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External Service Review

External Service Review template: The review of one external system service before the organization uses it and at each review after that, covering the contract's security and privacy requirements, the provider's evidence of compliance, the shared responsibilities and the decision, with a register of every external service and its next review, as SP 800-53 SA-9 requires.

TypeProgram stageStatusTemplate versionNIST basis
Form or registerOperateDraft1.0.0SP 800-53 release 5.2.0

The review of one external system service before the organization uses it and at each review after that, covering the contract’s security and privacy requirements, the provider’s evidence of compliance, the shared responsibilities and the decision, with a register of every external service and its next review, as SP 800-53 SA-9 requires.

ControlTitle
SA-9External System Services
SA-9(2)Identification of Functions, Ports, Protocols, and Services
SA-4Acquisition Process
CA-3Information Exchange
CA-5Plan of Action and Milestones
VariantReady to adoptAnnotated
All baselinesWord · MarkdownWord · Markdown

The register as a spreadsheet: CSV, with one column per field.

Review IDReview typeReview dateReviewerNext review due
Fill in: unique ID, as in the registerFill in: initial (before use), annual, or triggered, with the triggerFill in: dateFill in: name and titleFill in: date
ItemDescription
Service name and editionFill in: the service, and the edition or tier actually used
ProviderFill in: organization, and any sub-service providers the service relies on, such as the hosting platform
Service typeFill in: infrastructure, platform or software as a service; hosting; managed security; other outsourced operation
Systems that rely on itFill in: system names and identifiers
Business purposeFill in: why the organization uses the service
Contract or agreementFill in: contract number, term and end date, or the online terms accepted and their date
Information and impact levelFill in: each type of information the service processes, stores or transmits, with its impact level
Personally identifiable informationFill in: the types involved, or “none”
Data locationFill in: countries or regions where data is stored and processed, including backups and support access
Connection to the systemFill in: how the system connects, and the information exchange agreement ID, or “no connection”
Service ownerFill in: name and title of the person who manages the relationship

2. Security and privacy requirements in the contract

Section titled “2. Security and privacy requirements in the contract”

This section confirms the contract or service agreement states the organization’s requirements before the service is used.

  • The provider shall 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)
RequirementIn the contract (yes, no or not applicable)WhereNotes
Controls the provider implements, and the baseline or framework they meetFill in: answerFill in: clauseFill in: notes
Independent attestation provided, and how oftenFill in: answerFill in: clauseFill in: notes
Security incident and breach notification, with the timeFill in: answerFill in: clauseFill in: notes
Notice of significant changes to the service, its sub-service providers or its data locationsFill in: answerFill in: clauseFill in: notes
Functions, ports, protocols and services the service needs, identified by the providerFill in: answerFill in: clauseFill in: notes
Privacy requirements, such as use limits and breach notificationFill in: answerFill in: clauseFill in: notes
Data location limitsFill in: answerFill in: clauseFill in: notes
Availability, backup and recovery commitmentsFill in: answerFill in: clauseFill in: notes
Right to assess, or access to evidence on requestFill in: answerFill in: clauseFill in: notes
Return and deletion of the organization’s data when the service endsFill in: answerFill in: clauseFill in: notes
Requirements flowed down to the provider’s subcontractorsFill in: answerFill in: clauseFill in: notes
  • The reviewer shall record each requirement that is missing, and the service shall not be used until it is added or the risk is accepted in section 6. (SA-9a)

3. Evidence of the provider’s compliance

Section titled “3. Evidence of the provider’s compliance”
ItemDescription
Evidence typeFill in: for example an independent service auditor’s report on controls, a certification against a security standard, a government authorization, or the organization’s own assessment
Issued byFill in: the independent assessor or authorizing body
Period or date coveredFill in: start and end dates, or the certificate’s validity
Scope matches the service usedFill in: yes, or what is outside the scope
ResultFill in: for example an unqualified opinion, or the qualifications and exceptions
Sub-service providers included or carved outFill in: list

Exceptions and customer controls:

Item from the evidenceTypeEffect on the systemActionTracked in
Fill in: exception, or customer control the report expects the organization to operateFill in: exception or customer controlFill in: effectFill in: what the organization does about itFill in: POA&M item, system security plan section, or “none needed”
  • The reviewer shall confirm the evidence is current and covers the service actually used. (SA-9c)
  • The reviewer shall follow up each exception in the evidence, and each customer control the evidence expects the organization to operate, and record weaknesses that affect the system in its plan of action and milestones. (SA-9c, CA-5)
Control or areaProviderOrganization nameSharedWhere recorded in the system security plan
Fill in: for example account management, logging, encryption, backup, vulnerability remediationFill in: what the provider doesFill in: what the organization doesFill in: yes or noFill in: section

Oversight and user roles:

RoleWhoResponsibilities for this service
Service ownerFill in: name and titleFill in: for example managing the contract, receiving the provider’s reports and notices
Security oversightFill in: name and titleFill in: for example this review, and reviewing the provider’s evidence each year
AdministratorsFill in: teamFill in: for example configuring the organization’s settings and accounts in the service
UsersFill in: groupFill in: for example using the service only for the approved purpose and information
  • The System owner shall record the oversight roles, the user roles and the shared responsibility matrix for the service, and show each control in the system security plan as inherited, shared or system-owned. (SA-9b)

5. Functions, ports, protocols and services

Section titled “5. Functions, ports, protocols and services”

This section applies to Fill in: external system services that require the identification of functions, ports, protocols, and other services Typical: all external system services that connect to the system.

Function or servicePort and protocolDirectionAllowed under the organization’s list (CM-7)Boundary rule (SC-7)
Fill in: functionFill in: port and protocolFill in: inbound or outboundFill in: yes, or the exceptionFill in: rule reference
  • The System owner shall require the provider to identify the functions, ports, protocols and other services required for the use of the service, and record the list in the system security plan. (SA-9(2))
  • The reviewer shall check the list against the organization’s prohibited and restricted functions, ports, protocols and services before the service is used. (SA-9(2))
Risk or weaknessRatingResponseTracked in
Fill in: riskFill in: ratingFill in: mitigate, accept, transfer or avoid, with the measuresFill in: risk register or POA&M item

Decision: Fill in: approved for use; approved with conditions, listed below; or not approved.

Conditions: Fill in: conditions, or “none”.

  • A risk that remains after the review shall be accepted by the authorizing official for each system that relies on the service, before the service is used. (SA-9)
  • 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 repeat this review at least annually, when new evidence from the provider arrives, and when any of these occurs: a security incident or breach at the provider that affects the service, a significant change to the service or its sub-service providers, new evidence with exceptions, a change in the information the organization puts in the service or its impact level, or a contract renewal. (SA-9c)
Monitoring activityFrequencyWhoLast done
Review of the provider’s independent attestationFill in: for example each year, when the new report is issuedFill in: roleFill in: date
Review of the provider’s status or continuous monitoring reportsFill in: for example monthly or as they arriveFill in: roleFill in: date
Contract service reviewFill in: for example quarterlyFill in: roleFill in: date
Check of the provider’s security notices and advisoriesFill in: for example as they arriveFill in: roleFill in: date
NameRoleDecision or recommendationSignatureDate
Fill in: nameReviewer, security teamFill in: recommendationFill in: date
Fill in: nameSystem ownerFill in: recommendationFill in: date
Fill in: nameAuthorizing officialFill in: decision, and risk acceptance where section 6 needs itFill in: date

OMB Circular A-130, 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 to ensure 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, 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; agencies use the FedRAMP authorization package to issue their own authorization to operate or use (footnote 7). The assessment of security controls and materials in a FedRAMP authorization package is presumed adequate for use in an agency authorization to operate, which does not alter the agency’s own responsibility for compliance or its authority to require more where it has a demonstrable need (44 U.S.C. § 3613(e)). As of September 2026.

  • For a cloud product or service within the scope of OMB M-24-15, the reviewer shall record its FedRAMP authorization and impact level in section 3, and the service shall not process Federal information without one. (SA-9a)
  • The authorizing official shall issue the agency’s own authorization to use a FedRAMP-authorized service, relying on the FedRAMP package’s assessment as 44 U.S.C. § 3613(e) provides, and recording any agency-specific requirements beyond it with the demonstrable need for them. (SA-9)
  • For a system a contractor or other entity operates on the agency’s behalf, the System owner shall record in this review how the agency oversees it and verifies that its controls are effectively implemented, as OMB Circular A-130, Appendix I, section 4.j(2), requires. (SA-9c)
Review IDServiceProviderSystems that rely on itService typeInformation and impact levelEvidence type and period endLast reviewDecisionOpen exceptionsNext review dueService owner
Fill in: IDFill in: serviceFill in: providerFill in: systemsFill in: typeFill in: information and impact levelFill in: evidence and dateFill in: dateFill in: approved, approved with conditions, or not approvedFill in: number, with POA&M itemsFill in: dateFill in: name

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.