KSI-CMT-VTDPartial reviewValidating Throughout Deployment
CMT — Change Management
NIST 800-53: cm-3, cm-3.2, cm-4.2, si-2
- Who this is for
- Cloud service providers
- Service class
- All service classes
- Implementation guidance
- Reviewed guidance available
- Evidence automation
- Not published
What your CSP needs to do
"Throughout deployment" is the operative phrase: validation has to be automated both before a change merges and after it is running. Four proof points:
- CI pipelines exist in version control —
.github/workflows/on GitHub,.gitlab-ci.ymlon GitLab,bitbucket-pipelines.ymlon Bitbucket. - Those pipelines actually run — recent workflow/pipeline executions, not dormant config committed a year ago.
- Those pipelines actually test — detectable test commands in the CI config, not just build-and-push steps.
- Validation continues after deploy: patch compliance and vulnerability scanning on running resources (AWS SSM Patch Manager, AWS Inspector), continuous posture and managed-config assessment (Azure Defender secure score, Azure VM Guest Configuration), and automated inventory tracking of resource changes (GCP Cloud Asset Inventory).
The most common way CSPs fail it: CI exists but doesn't validate — a pipeline that lints and deploys proves automation, not testing. The "has tests" question is checked separately from "has CI" for exactly this reason.
Implementation: AWS
Two post-deploy signals prove that validation keeps running after changes ship.
- SSM Patch Manager (
aws:ssm_patch_compliance) — every managed instance must be patch-compliant: no missing critical or security patches, no failed patch operations, managed by a patch baseline. Scored per instance — one non-compliant instance is a listed failure. When no instances are managed at all, the evidence is an explicit failing row with a reason, so the KSI does not false-pass on an unscanned environment. - Inspector v2 (
aws:inspector) — satisfied by any one region where Inspector is enabled and actually covering more than zero resources. Enabled-but-covering-nothing fails. The evidence reports enabled scan types and active finding counts (critical/high), proving post-deploy CVE detection is live — CI tests catch issues before merge; Inspector catches vulnerabilities introduced into running resources after.
Implementation: Azure
Two signals prove continuous post-deploy assessment.
- Defender for Cloud secure score (
azure:defender_secure_score) — every subscription must have an active Defender secure score. An unavailable score fails: it means the Defender assessment baseline is not running for that subscription. The evidence records the current/max score and percentage as continuous posture measurement. - VM Guest Configuration (
azure:vm_guest_config) — every VM with a Guest Configuration assignment must report Compliant. NonCompliant, NotAssigned, or missing assignments fail: managed configuration drift is not being detected and remediated on that VM.
Implementation: GCP
One signal.
- Cloud Asset Inventory (
gcp:cloudasset) — satisfied by any one project where Cloud Asset Inventory is enabled and tracking more than zero assets. Enabled-but-tracking-nothing fails. This proves automated component-inventory updates: every resource change in the project is captured, the automation CM-8(1) asks for.
What passing evidence looks like
Passing automated evidence contains these signals (each row carries the collected_at timestamp of the most recent connector scan; no separate freshness gate applies):
scm:ci_exists— org-level, satisfied by any one connected SCM (GitHub, GitLab, or Bitbucket) that has CI configuration in version control; the evidence reports how many repos have CI out of the total.scm:ci_runs— org-level: any SCM that has CI config shows recent pipeline/workflow runs. SCMs with no CI at all are filtered out of this signal so the missing-config failure isn't double-counted.scm:ci_has_tests— org-level: any SCM-with-CI has test commands detected in its CI config. Same filter applies.aws:ssm_patch_compliance— per managed instance, patch-compliant (see Implementation: AWS)aws:inspector— any one region enabled and covering resources (see Implementation: AWS)azure:defender_secure_score— per subscription, Defender secure score active (see Implementation: Azure)azure:vm_guest_config— per VM, Guest Configuration assignment Compliant (see Implementation: Azure)gcp:cloudasset— any one project with Cloud Asset Inventory enabled and tracking assets (see Implementation: GCP)
What an assessor may challenge
- CI with no test step. Pipelines that build, package, and deploy but contain no detectable test commands —
scm:ci_has_testsfails even whilescm:ci_existspasses. - Dormant pipelines. CI config is committed but there are no recent runs — automated validation is configured, not executing.
- Scanners that scan nothing. AWS Inspector enabled but covering zero resources, or SSM Patch Manager with no managed instances — both are explicit failures, not silent passes.
- Post-deploy drift unwatched on Azure. VMs whose Guest Configuration assignment reports NonCompliant (or was never assigned), or subscriptions where the Defender secure score is unavailable because the assessment baseline isn't running.
- Inventory blind spot on GCP. Cloud Asset Inventory disabled, or enabled but tracking zero assets — resource changes aren't feeding any automated inventory.
Official FedRAMP source
Verbatim from FedRAMP/rules
Persistent testing and validation of changes throughout deployment is automated.
How Boundera handles this
Boundera evaluates KSI-CMT-VTD across the whole deployment lifecycle. Pre-merge, scm:ci_exists, scm:ci_runs, and scm:ci_has_tests are evaluated over GitHub, GitLab, and Bitbucket — any one connected SCM can satisfy each. Post-deploy, coverage is provider-specific as implemented: on AWS, aws:ssm_patch_compliance scores every managed instance and aws:inspector confirms live vulnerability scanning; on Azure, azure:defender_secure_score scores each subscription and azure:vm_guest_config scores each VM; on GCP, gcp:cloudasset confirms automated inventory tracking.
What still needs you: connect your SCM and cloud connectors, put real test commands in your pipelines, and enroll instances/VMs into SSM Patch Manager and Guest Configuration so the per-resource signals have something to score. Request a demo to watch KSI-CMT-VTD evaluate your real pipelines, patch compliance, and scanner coverage end to end.
References
- FRMR rule definition:
data/fedramp-rules/fedramp-consolidated-rules.json(KSI.CMT.indicators["KSI-CMT-VTD"]) - NIST SP 800-53 Rev 5: CM-3, CM-3(2), CM-4(2), SI-2
Content provenance
Official requirement text is sourced from FedRAMP/rules . Boundera implementation guidance has not been fully reviewed for this item.
Guidance authors: Eddy Agu.