CIS Control 16.13: Application Penetration Testing
Application penetration testing is your proactive defense against vulnerabilities attackers actively exploit. CIS Control 16.13 requires organizations to conduct authenticated testing on critical applications at least annually, moving beyond surface-level scans to simulate real-world attack scenarios. For SMBs, implementing this control systematically is essential to meeting CIS, SOC 2, and other compliance frameworks.
What this means
This control mandates conducting application penetration testing—simulated attacks that identify exploitable weaknesses in your software and web applications before malicious actors do. For critical applications, authenticated penetration testing (where the tester has valid credentials) is strongly preferred as it reveals vulnerabilities accessible to insider threats or compromised accounts. Testing must occur at minimum annually, though organizations should consider more frequent testing for high-risk applications or after significant code changes.
How to comply
- 1.Identify and inventory all critical applications that store, process, or transmit sensitive data
- 2.Define penetration testing scope, including authenticated and unauthenticated test scenarios
- 3.Engage qualified penetration testers (internal security team or third-party firm) with proven expertise in application security
- 4.Conduct annual penetration tests with documented findings and severity ratings
- 5.Prioritize remediation of identified vulnerabilities based on risk level and exploitability
- 6.Verify fixes through retesting before returning applications to production
- 7.Maintain detailed records of all testing activities, findings, and remediation efforts
- 8.Schedule additional ad-hoc testing after significant application updates or security incidents
Evidence auditors look for
- Annual penetration test reports signed by qualified testers with methodology and findings documented
- Scope documents defining which applications are in-scope and why they are classified as critical
- Vulnerability assessment reports showing authenticated and unauthenticated test results
- Remediation tracking logs linking discovered vulnerabilities to patches and code fixes
- Risk assessment matrices prioritizing vulnerabilities by CVSS score and business impact
- Retesting reports confirming that critical findings have been resolved
- Third-party penetration testing contracts or internal testing schedules with documented completion dates
- Management sign-offs on test results and remediation timelines
Frequently asked questions
When will FAQs be available?
The FAQ for this control is currently being prepared.
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