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Security & Compliance Glossary

POA&M (Plan of Action and Milestones)

A Plan of Action and Milestones, usually shortened to POA&M, is a tracked record of security requirements that are not yet met, each with a named owner, a planned remediation and a target completion date. It sits alongside the System Security Plan.

In practice

The POA&M is a live document rather than a submission artefact. Items close, new ones open when the environment changes, and an assessor comparing this year's to last year's will notice if the same entries have simply had their dates pushed.

The most common weakness is vagueness. "Improve logging" with an owner of "IT" and a date of "Q4" tells nobody anything. "Enable CloudTrail in the two remaining regions, owner J. Smith, 30 November" can be verified.

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Where it comes up

A POA&M is how you carry an unmet requirement without failing. It records what is not in place, who owns it, what the fix is and when it lands.

Assessors read the POA&M alongside the System Security Plan. The SSP says how each requirement is met; the POA&M covers the ones that are not yet. Dates that have already passed are the fastest way to lose credibility with an assessor.

POA&M (Plan of Action and Milestones): common questions

Is a POA&M an admission of failure?

No. Every real program has open items. What matters is that each has a named owner, a specific remediation and a date that has not already gone by.

Do SOC 2 and ISO 27001 require a POA&M?

Not by that name. ISO 27001 uses a risk treatment plan and SOC 2 relies on management responses to findings, but the substance is the same: a tracked list of gaps with owners and dates.

How long can something sit on a POA&M?

The honest test is whether the date is real and whether it moves each time somebody looks.