Requirement ID: SCN-RTR-NNR
The requirement
Providers SHOULD NOT make formal Significant Change Notifications for routine recurring changes; this type of change is exempted from notification requirements. (force: SHOULD NOT)
What does this mean?
Some changes to a cloud system happen over and over as a normal part of running operations. Examples of the general category include ongoing operations work, incident response activities, and the regular process of mitigating or remediating vulnerabilities. These are described in the source as “routine recurring changes.”
This requirement says that when a change fits that routine recurring pattern, a provider should not file a formal Significant Change Notification for it. That class of change is treated as exempt from the notification process.
In short, this is a scoping rule. It tells providers what does not need a formal notification, so effort is focused on changes that actually warrant one.
One important note: the exemption applies only to the requirement to submit a formal notification. Teams must still evaluate each change to determine its type and keep a record of that evaluation, consistent with SCN-CSO-EVA and SCN-CSO-MAR.
This article is also a LinkedIn newsletter. If you would like to receive it straight to your inbox, subscribe here.
Why does this matter?
Significant Change Notifications exist so that changes likely to substantively affect a system’s security or privacy posture get appropriate visibility. If providers filed a formal notification for every routine, predictable, repeated change, the notification stream would fill with low-value noise.
That noise carries real risk. Genuinely significant changes could get buried, review attention could be diluted, and the whole process could slow down. Exempting routine recurring changes keeps the signal meaningful and lets everyone concentrate on the changes that matter most.
What could implementation look like?
This is illustrative, not mandatory. The source states an exemption, not a required method.
One approach is to define clearly, in internal change management policy, what qualifies as a routine recurring change for your environment. The definition could lean on the idea that the change regularly and routinely recurs as part of ongoing operations, vulnerability mitigation, or vulnerability remediation, performed on a consistent, predictable, repeated basis following a documented plan.
Teams could then map their common change types against that definition, so engineers know upfront which changes fall outside the formal notification path. A periodic review of that mapping may help keep it accurate as operations evolve.
Example scenario
A fictional cloud provider runs a monthly patch cycle for its managed database fleet. Each cycle applies vendor security patches on a set schedule, following a documented and repeatable plan.
Because this activity recurs predictably as part of ongoing vulnerability remediation, the provider classifies it internally as a routine recurring change. Following this requirement, the team does not file a formal Significant Change Notification for each monthly cycle. Instead, the provider keeps its notification effort reserved for changes that do not fit the routine recurring pattern.
What evidence could demonstrate implementation?
Examples may include:
- A documented internal definition of what counts as a routine recurring change in your environment
- Change management records showing routine recurring changes handled through a standard operational path rather than a notification path
- Procedures or playbooks describing recurring operational and vulnerability remediation activities
- Records of periodic review of which change types are classified as routine recurring
- Records showing evaluation of change types (per SCN-CSO-EVA and SCN-CSO-MAR), even when a change is classified as routine recurring
Common pitfall
One likely misunderstanding is stretching the “routine recurring” label to cover changes that are actually one-off or that substantively shift the system’s security or privacy posture. The exemption applies to changes that genuinely recur on a predictable, repeated basis. Treating a novel or unusual change as routine just to skip notification could bypass review that a significant change should receive.
Question for your team
Do we have a written, agreed definition of which of our change types are routine recurring, and can our engineers tell that class apart from changes that still need a formal notification?
Key takeaway
Predictable, repeated operational and remediation changes are exempt from formal Significant Change Notifications, which keeps the notification process focused on changes that truly affect security or privacy posture.
Related requirements
None listed in the source data.
Have a question about putting this requirement into practice?
38North Security can help you turn the requirements into an operating model that works in practice. Talk to us →
The quoted requirement above is from the provided FedRAMP CR-26 JSON. The implementation ideas, example scenario, and evidence examples are general guidance and should be validated against official FedRAMP guidance.
About the Authors
