# System and Services Acquisition Policy

**Template version:** 1.0.0 · **Baseline:** Low · **Edition:** Ready to adopt · **NIST basis:** SP 800-53 Rev. 5, release 5.2.0

*Tailor this template before adoption; it is not legal advice.* Latest version: <https://kston83.github.io/nist-guide/templates/policies/sa/>. Dedicated to the public domain under CC0 1.0 (<https://creativecommons.org/publicdomain/zero/1.0/>): adopt and change it without attribution.

## Purpose

This policy states what [Organization name] requires for System and Services Acquisition, and who is accountable for meeting those requirements. (SA-1a.1(a))

## Scope

This policy applies at the [Select one or more: organization-level; mission/business process-level; system-level. Typical: organization-level] to every system that [Organization name] owns or operates, or that is operated on its behalf, and to every person with access to those systems, including employees, contractors and partners. (SA-1a.1(a))

## Roles and responsibilities

- The [Chief Information Security Officer] is accountable for this policy and shall approve exceptions to it. (SA-1a.1(a))
- The [Fill in: an official to manage the system and services acquisition policy and procedures. Typical: Chief Information Security Officer] shall manage the development, documentation and dissemination of this policy and its procedures. (SA-1b)
- Each [System owner] shall implement this policy for their system and document how in the system security plan. (SA-1a.1(a))
- Each person within scope shall follow this policy and report suspected violations to the [Chief Information Security Officer]. (SA-1a.1(a))

## Management commitment

The [Senior leader] approves this policy and shall provide the resources needed to implement it. (SA-1a.1(a))

## Coordination

The [Chief Information Security Officer] shall coordinate this policy with the legal, privacy, human resources and procurement functions, and with the owners of related policies, before each approval. (SA-1a.1(a))

## Compliance

- This policy shall be consistent with the laws, executive orders, directives, regulations, policies, standards and guidelines that apply to [Organization name], including [Fill in: laws, regulations and standards that apply to the organization]. (SA-1a.1(b))
- The [Chief Information Security Officer] shall review compliance with this policy through the organization's assessment and continuous monitoring activities. (SA-1a.1(a))
- An exception to this policy shall be requested in writing, approved by the [Chief Information Security Officer], time-limited and recorded with its compensating measures. (SA-1a.1(a))
- Violations of this policy shall be handled through the organization's sanctions process. (SA-1a.1(a))

## Procedures

The [Fill in: an official to manage the system and services acquisition policy and procedures. Typical: Chief Information Security Officer] shall ensure that documented procedures exist to implement this policy and its associated controls. (SA-1a.2)

## Dissemination

- The [Fill in: an official to manage the system and services acquisition policy and procedures. Typical: Chief Information Security Officer] shall disseminate this policy to [Fill in: personnel or roles to whom the system and services acquisition policy is to be disseminated. Typical: everyone within its scope, through the policy library]. (SA-1a)
- The [Fill in: an official to manage the system and services acquisition policy and procedures. Typical: Chief Information Security Officer] shall disseminate the procedures that implement this policy to [Fill in: personnel or roles to whom the system and services acquisition procedures are to be disseminated. Typical: the people who carry them out, and the system owners]. (SA-1a)

## Policy statements

### Allocation of resources (SA-2)

- The [System owner] shall determine the high-level information security and privacy requirements for the system or system service during mission and business process planning, before an acquisition or development begins. (SA-2a)
- The [System owner] shall determine and document the resources required to protect the system or system service, including acquisition, sustainment and supply chain risk management costs across the system development life cycle, as part of the organization's capital planning and investment control process. (SA-2b)
- The [Senior leader] shall allocate the documented resources through the capital planning and investment control process, and record the reason for any shortfall. (SA-2b)
- The [Chief Information Security Officer] and the [Senior privacy official] shall ensure a discrete line item for information security and a discrete line item for privacy are established in the organization's programming and budgeting documentation for the system. (SA-2c)

#### Federal systems

[OMB Circular A-130](https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/circulars/A130/a130revised.pdf), Appendix I, section 4.b(1) to (3), requires agencies to identify and plan for the resources needed to implement information security and privacy programs; to ensure that security and privacy are addressed throughout the life cycle of each agency information system, with security and privacy activities and costs identified and included in IT investment capital plans and budgetary requests; and to plan and budget to upgrade, replace or retire any system for which protections commensurate with risk cannot be effectively implemented. Section 4.e(6) requires the Senior Agency Official for Privacy to review IT capital investment plans and budgetary requests so that privacy requirements, and their costs, are explicitly identified and included. As of September 2026.

- The [System owner] shall identify the system's security and privacy activities and costs in its IT investment capital plan and budgetary requests, as OMB Circular A-130, Appendix I, section 4.b(2), requires. (SA-2b)
- For a system that processes personally identifiable information, the [Senior privacy official] shall review the system's IT capital investment plan and budgetary requests to confirm that privacy requirements and their costs are explicitly identified and included, as OMB Circular A-130, Appendix I, section 4.e(6), requires. (SA-2c)

### System development life cycle (SA-3)

- The [System owner] shall acquire, develop and manage the system using [Fill in: system development life cycle. Typical: the organization's documented system development life cycle, with security and privacy activities and a review gate in each phase: initiation, development or acquisition, implementation and assessment, operations and maintenance, and disposal] that incorporates information security and privacy considerations. (SA-3a)
- The [Chief Information Security Officer] and the [Senior privacy official] shall define and document the information security and privacy roles and responsibilities for each phase of the system development life cycle. (SA-3b)
- The [System owner] shall identify, in the system security plan, the individuals who hold information security and privacy roles and responsibilities for the system. (SA-3c)
- The [System owner] shall integrate the organization's information security and privacy risk management process into the system development life cycle, so that categorization, control selection, implementation, assessment, authorization and monitoring take place in the phases the risk management process assigns them to. (SA-3d)

#### Federal systems

[OMB Circular A-130](https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/circulars/A130/a130revised.pdf), Appendix I, section 4.b(2), requires agencies to ensure that information security and privacy are addressed throughout the life cycle of each agency information system. As of September 2026.

- The [System owner] shall ensure information security and privacy are addressed in every phase of the system's life cycle, from planning and acquisition through operation, maintenance and disposal, as OMB Circular A-130, Appendix I, section 4.b(2), requires. (SA-3a)

### Acquisition process (SA-4)

- The [System owner] shall include the following requirements, descriptions and criteria, explicitly or by reference, using [Select one or more: standardized contract language; [Assignment: organization-defined contract language]. Typical: standardized contract language that the procurement office maintains and the Chief Information Security Officer and senior privacy official approve, with system-specific requirements added for each acquisition], in the acquisition contract for each system, system component or system service. (SA-4)
- The contract shall state the security and privacy functional requirements. (SA-4a)
- The contract shall state the strength of mechanism requirements, such as resistance to tampering, bypass and direct attack. (SA-4b)
- The contract shall state the security and privacy assurance requirements, including the development processes and the evidence from development and assessment that the supplier provides. (SA-4c)
- The contract shall state the controls needed to satisfy the security and privacy requirements, with any control parameter values the supplier must meet. (SA-4d)
- The contract shall state the security and privacy documentation requirements (SA-5). (SA-4e)
- The contract shall state the requirements for protecting security and privacy documentation. (SA-4f)
- The contract shall describe the system development environment and the environment in which the system is intended to operate. (SA-4g)
- The contract shall allocate responsibility for, or identify the parties responsible for, information security, privacy and supply chain risk management. (SA-4h)
- The contract shall state the acceptance criteria for the system, component or service. (SA-4i)
- The [Chief Information Security Officer] shall review each solicitation for a system, system component or system service for these requirements before it is issued, and the [Senior privacy official] shall review each one for a system that processes personally identifiable information. (SA-4)

#### Federal systems

[OMB Circular A-130](https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/circulars/A130/a130revised.pdf), Appendix I, section 4.j(1), requires agencies to ensure that the terms and conditions of contracts and other agreements involving Federal information incorporate security and privacy requirements sufficient to meet Federal and agency-specific requirements for its protection; section 4.j(5) requires them to include provisions for Federal Government notification and access, and for cooperation with agency personnel and Inspectors General. [OMB M-26-05](https://www.whitehouse.gov/wp-content/uploads/2026/01/M-26-05-Adopting-a-Risk-based-Approach-to-Software-and-Hardware-Security.pdf), Adopting a Risk-based Approach to Software and Hardware Security (January 23, 2026), rescinds M-22-18 and M-23-16, so agencies are no longer required to collect the Secure Software Development Attestation Form. It requires agencies to develop software and hardware assurance policies and processes that match their risk determinations, and lets them use the attestation form, and contract terms requiring a current software bill of materials on request, where they choose to. As of September 2026.

- The [System owner] shall ensure each contract or agreement involving Federal information incorporates the security and privacy requirements that apply to that information, and provisions for Federal Government notification and access and for cooperation with agency personnel and the Inspector General, as OMB Circular A-130, Appendix I, sections 4.j(1) and 4.j(5), require. (SA-4)
- The [Chief Information Security Officer] shall decide, for each acquisition of software or hardware and based on a risk assessment, whether to require a secure software development attestation or a software bill of materials, following the agency's assurance policy under OMB M-26-05. (SA-4c)

<!-- TODO(verify): FAR contract requirements for IT security. The FAR as codified on acquisition.gov (FAC 2026-01, effective March 13, 2026) has 39.101(c), requiring agencies to include the appropriate information technology security policies and requirements, including use of common security configurations from NIST, in IT acquisitions, and the 52.239-1 clause at 39.106. Many agencies (for example GSA, Treasury, DOL and HUD) have issued Revolutionary FAR Overhaul class deviations for Part 39, and whether the deviation text keeps these requirements was not confirmed on 2026-09-29. Cite the FAR here once it is clear which text governs. -->

### Use of approved PIV products (SA-4(10))

- Where the system implements Personal Identity Verification (PIV) capability, the [System owner] shall employ only information technology products on the FIPS 201-approved products list for that capability. (SA-4(10))
- The [System owner] shall record the approved products list entry for each PIV product in the system's component inventory, and replace a product that is moved to the removed products list. (SA-4(10))

#### Federal systems

[FIPS 201-3](https://csrc.nist.gov/pubs/fips/201-3/final), Personal Identity Verification (PIV) of Federal Employees and Contractors (January 2022), states in its preamble (item 7) that FIPS 201 compliance of PIV components and subsystems is provided through products and services from the General Services Administration's approved products and services list, and in Appendix A.5 that products evaluated and approved under GSA's FIPS 201 Evaluation Program are placed on the [FIPS 201 Approved Products List](https://www.idmanagement.gov/fips201/) to promote the procurement of conformant products by agencies. As of September 2026.

- The [System owner] shall acquire PIV card products, readers and physical access control system products for the system only from the FIPS 201 Approved Products List that GSA maintains. (SA-4(10))

<!-- TODO(verify): FAR 4.1302(a) as codified on acquisition.gov (FAC 2026-01, effective March 13, 2026) reads "In order to comply with FIPS PUB 201, agencies must purchase only approved personal identity verification products and services." Confirm whether the Revolutionary FAR Overhaul deviation text for Part 4 keeps this before citing it here. -->

### System documentation (SA-5)

- The [System owner] shall obtain or develop administrator documentation for the system, system component or system service that describes its secure configuration, installation and operation. (SA-5a.1)
- The administrator documentation shall describe the effective use and maintenance of the security and privacy functions and mechanisms. (SA-5a.2)
- The administrator documentation shall describe known vulnerabilities regarding the configuration and use of administrative or privileged functions. (SA-5a.3)
- The [System owner] shall obtain or develop user documentation that describes the user-accessible security and privacy functions and mechanisms, and how to use them effectively. (SA-5b.1)
- The user documentation shall describe methods of user interaction that let individuals use the system, component or service more securely and protect individual privacy. (SA-5b.2)
- The user documentation shall describe users' responsibilities for maintaining the security of the system, component or service and the privacy of individuals. (SA-5b.3)
- When documentation is unavailable or does not exist, the [System owner] shall document the attempts made to obtain it and [Fill in: actions to take when system, system component, or system service documentation is either unavailable or nonexistent. Typical: ask the manufacturer or supplier again and search its published material; where the documentation is essential to operating a control, write it in-house; and record any remaining gap as a risk in the risk register]. (SA-5c)
- The [System owner] shall distribute the documentation to [Fill in: personnel or roles to distribute system documentation to. Typical: the system owner, the system security officer and the system administrators]. (SA-5d)
- The [System owner] shall protect the documentation according to the system's security category, restricting documentation that describes vulnerabilities to those who need it. (SA-5)

#### Federal systems

[OMB Circular A-130](https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/circulars/A130/a130revised.pdf), Appendix I, section 4.i(6), requires agencies to protect administrator, user and system documentation related to the design, development, testing, operation, maintenance and security of the hardware, firmware and software components of information systems. As of September 2026.

- The [System owner] shall protect the administrator, user and system documentation for the system's hardware, firmware and software components, as OMB Circular A-130, Appendix I, section 4.i(6), requires. (SA-5)

### Security and privacy engineering principles (SA-8)

- The [System owner] shall apply the following systems security and privacy engineering principles in the specification, design, development, implementation and modification of the system and system components: [Fill in: systems security and privacy engineering principles. Typical: for security, the principles for trustworthy secure design in NIST SP 800-160 Vol. 1 Rev. 1, Appendix E, that the system's security architecture selects; for privacy, the objectives of predictability, manageability and disassociability from NIST IR 8062, and minimization (SA-8(33))]. (SA-8)
- The [System owner] shall record in the security and privacy architectures (PL-8) the principles applied to the system, and the reason for any principle not applied. (SA-8)
- For an existing system, the [System owner] shall apply the principles to upgrades and modifications to the extent feasible, given the current state of its hardware, software and firmware. (SA-8)

### External system services (SA-9)

- The [System owner] shall require that providers of external system services comply with the organization's security and privacy requirements and employ [Fill in: controls to be employed by external system service providers. Typical: the controls of the system's baseline that the provider is responsible for, per the shared responsibility matrix, with evidence from an independent attestation]. (SA-9a)
- The [System owner] shall record those requirements in the contract or service agreement before the service is used. (SA-9a)
- The [System owner] shall define and document the organization's oversight roles and responsibilities, and the user roles and responsibilities, for each external system service, including a shared responsibility matrix. (SA-9b)
- The [System owner] shall employ [Fill in: processes, methods, and techniques employed to monitor control compliance by external service providers. Typical: annual review of independent attestation reports, review of the provider's continuous monitoring or status reports, and contract service reviews] to monitor the provider's control compliance on an ongoing basis. (SA-9c)
- The [System owner] shall follow up each exception in a provider's attestation report, and each customer control the report expects the organization to operate, and record weaknesses that affect the system in its plan of action and milestones (CA-5). (SA-9c)

#### Federal systems

[OMB Circular A-130](https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/circulars/A130/a130revised.pdf), Appendix I, section 4.j(2)(a) and (b), requires agencies to provide oversight of information systems used or operated by contractors or other entities on behalf of the Federal Government, including documented oversight policies and procedures and ensuring that the security and privacy controls of those systems and services are effectively implemented and comply with NIST standards and guidelines and agency requirements. Under [OMB M-24-15](https://www.fedramp.gov/2026/authority/m-24-15/), Modernizing the Federal Risk and Authorization Management Program (July 25, 2024), agencies must obtain and maintain a FedRAMP authorization for cloud products and services that create, collect, process, store or maintain federal information on the agency's behalf, unless the memo places them out of scope. As of September 2026.

- The [System owner] shall ensure each cloud product or service within the scope of OMB M-24-15 has a FedRAMP authorization before it processes federal information, and that the agency issues its own authorization to use it. (SA-9a)
- The [System owner] shall document the agency's oversight of each system a contractor or other entity operates on its behalf, and verify that its controls are effectively implemented, as OMB Circular A-130, Appendix I, section 4.j(2), requires. (SA-9c)

### Unsupported system components (SA-22)

- The [System owner] shall replace system components when support for them is no longer available from the developer, vendor or manufacturer. (SA-22a)
- The [System owner] shall plan and budget each replacement before the component's announced end-of-support date. (SA-22a)
- Where a component cannot be replaced by its end-of-support date, the [System owner] shall provide the following options for alternative sources of continued support: [Select one or more: in-house support; [Assignment: organization-defined support from external providers]. Typical: support from an external provider under contract, such as extended vendor support or a third-party support provider; in-house support only for an isolated component whose replacement is scheduled]. (SA-22b)
- The authorizing official shall approve each continued use of an unsupported component, for a set period, with the compensating measures recorded and the replacement tracked in the plan of action and milestones. (SA-22b)

#### Federal systems

[OMB Circular A-130](https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/circulars/A130/a130revised.pdf), Appendix I, section 4.i(8), requires agencies to prohibit the use of unsupported information systems and system components, and to give systems and components that cannot be appropriately protected a high priority for upgrade or replacement; section 5.p allows the same exceptions as NIST's SA-22 discussion, with in-house or contracted support for them. CISA [Binding Operational Directive 26-02](https://www.cisa.gov/news-events/directives/bod-26-02-mitigating-risk-end-support-edge-devices), Mitigating Risk From End-of-Support Edge Devices (February 5, 2026), covers edge devices: devices on the boundary of an agency's network that are reachable from the public internet. It requires agencies to update supported devices running end-of-support software immediately; to inventory devices on CISA's end-of-support edge device list within 3 months; to decommission listed devices and report to CISA within 12 months; to decommission every end-of-support edge device within 18 months; and, within 24 months, to keep a continuous discovery process and inventory and decommission each edge device by its end-of-support date. As of September 2026.

- The [System owner] shall not use an unsupported system component except under an exception that OMB Circular A-130, Appendix I, section 5.p, allows, approved by the authorizing official. (SA-22a)
- The [System owner] shall inventory the system's edge devices, replace or decommission each one that is end of support, and report each decommission to CISA, by the deadlines BOD 26-02 sets. (SA-22a)
- From the directive's 24-month deadline, the [System owner] shall decommission each edge device on or before its end-of-support date, as BOD 26-02 requires. (SA-22a)

## Review and update

- The [Fill in: an official to manage the system and services acquisition policy and procedures. Typical: Chief Information Security Officer] shall review and update this policy [Fill in: the frequency at which the current system and services acquisition policy is reviewed and updated. Typical: annually] and following [Fill in: events that would require the current system and services acquisition policy to be reviewed and updated. Typical: assessment or audit findings, security incidents or breaches, and changes in applicable laws, executive orders, directives, regulations, policies, standards or guidelines]. (SA-1c.1)
- The [Fill in: an official to manage the system and services acquisition policy and procedures. Typical: Chief Information Security Officer] shall review and update the procedures that implement this policy [Fill in: the frequency at which the current system and services acquisition procedures are reviewed and updated. Typical: annually] and following [Fill in: events that would require the system and services acquisition procedures to be reviewed and updated. Typical: the same events as the policy, and changes to the systems, tools or services the procedures describe]. (SA-1c.2)

### Federal systems

For federal information systems, this policy also carries out the agency's information security responsibilities under the Federal Information Security Modernization Act of 2014 ([44 U.S.C. § 3554](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title44-section3554&num=0&edition=prelim), Federal agency responsibilities) and [OMB Circular A-130](https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/circulars/A130/a130revised.pdf), Appendix I, Responsibilities for Protecting and Managing Federal Information Resources.

- Where the agency's organization-wide policy sets a value for a parameter in this policy, each system shall use that value or a stricter one. (SA-1a.1(b))