AST-38: Technical Debt Reviews
Mechanisms exist to conduct ongoing “technical debt” reviews of hardware and software technologies to remediate outdated and/or unsupported technologies.
Renumbered: Formerly SEA-02.3 in SCF 2025.4.
Control Question: Does the organization conduct ongoing “technical debt” reviews of hardware and software technologies to remediate outdated and/or unsupported technologies?
General (4)
| Framework | Mapping Values |
|---|---|
| NIST AI 100-1 (AI RMF) 1.0 | GOVERN 1.7 |
| PCI DSS 4.0.1 (source) | 12.3.4 A3.3.2 |
| PCI DSS 4.0.1 SAQ D Merchant (source) | 12.3.4 |
| PCI DSS 4.0.1 SAQ D Service Provider (source) | 12.3.4 |
US (2)
| Framework | Mapping Values |
|---|---|
| USA Federal CISA CPG 2022 | 2.K |
| USA Federal DoW BaTB IT 2026 | 3 |
EMEA (3)
| Framework | Mapping Values |
|---|---|
| EMEA EU DORA 2023 | Article 8.7 |
| EMEA EU DORA RTS 2024 | Article 4.2(c) Article 8.2(a)(iii) |
| EMEA LUX CCSF 20/750 2020 | 3.5-55 |
Capability Maturity Model
Level 0 — Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 — Performed Informally
SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.
Level 2 — Planned & Tracked
SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).
Level 3 — Well Defined
Asset Management (AST) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with AST domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Standardized Operating Procedures (SOP) associated with AST domain capabilities are well-documented and kept current by process owners. ▪ An IT Asset Management (ITAM) team, or similar function, is appropriately staffed and supported to implement and maintain AST domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of ITAM operations (e.g., ITAM platform, (e.g., Configuration Management Database (CMBD) Asset Management solution). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with AST domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to conduct ongoing “technical debt” reviews of hardware and software technologies to remediate outdated and/or unsupported technologies.
Level 4 — Quantitatively Controlled
Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.
Level 5 — Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
Assessment Objectives
- AST-38_A01 “technical debt” reviews of hardware and software technologies are routinely conducted.
- AST-38_A02 the results of “technical debt” reviews are leveraged as justification to remediate outdated and/or unsupported technologies.
Evidence Requirements
- E-AST-09 Computer Lifecycle Plan (CLP)
-
Documented evidence of a Computer Lifecycle Plan (CLP) that describes how the life of technology assets is managed.
Asset Management
Technology Recommendations
Micro/Small
- Computer Lifecycle Program (CLP)
- IT Asset Management (ITAM) program
- Risk Management Program (RMP)
Small
- Computer Lifecycle Program (CLP)
- IT Asset Management (ITAM) program
- Risk Management Program (RMP)
Medium
- Computer Lifecycle Program (CLP)
- IT Asset Management (ITAM) program
- Risk Management Program (RMP)
Large
- Computer Lifecycle Program (CLP)
- IT Asset Management (ITAM) program
- Risk Management Program (RMP)
Enterprise
- Computer Lifecycle Program (CLP)
- IT Asset Management (ITAM) program
- Risk Management Program (RMP)