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TDA-05.4: Software Design Review

TDA 10 — Critical Detect

Mechanisms exist to have an independent review of the software design to validate: (1) Applicable security, compliance and resilience requirements are met; and (2) Identified risks are remediated.

Renumbered: Formerly TDA-06.5 in SCF 2025.4.

Control Question: Does the organization have an independent review of the software design to validate: (1) Applicable security, compliance and resilience requirements are met; and (2) Identified risks are remediated?

General (10)
Framework Mapping Values
CIS CSC 8.1 16.2 16.7 16.12
CIS CSC 8.1 IG2 16.2 16.7
CIS CSC 8.1 IG3 16.2 16.7 16.12
MPA Content Security Program 5.3.1 TS-1.13
NIST 800-218 PO.4 PW.2 PW.2.1 RV.1 RV.1.2
PCI DSS 4.0.1 (source) 6.2.3
PCI DSS 4.0.1 SAQ D Merchant (source) 6.2.3
PCI DSS 4.0.1 SAQ D Service Provider (source) 6.2.3
SCF DPMP 2026 7.1
SPARTA 4.0 CM0043
US (3)
Framework Mapping Values
USA Federal C2M2 2.1 ARCHITECTURE-4f
USA California CCPA 2025 7123(c)(14)
USA New York DFS 23 NYCRR500 2023 Amd 2 500.8(a)
EMEA (2)
Framework Mapping Values
EMEA LUX CCSF 20/750 2020 3.6.1-64
EMEA Saudi Arabia IoT CGIoT-1 2024 2-14-3
Americas (1)
Framework Mapping Values
Americas Canada OSFI B-13 2022 2.4.1 2.4.2

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

Technology Development & Acquisition (TDA) 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 TDA 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 TDA domain capabilities are well-documented and kept current by process owners. ▪ A software development team, or similar function, is appropriately staffed and supported to implement and maintain TDA domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of technology development and acquisition management (e.g., project management software, software escrow solution and software testing tools). ▪ 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 TDA 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 have an independent review of the software design to validate: (1) Applicable security, compliance and resilience requirements are met; and (2) Identified risks are remediated.

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

  1. TDA-05.4_A01 an independent review of the software design confirms that all cybersecurity / data privacy requirements are met and that any identified risks are satisfactorily addressed.

Evidence Requirements

E-TDA-05 Failure Mode and Effect Analysis (FMEA)

Documented evidence of an engineering method designed to define, identify, and present solutions for system failures, problems, or errors.

Technology Design & Acquisition

Technology Recommendations

Micro/Small

  • Note: Typically not required at this size; peer review of designs where feasible

Small

  • Independent peer review of software designs before build

Medium

  • Security architecture review of software designs by someone independent of the development team
  • Review checklist covering requirements, threats and controls

Large

  • Formal independent design review board
  • Review criteria mapped to security, compliance and resilience requirements
  • Findings tracked to closure

Enterprise

  • Enterprise architecture and security design review board with independent reviewers
  • Automated design artifact analysis
  • Design review metrics and governance

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