

CA-7(4) Risk Monitoring

Baselines: Low, Moderate, High, Privacy

Ensure risk monitoring is an integral part of the continuous monitoring strategy that includes the following:

(a) Effectiveness monitoring;
(b) Compliance monitoring; and
(c) Change monitoring.

Discussion and assessment objectives for CA-7(4)

Risk monitoring is informed by the established organizational risk tolerance. Effectiveness monitoring determines the ongoing effectiveness of the implemented risk response measures. Compliance monitoring verifies that required risk response measures are implemented. It also verifies that security and privacy requirements are satisfied. Change monitoring identifies changes to organizational systems and environments of operation that may affect security and privacy risk.

Determine if risk monitoring is an integral part of the continuous monitoring strategy;

CA-07(04)(a) effectiveness monitoring is included in risk monitoring;
CA-07(04)(b) compliance monitoring is included in risk monitoring;
CA-07(04)(c) change monitoring is included in risk monitoring.

Examine: Assessment, authorization, and monitoring policy; organizational continuous monitoring strategy; system-level continuous monitoring strategy; procedures addressing continuous monitoring of system controls; assessment report; plan of action and milestones; system monitoring records; impact analyses; status reports; system security plan; privacy plan; other relevant documents or records.

Interview: Organizational personnel with continuous monitoring responsibilities; organizational personnel with information security and privacy responsibilities.

Test: Mechanisms supporting risk monitoring.

CA-7(5) Consistency Analysis

Baselines: Not in a baseline

Employ the following actions to validate that policies are established and implemented controls are operating in a consistent manner: [Assignment: organization-defined actions].

Discussion and assessment objectives for CA-7(5)

Security and privacy controls are often added incrementally to a system. As a result, policies for selecting and implementing controls may be inconsistent, and the controls could fail to work together in a consistent or coordinated manner. At a minimum, the lack of consistency and coordination could mean that there are unacceptable security and privacy gaps in the system. At worst, it could mean that some of the controls implemented in one location or by one component are actually impeding the functionality of other controls (e.g., encrypting internal network traffic can impede monitoring). In other situations, failing to consistently monitor all implemented network protocols (e.g., a dual stack of IPv4 and IPv6) may create unintended vulnerabilities in the system that could be exploited by adversaries. It is important to validate—through testing, monitoring, and analysis—that the implemented controls are operating in a consistent, coordinated, non-interfering manner.

Determine if:

CA-07(05)[01] [Assignment: organization-defined actions] are employed to validate that policies are established;
CA-07(05)[02] [Assignment: organization-defined actions] are employed to validate that implemented controls are operating in a consistent manner.

Examine: Assessment, authorization, and monitoring policy; organizational continuous monitoring strategy; system-level continuous monitoring strategy; procedures addressing continuous monitoring of system security controls; assessment report; plan of action and milestones; system monitoring records; security impact analyses; status reports; system security plan; other relevant documents or records.

Interview: Organizational personnel with continuous monitoring responsibilities; organizational personnel with information security and privacy responsibilities.

Test: Mechanisms supporting consistency analyses.

CA-7(6) Automation Support for Monitoring

Baselines: Not in a baseline

Ensure the accuracy, currency, and availability of monitoring results for the system using [Assignment: organization-defined automated mechanisms].

Discussion and assessment objectives for CA-7(6)

Using automated tools for monitoring helps to maintain the accuracy, currency, and availability of monitoring information which in turns helps to increase the level of ongoing awareness of the system security and privacy posture in support of organizational risk management decisions.

Determine if [Assignment: organization-defined automated mechanisms] are used to ensure the accuracy, currency, and availability of monitoring results for the system.

Examine: Assessment, authorization, and monitoring policy; organizational continuous monitoring strategy; system-level continuous monitoring strategy; procedures addressing continuous monitoring of system controls; assessment report; plan of action and milestones; system monitoring records; impact analyses; status reports; system security plan; privacy plan; other relevant documents or records.

Interview: Organizational personnel with continuous monitoring responsibilities; organizational personnel with information security and privacy responsibilities.

Test: Mechanisms supporting automated monitoring.

Withdrawn enhancements: CA-7(2).

Assessment objectives (SP 800-53A)

Objectives and methods for CA-7

Determine if:

CA-07[01] a system-level continuous monitoring strategy is developed;
CA-07[02] system-level continuous monitoring is implemented in accordance with the organization-level continuous monitoring strategy;
CA-07a. system-level continuous monitoring includes establishment of the following system-level metrics to be monitored: [Assignment: organization-defined system-level metrics];
CA-07b.
- CA-07b.[01] system-level continuous monitoring includes established [Assignment: organization-defined frequencies] for monitoring;
- CA-07b.[02] system-level continuous monitoring includes established [Assignment: organization-defined frequencies] for assessment of control effectiveness;
CA-07c. system-level continuous monitoring includes ongoing control assessments in accordance with the continuous monitoring strategy;
CA-07d. system-level continuous monitoring includes ongoing monitoring of system and organization-defined metrics in accordance with the continuous monitoring strategy;
CA-07e. system-level continuous monitoring includes correlation and analysis of information generated by control assessments and monitoring;
CA-07f. system-level continuous monitoring includes response actions to address the results of the analysis of control assessment and monitoring information;
CA-07g.
- CA-07g.[01] system-level continuous monitoring includes reporting the security status of the system to [Assignment: organization-defined personnel or roles] [Assignment: organization-defined frequency];
- CA-07g.[02] system-level continuous monitoring includes reporting the privacy status of the system to [Assignment: organization-defined personnel or roles] [Assignment: organization-defined frequency].

Examine: Assessment, authorization, and monitoring policy; organizational continuous monitoring strategy; system-level continuous monitoring strategy; procedures addressing continuous monitoring of system controls; procedures addressing configuration management; control assessment report; plan of action and milestones; system monitoring records; configuration management records; impact analyses; status reports; system security plan; privacy plan; other relevant documents or records.

Interview: Organizational personnel with continuous monitoring responsibilities; organizational personnel with information security and privacy responsibilities; system/network administrators.

Test: Mechanisms implementing continuous monitoring; mechanisms supporting response actions to address assessment and monitoring results; mechanisms supporting security and privacy status reporting.

Policy statement

The System owner shall develop a system-level continuous monitoring strategy that follows the organization-wide continuous monitoring strategy, and implement continuous monitoring in accordance with it. (CA-7)
The system-level strategy shall establish the following system-level metrics to be monitored: Fill in: system-level metrics to be monitored Typical: open vulnerabilities by severity and age, configuration compliance rate, plan of action and milestones items past due, and unauthorized components found. (CA-7a)
The system-level strategy shall establish that control effectiveness is monitored Fill in: frequencies at which to monitor control effectiveness Typical: continuously for automated controls, and at least monthly for vulnerability, configuration and account data. (CA-7b)
The system-level strategy shall establish that control effectiveness is assessed at Fill in: frequencies at which to assess control effectiveness Typical: the schedule in the system’s continuous monitoring strategy, assessing a third of the controls each year so every control is assessed at least every three years. (CA-7b)
The System owner shall ensure ongoing control assessments are carried out in accordance with the continuous monitoring strategy. (CA-7c)
The System owner shall ensure the system-level and organization-defined metrics are monitored on an ongoing basis in accordance with the continuous monitoring strategy. (CA-7d)
The System owner shall correlate and analyze the information that control assessments and monitoring produce. (CA-7e)
The System owner shall take response actions to address the results of that analysis, recording weaknesses in the plan of action and milestones (CA-5) and raising risks above tolerance with the authorizing official. (CA-7f)
The System owner shall report the security status of the system to Fill in: personnel or roles to whom the security status of the system is reported Typical: the authorizing official and the Chief Information Security Officer, Fill in: frequency at which the security status of the system is reported Typical: at least quarterly. (CA-7g)
For a system that processes personally identifiable information, the System owner shall report the privacy status of the system to Fill in: personnel or roles to whom the privacy status of the system is reported Typical: the authorizing official and the senior privacy official, Fill in: frequency at which the privacy status of the system is reported Typical: at least quarterly. (CA-7g)
The System owner shall review and update the system-level strategy when the system changes significantly, when the organization-wide strategy changes, and at least annually. (CA-7)

Federal systems

OMB Circular A-130, Appendix I, section 4.d(5) to (8), requires agencies to develop and maintain an information security continuous monitoring (ISCM) strategy, update it at an organization-defined frequency, ensure all selected and implemented controls are addressed in it and effectively monitored on an ongoing basis, and keep an ISCM program with metrics that give meaningful indications of security status and trend analysis at every risk management tier. Section 4.d(9) adds a privacy continuous monitoring (PCM) strategy; footnote 85 allows the two strategies to be combined into one. Section 5.c says that, after the authorization decision, agencies monitor the controls in each system on an ongoing basis, as described in NIST SP 800-137, including assessing control effectiveness, documenting changes, analyzing their security impact and reporting the system’s security state to designated officials. As of September 2026.

The System owner shall ensure every control selected and implemented for the system is addressed in the system-level strategy and monitored on an ongoing basis, as OMB Circular A-130, Appendix I, section 4.d(7), requires. (CA-7c)
The System owner shall ensure the system-level strategy follows the agency’s ISCM strategy and, for a system that processes personally identifiable information, its PCM strategy, or the single strategy that combines them. (CA-7)

CA-7(1) Independent assessment

The Chief Information Security Officer shall employ independent assessors or assessment teams to monitor the controls in the system on an ongoing basis. (CA-7(1))
The ongoing assessors shall meet the independence the authorizing official set for the system under CA-2(1). (CA-7(1))

CA-7(4) Risk monitoring

The System owner shall make risk monitoring an integral part of the system’s continuous monitoring strategy, informed by the organization’s risk tolerance. (CA-7(4))
The strategy shall include effectiveness monitoring, to determine whether the implemented risk response measures remain effective. (CA-7(4)(a))
The strategy shall include compliance monitoring, to verify that required risk response measures are implemented and that security and privacy requirements are satisfied. (CA-7(4)(b))
The strategy shall include change monitoring, to identify changes to the system and its environment of operation that may affect security and privacy risk. (CA-7(4)(c))

From the Assessment, Authorization, and Monitoring Policy template (draft). Highlighted fields are values your organization sets.

How to apply it

Continuous monitoring keeps the authorization current between full assessments. The system-level strategy (Continuous Monitoring Strategy template, Part B) sets what is measured, how often controls are monitored and assessed, how results are analyzed and acted on, and how often the system’s status is reported. It follows the organization-level strategy set in the Prepare step (P-7).

Common implementations. A continuous monitoring strategy that assigns each control an assessment frequency, often by volatility: frequently changing controls such as vulnerability management monthly, stable ones such as physical security annually. Automated feeds from vulnerability scanning, configuration compliance and inventory tools. A monthly status report to the system owner and a periodic report to the authorizing official. Independent assessors for the ongoing assessments (CA-7(1)).

Organization-defined parameters. Typical values, which your organization may set differently:

Parameter	Typical value
System-level metrics (a)	Open vulnerabilities by severity and age, configuration compliance rate, POA&M items past due, and unauthorized components found
Monitoring and assessment frequencies (b)	Monitoring monthly or continuously for automated metrics; assessment per the control schedule in the strategy
Status reporting (g)	To the authorizing official and the Chief Information Security Officer, at least quarterly

Evidence assessors ask for.

The system-level continuous monitoring strategy
Recent status reports and the metrics behind them
Examples of response actions taken from monitoring results (CA-7f)

Inheritance. The organization-level strategy and shared monitoring tools are common; the system owns its strategy, metrics and reports.

Common findings.

A strategy that exists on paper with no reports produced.
Metrics collected but not tied to decisions or POA&M items.
Ongoing assessments done by the system’s own administrators.

Enhancements in the Moderate baseline. CA-7(1) independent assessment and CA-7(4) risk monitoring (also Low).

Artifacts

Independent guidance, not an official NIST publication. Control text is from NIST SP 800-53 Rev. 5 and SP 800-53A (public domain). Original content is licensed CC BY 4.0; program templates and the downloadable kit are dedicated to the public domain under CC0 1.0.