C5-Readiness

BSI C5

C5 domain AM: building an asset register with classification

The AM domain requires the cloud service provider to know all hardware and software assets of its service, classify them by protection needs and manage them throughout their lifecycle, including virtual machines, storage and containers at a hyperscaler. It comprises twelve criteria, six of them new in C5:2026, with 26 basic subcriteria. Using a SaaS example, this page shows a classification scheme and an asset register that stands up to an audit.

Server rack in the dark, small labels on the devices, one label caught by golden light

Last updated: 2026-11-06

This page covers the AM (asset management) domain of C5:2026, section 5.4 of the catalogue. How criteria and subcriteria are structured in general is explained on the page C5 criteria catalogue.

What is the AM domain about?

AM governs how the cloud service provider records and protects its assets. The catalogue states as its objective to identify the organisation’s own assets and to ensure an appropriate level of protection throughout their lifecycle (section 5.4). According to the supplementary information on AM-01, assets are the objects in the provider’s area of responsibility that are required for the information security of the service, for example firewalls, load balancers, web servers, application and database servers. They consist of hardware objects, which expressly include virtual infrastructure resources, and software objects such as containers, operating systems, databases, microservices and application programming interfaces.

The domain comprises twelve criteria, AM-01 to AM-12, with 26 basic subcriteria, 2 sharpening and 9 complementing additional subcriteria. According to the change history, six criteria are new: AM-01, AM-03, AM-04, AM-10, AM-11 and AM-12. The asset inventory is also the basis for other domains, for example for the risk assessment (AM-02.03B refers to OIS-07), the network topology (COS-07.03B) and container management (OPS-34.02B refers to AM-02, AM-03 and AM-09).

A note for bilingual teams: in the English version 1.0.1, the complementing subcriterion on keeping the inventory up to date is AM-01.02AC, in the German version 1.1.0 it is AM-02.01AC. The content is the same.

Starting point: inventory in a console and a spreadsheet

Fictitious example, not a client. A provider runs a platform through which building authorities and architecture firms exchange building applications, plans and approvals. Around 45 employees; the service runs as SaaS on the infrastructure of a large cloud provider: a managed Kubernetes cluster with microservices, a managed database, an object storage for plans and documents. Administrators sign in with FIDO2 security keys.

Before the project, the situation looks like this:

  • The cloud resources can be seen in the platform’s console, laptops and security keys are listed in an IT spreadsheet. There is no common inventory.
  • Which resource contains which data and who is responsible for it is recorded nowhere; some test resources have no recognisable purpose.
  • The software list is limited to the provider’s own microservices. Which libraries, images and database version run underneath is known only to the operations team.
  • Changes to the spreadsheet are overwritten, without history.
  • A security key of an administrator who has left has not been returned for weeks.

Who is responsible for what: provider, platform, customer?

For a SaaS service on third-party infrastructure, AM is split along the boundary between virtual and physical resources. Our classification for the example:

AspectProviderPlatform (subservice organisation)Customer (building authority, architecture firm)
Virtual resources: cluster, database instance, storage, networksinventories and classifies them (AM-02, AM-03, AM-09); may use the platform’s tools for this if it considers them suitable based on its frameworkprovides inventory functions-
Software: microservices, images, libraries, database systemmaintains the software inventory with dependencies (AM-04)is responsible for the software of the managed services-
Physical servers and data media of the data centresdescribes which controls it assumes at the subservice organisation and monitors them as described in the SSO domaincommissioning, decommissioning, storage and transport of its own hardware (topics of AM-06, AM-07, AM-10, AM-11); outside your audit under the carve-out method-
End user devices and security keys of personnelinventories them where the risk assessment calls for it, commits personnel to secure use and return (AM-08, AM-12)--
Protection needs of customer dataclassifies assets by the protection needs of the data they process-ensures, under the complementary customer criteria for AM-09, that the protection need of its information is adequately determined

How the data centres themselves are secured belongs to the PS domain. Whether individual hardware criteria are applicable to your service and how you include subservice organisations is defined with the scope and justified in the system description. You may not exclude a criterion there because your controls are missing.

What does a classification scheme under AM-09 look like?

AM-09 requires assets to be classified by the protection needs of the data they process, store or transmit. The protection need is determined by the people responsible for the assets according to a uniform, documented scheme (AM-09.03B). The scheme provides levels of protection for confidentiality, integrity, availability and authenticity, aligned with the recovery objectives in the business continuity and disaster recovery plans (AM-09.04B). Our scheme for the example:

LevelConfidentialityIntegrity and authenticityAvailability (link to recovery plans)Examples
highpersonal data and building documents of customers, keys and credentialschanges to plans and approvals must be traceable and unalteredrecovery within 4 hours, data loss at most 15 minutesdatabase, object storage, identity service, administrators’ security keys
mediuminternal operational data, logs without content dataerrors are noticed and correctedrecovery within 24 hoursmonitoring, ticket system, build pipeline
normalpublic or non-critical informationno particular requirementsrecovery within 5 working dayswebsite, documentation for customers

The target values in the availability column are example values that must come from the provider’s own business continuity and disaster recovery plans; how to set them is shown in the BCM domain. You review the levels at least annually and in case of significant changes to the service (AM-09.02B). If a provider does not classify its assets individually, according to the supplementary information on AM-09 all assets may be treated as requiring the highest level of protection. For small services this is a possible route, but in our assessment a demanding one, because the strictest measures then apply everywhere.

What does an audit-ready asset register look like?

AM-03.01B and AM-04.01B define what an entry must achieve: identify the asset, provide visibility into its lifecycle or dependencies and enable the provider to control it and perform a risk assessment. The supplementary information lists possible fields for this, such as name, function, model, location, owner and information security requirements, for software the version and the parent resource. An asset owner is the individual or role responsible for managing and protecting the asset, not the legal owner. The catalogue speaks of the asset inventory; the asset register is the work product with which you maintain it. An excerpt from our register for the example (protection needs as C/I/A/A in the order confidentiality, integrity, availability, authenticity; the first A stands for availability, the second for authenticity):

IDTypeName and functionLocationOwnerProtection needs C/I/A/AStatusDepends on
HW-012Hardware, virtualProduction node pool, runs the microservicesRegion Germany, two zonesHead of operationshigh/high/high/highin operationPlatform (subservice organisation)
HW-031Hardware, virtualObject storage for building documentsRegion GermanyHead of operationshigh/high/medium/highin operationPlatform
HW-107Hardware, end user deviceFIDO2 security key for administrationwith the personPerson as per issue recordhigh/high/medium/highissued-
SW-204Software, databaseDatabase system of the managed database, major version as per platformon HW-020Head of operationshigh/high/high/highin operation, end of support as per vendor recordedHW-020
SW-311Software, microserviceService “Plan approval”, container image version 2.14on HW-012Head of developmenthigh/high/high/highin operationHW-012, SW-204
HW-044Hardware, virtualTest resource without recognisable purposeRegion Germanyopenopenunder clarification, deletion planned-

Three points make the register audit-ready. First, recording: performed automatically and/or by the people responsible, so that the inventory is complete, accurate, valid and consistent (AM-02.02B). Second, the change log: changes to the recorded information are logged (AM-02.04B); a spreadsheet that can be overwritten is not enough for this. Third, the link to access rights: AM-02.05B requires lists of the users with access to a resource and their rights; these may come from the identity service, as described on the page IAM. Containers that you operate yourself are inventoried with their lifecycle; the details are in the OPS domain. The software list for third-party components (SBOM) belongs to DEV.

Example control description for AM-02

A register is only as good as its reconciliation with reality. Our example control for the provider above (own wording, not catalogue text):

FieldExample
Control IDK-AM-02-01 Reconciliation of the asset register with platform and device management
Mapped toAM-02.01B to AM-02.04B, AM-09.01B, AM-09.03B
ObjectiveEvery asset in scope is in the register with owner and protection needs; new, changed and deleted resources are updated within one week, every change is logged.
OwnerHead of operations (cloud resources and software), IT (end user devices); checked by the information security officer
Trigger and frequencydaily automated reconciliation; weekly handling of deviations; review of the entire register once a quarter
ExecutionA script reads all resources from the platform and all devices from device management every day and compares them with the register. New resources without an entry, entries without a resource and entries without owner or protection needs are passed as a ticket to the responsible team. The team completes the entry in the register, which stores every change with person and time.
CheckThe information security officer reviews the list of open deviations weekly and, each quarter, a sample of entries against the actual configuration.
EscalationIf a ticket is still open after one week, it goes to the head of operations; a resource without an owner after two weeks is locked and deleted after consultation. Deviations are assessed in the risk register.
EvidenceReports of the daily reconciliation, tickets with handling time, change log of the register, records of the samples

Automated monitoring of the inventory process corresponds to the complementing subcriterion AM-01.02AC (AM-02.01AC in the German version). Whether you include it is your decision; as a way of working we recommend the reconciliation even without including it, because it is what makes the basic subcriteria verifiable in the first place.

Diagram “Structure of an asset register under C5 AM”. At the top the framework with asset types, scheme for protection needs, lifecycles and inventory procedures (AM-01). Below it an excerpt from the example register with the columns ID and name, type, owner, protection needs C/I/A/A and depends on; owner and protection needs highlighted (AM-09). Hardware, physical and virtual (AM-03): HW-012 production node pool and HW-107 FIDO2 security key. Software with dependencies (AM-04): SW-204 database system and SW-311 service “Plan approval”. Three inflows into the register: highlighted as the example control, inventory performed automatically and by the people responsible with daily reconciliation with platform and device management (AM-02.02B); every change logged (AM-02.04B); lists of users with access per resource (AM-02.05B). At the bottom physical hardware, in the example at the subservice organisation: commissioning (AM-06), storage (AM-10), transfer (AM-11), decommissioning with deletion or destruction of the media (AM-07).
Tap the graphic to open it at full size.Structure of an asset register in the AM domain. Source: BSI, Cloud Computing Compliance Criteria Catalogue C5:2026, version 1.0.1, section 5.4; own illustration.

What evidence the auditor wants to see

For AM, the register and its history are the central evidence, together with procedures and records for the lifecycle steps. Examples from our scenario:

EvidenceCriterionSourceOwnerTiming
Asset management framework with asset types, scheme, lifecycles and inventory proceduresAM-01.01BISMS documentationinformation security officerversion valid in the period
Asset register with owner, protection needs and change historyAM-02.01B to 04B, AM-03.01B, AM-04.01Bregister, reconciliation reportshead of operations, ITreference date on request, changes in the period
Lists of users with access per resourceAM-02.05Bexport from identity service and platformoperationsreference date on request
Policy for the secure use of assetsAM-05.01B, AM-05.02Bdocument repositoryinformation security officerversion valid in the period
Issue records and commitments for laptops and security keys, return recordsAM-08.01B to 03Bdevice management, HR systemITsample of joiners and leavers
Classification scheme and record of the review of the levelsAM-09.02B to 04BISMS documentationinformation security officer, asset ownerannual review and occasions in the period
Configuration of end user devices: encryption, anti-malware, blocking of removable mediaAM-12.01Bdevice managementITstate at the start and end of the period

An evidence register maps each subcriterion to its evidence; how to maintain it is shown on the page Evidence and documentation.

Possible gaps: cause, effect, remedy

The following gaps follow from the wording of the criteria and the scenario above. If a single subcriterion is not met, the criterion counts as not met, and the auditor reports the deviation (sections 3.4.12 and 3.4.13).

Possible gapCauseEffectRemedy
No common inventoryCloud resources in the console, devices in a spreadsheet.AM-02.01B requires an inventory of hardware and software assets in accordance with the framework; two unconnected sources do not evidence complete recording.One register with automated recording from both sources, as in K-AM-02-01.
Entries without owner and protection needsPurely technical recording.AM-02.03B requires the information needed for risk management, AM-09.01B classification by the protection needs of the data.Mandatory fields for owner and protection needs, deviation ticket if values are missing.
Changes without historyThe spreadsheet is overwritten.AM-02.04B requires changes to the recorded information to be logged.Maintain the register in a system with a change log.
Software inventory without dependenciesOnly the provider’s own microservices recorded.AM-04.01B requires an inventory of all software assets with visibility into which other assets use them.Add images, runtime environments and database system, derive dependencies from the deployment.
Security key not returned after leavingReturn not linked to the leaving process.AM-08.02B requires provable return; if this is not possible by the date of leaving, the provider removes the access rights no later than the date of leaving under AM-08.03B.Return as a step in the leaving process (see HR), block the key in the identity service.

All criteria of the AM domain

Titles as in the English version 1.0.1, number of subcriteria counted per section 5 of the English version (B = basic, AS = sharpening, AC = complementing). In the German version 1.1.0, AM-01 has one and AM-02 one complementing subcriterion (AM-02.01AC there corresponds to AM-01.02AC here). The column “What it covers” is our own short description, not catalogue text; the wording of the criteria in the catalogue is binding.

IDTitle (catalogue)B/AS/ACWhat it covers
AM-01Asset Management Framework1/0/2The documented framework: which assets, which types, which scheme for protection needs, which lifecycles, which inventory procedure.
AM-02Asset Inventory5/0/0The inventory itself: completely recorded, with information for risk management, change log and lists of users with access.
AM-03Hardware Asset Inventory1/0/0What a hardware entry must contain, for physical and virtual resources.
AM-04Software Asset Inventory1/0/1What a software entry must contain, including dependencies on other assets.
AM-05Policy for the Proper and Secure Use of Assets2/0/0Rules for handling assets over the lifecycle, from approval to deletion of data.
AM-06Commissioning of Hardware2/0/0Approval of physical hardware for production after risk assessment and verification of the secure configuration.
AM-07Decommissioning of Hardware2/1/1Approved decommissioning with permanent deletion or destruction of the media.
AM-08Commitment to Proper Use, Safe and Secure Handling and Return of Assets3/0/0Commitment of personnel before use, return on leaving, removal of rights if the return is missing.
AM-09Asset Classification and Labelling4/0/4Classification by the protection needs of the data, uniform scheme for four protection objectives, annual review.
AM-10Protection of Hardware on Hold1/1/0Secure storage of inactive production hardware.
AM-11Transfer of Hardware3/0/0Authorised, tracked and protected transport of production hardware.
AM-12Removable Media and Endpoint Devices1/0/1Controls for managed endpoints and removable media, for example encryption, anti-malware and restricted use of removable media.

Among the additional criteria, AM-07.01AS (decommissioning also for development, test and staging environments), AM-04.01AC (information on how long a software asset will receive security updates) and AM-09.03AC and AM-09.04AC (logging and monitoring take the protection needs of the assets into account) are particularly tangible for SaaS providers.

Relationship to ISO/IEC 27001:2022 Annex A

The following mapping is our own, unofficial classification by topic. The BSI has not yet published a cross-reference for C5:2026. The catalogue refers to the BSI website for it (section 3.3). So far the table there covers C5:2020 only, and the BSI says the table for C5:2026 is “scheduled for publication in the near future” (as of 6 November 2026). According to the catalogue, even an official table only shows thematic proximity, not fulfilment of the criteria (section 3.3). The short labels are ours, not titles from the standard. What you can reuse overall from a certified ISMS is shown on the page C5 and ISO 27001.

C5:2026ISO/IEC 27001:2022 Annex ATopic (short label)What C5 additionally requires in concrete terms (our assessment)
AM-01 to AM-04A.5.9Inventoryseparate requirements for hardware and software entries, change log, dependencies, virtual resources
AM-05, AM-08A.5.10, A.5.11Acceptable use and returnremoval of rights no later than the date of leaving if the return is missing
AM-06no direct counterpart; close to A.8.9Approval of hardwareapproval process with risk assessment
AM-07A.7.14Disposal and reuseapproval by authorised personnel
AM-09A.5.12, A.5.13Classification and labellingfour protection objectives including authenticity, aligned with recovery objectives
AM-10, AM-11A.7.8, A.7.9, A.7.10Storage and transportchain-of-custody tracking during transport
AM-12A.7.10, A.8.1Removable media and endpoint devicesprohibition of removable media except for unavoidable administration

Frequently asked questions

Do virtual machines and containers belong in the inventory?+
Yes. According to the supplementary information on AM-01, physical and virtual infrastructure resources count as hardware objects, and containers, operating systems, databases, microservices and application programming interfaces as software objects.
May I use the cloud platform’s inventory?+
Yes. If you procure your infrastructure as virtual resources from a service organisation, you may use its tools to inventory those assets, insofar as you consider them suitable based on your asset management framework (supplementary information on AM-02). Owner, protection needs and change log must still be in place.
Do laptops and smartphones belong in it?+
End user devices belong in it where the provider has determined in a risk assessment that they could endanger the information security of the service in the event of loss or unauthorised access, for example mobile devices used as security tokens for authentication. Managed endpoints are also subject to the controls under AM-12.
Does every asset have to be classified individually?+
AM-09.01B requires classification by the protection needs of the data. If the provider does not classify specifically, according to the supplementary information all assets may be treated as requiring the highest level of protection.
Why does the subcriterion on keeping the inventory up to date have a different ID in the German version?+
The German version 1.1.0 is more recent than the English version 1.0.1. The complementing subcriterion under which the provider assures that the inventory is up to date by monitoring the process maintaining it is AM-01.02AC in English and AM-02.01AC in German. Name both IDs in bilingual documents.

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Sources

This content provides general technical and organisational information and does not constitute legal advice (no legal services within the meaning of the German RDG).