What This Objective Requires
CM.L2-3.4.3[a] ensures you’ve defined thresholds for change approval so that not every minor configuration update requires full review, but impactful changes are formally approved before implementation. This helps maintain secure, controlled update practices across systems that support organizational operations and CUI handling. :contentReference[oaicite:0]{index=0}
Examples of changes that typically require pre-approval include operating system upgrades or rebuilds, application version updates, firewall or network configuration changes, new software installations, alterations to access control settings or user roles, and modifications to systems that store or access Controlled Unclassified Information. :contentReference[oaicite:1]{index=1}
Why Defining Pre-Approval Criteria Matters
Without clear criteria for which changes require pre-approval, high-risk updates can be implemented without oversight. This can weaken your baseline configuration and overall security posture while reducing accountability over who made impactful changes and why. :contentReference[oaicite:2]{index=2}
Documented pre-approval criteria help ensure change decisions are planned, controlled, and appropriately reviewed before they are made, supporting both operational stability and audit readiness. :contentReference[oaicite:3]{index=3}
How to Define Pre-Approval Criteria
Start by defining a written list of change types that require formal pre-approval in your configuration management policy, change management standard operating procedures (SOP), and System Security Plan (SSP). Categorize changes by risk level—such as high-risk versus low-risk—and link this list directly into your change request or ticketing workflow. :contentReference[oaicite:4]{index=4}
This ensures that reviewers and approvers can quickly determine when pre-approval is needed and helps prevent informal or ad hoc changes from slipping through controls. Regularly review and update criteria to reflect evolving system architectures and threats. :contentReference[oaicite:5]{index=5}
Change Pre-Approval Criteria Table
| Change Category | Why It Requires Pre-Approval | Documentation Needed | Typical Reviewer |
|---|---|---|---|
| Access control modifications | Affects who can access sensitive systems | Change reason, role impact, ownership | Security / IAM owner |
| Firewall and network rule changes | Affects segmentation and exposure | Rule summary, impact note | Network/security lead |
| Software/platform upgrades | May affect stability or compatibility | Version details, rollback plan | Platform owner |
| Baseline configuration adjustments | Potential drift from controlled state | Baseline diff, rationale | Configuration manager |
| Logging and monitoring setting changes | Influences visibility and alerting | Setting details, risk notes | Security operations |
Evidence Assessors Commonly Expect
Assessors commonly examine documented criteria that clearly state which types of changes require pre-approval, along with example change requests showing that criteria were used to determine when pre-approval was necessary. :contentReference[oaicite:6]{index=6}
They may also review policy references, role definitions for approvers, and records showing prior approval decisions tied to the documented list. :contentReference[oaicite:7]{index=7}
Common Gaps to Avoid
Common gaps include failing to define any criteria, leaving approval decisions to individual discretion, or treating all changes the same—which can lead to either over-approval or under-review. :contentReference[oaicite:8]{index=8}
Having a clear, structured list tied to your change control process helps prevent these issues and provides clearer evidence during assessments. :contentReference[oaicite:9]{index=9}
FAQ
What does CM.L2-3.4.3[a] require?
It requires organizations to define which configuration changes require formal pre-approval before implementation.
Why define pre-approval criteria for changes?
Defining pre-approval criteria ensures that high-impact changes are reviewed and controlled consistently, reducing risk and supporting accountability.
What evidence demonstrates compliance?
Evidence includes documented criteria, a list of change types requiring pre-approval, and examples showing the criteria applied before approval decisions.