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Clear out junk files and repair common Windows errorsFree Scan →Fix the driver behind crashes, sound loss and screen glitchesFind Drivers →Yes, a change process can govern a change that involved no source code. What decides it is the scope written into the governing policy and whether the change touches a system or configuration item that policy controls. Whether someone edited a code file is not the test.
Why “not code” does not settle the question
Many change processes were built around software releases, so the word “code” often shows up in their titles, templates, and approval queues. That history can make non-code changes look out of scope by default. Policies, however, are usually written around systems, services, and configuration items, and code is only one kind of item inside those boundaries.
Three things determine whether a particular change falls under a process:
- The policy’s scope statement. Look for the list of covered systems, services, artifacts, and environments, and for any explicit exclusions.
- The item being changed. A firewall rule, an access control list, a baseline configuration setting, a runbook, or a piece of documentation can each be a configuration item under some policies.
- The effect of the change. A non-code edit can alter security posture, availability, functionality, or how an operational procedure is carried out, and those effects are what a controlled process is designed to catch.
What counts as a non-code change
Non-code changes are modifications that do not involve creating or editing service source code. Published examples include:
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- Opening or closing network ports.
- Changing access control lists (ACLs) or other access settings.
- Changing configuration settings and baseline configurations on a system.
- Applying vulnerability remediation or security updates that are configuration-level rather than code-level.
- Installing or upgrading hardware, and changing firmware.
- Editing documentation that a policy names as a controlled artifact.
The Georgia Technology Authority’s operational change control policy is one example that explicitly names hardware, software, firmware, and documentation within its definition of change, and lists functionality changes, service interruptions, repairs and security updates, removals, maintenance, and hardware installations or upgrades among the changes it addresses. The IRS policy’s scope similarly names architectures, applications, software, tools, documentation, and associated configuration items. Neither is a template for every organization, but both show that a policy can reach well beyond source code.
How to decide whether a change is in scope
- Find the governing document. Start with the organization’s change management or configuration control policy, not the software release procedure. If a team has a deployment workflow and a separate organizational policy, both may apply, and the broader one usually sets the scope.
- Read the scope clause and the definitions. Check whether the policy defines “change,” “system,” “configuration item,” or “artifact,” and whether it excludes anything by category or environment.
- Identify the affected configuration items. List every system, setting, rule, document, or service the change touches, including indirect dependencies.
- Assess the impact. Ask whether the change could affect security, availability, functionality, or a documented procedure. If the answer is yes for any item, the change should be evaluated under the process even if no code moved.
- Classify the change under the applicable model. Many policies assign standard, normal, or emergency paths based on risk. The route follows from the classification, not from the file type.
- Record the decision. If the change is judged out of scope, note why. A short written rationale protects the team if the question comes up later.
What the published frameworks say
Microsoft 365
Microsoft states that it enforces change management procedures when both code and non-code changes to its systems are made, in order to maintain its security posture. For code, its controls include personnel review, automated security checks, and staged release. For non-code changes, it defines them as modifications that do not involve creating or editing service source code, and gives opening ports and changing ACLs as examples. Its non-code path includes documented implementation and validation steps, a rollback plan, peer review for accuracy and security impact, approval, implementation, and ticketed validation results. The page was last updated September 29, 2025. See the Microsoft 365 change management documentation. This describes one vendor’s controls, not a requirement for every organization.
NIST SP 800-171 Revision 3
NIST SP 800-171 Rev. 3 (May 2024) is written for nonfederal systems and organizations that handle Controlled Unclassified Information. Its requirement 03.04.03 asks organizations to define the types of system changes that are configuration-controlled, to review proposed changes with explicit consideration of security impact, and to implement, document, and monitor approved changes. Its discussion describes configuration change control as a systematic process of proposal, justification, implementation, testing, review, and disposition. Requirement 03.04.04 calls for a security impact analysis before implementation and verification afterward. The document states plainly: “Not all changes to the system are configuration controlled.” Read the NIST SP 800-171 Rev. 3 text in full before applying it to a specific environment.
IRS change management policy and process
The IRS change management policy in IRM 2.125.1 states at its scope section that “This policy shall apply to all changes that may impact IRS systems, infrastructure, and services.” It covers architectures, applications, software, tools, documentation, and associated configuration items across the service lifecycle. It requires proposed changes to be formally recorded, classified, assessed for impact, authorized, implemented under control, validated, and closed with updated records. The page gives an effective date of June 5, 2026. The companion process manual, IRM 2.125.2, is effective May 21, 2026, and describes execution for IRS IT services and configuration items.
Georgia Technology Authority
The Operational Change Control (SS-08-026) standard defines change to include modifications to hardware, software, firmware, and documentation. Its procedures call for a technical record, formal approval, an emergency process, impact assessment, pre-implementation testing, transition to production, and communication. The page shows an issue date of March 31, 2008 and a review date of December 1, 2024. Because the review date is not recent, confirm with the issuing agency that the text still reflects current practice before relying on it.
Comparing the four sources
| Source | Scope of non-code change | Controls named | Date shown |
|---|---|---|---|
| Microsoft 365 change management | Explicit: non-code changes such as opening ports and changing ACLs | Documented implementation and validation, rollback plan, peer review, approval, ticketed validation | Last updated September 29, 2025 |
| NIST SP 800-171 Rev. 3 | Organization defines which change types are configuration-controlled; not all changes are | Proposal, security impact analysis, review, implementation, documentation, monitoring | May 2024 |
| IRS IRM 2.125.1 | Explicit: documentation and associated configuration items, among others | Recording, classification, impact assessment, authorization, validation, record updates, closure | Effective June 5, 2026 |
| Georgia Technology Authority SS-08-026 | Explicit: hardware, software, firmware, and documentation | Technical record, formal approval, emergency process, impact assessment, testing, communication | Issued March 31, 2008; reviewed December 1, 2024 |
What a controlled non-code change usually requires
- A written record that identifies the change, the affected configuration items, and the requester.
- An impact assessment covering security, availability, and functionality before implementation.
- Review and authorization by someone outside the implementer, at a level set by the change’s classification.
- A documented implementation plan and a rollback or recovery plan.
- Validation after implementation, with the results attached to the record.
- Updates to the configuration baseline, documentation, or runbooks, followed by closure.
When a full change board is not required
Controlled change does not mean every non-code edit goes to a board. NIST’s statement that not all system changes are configuration-controlled means the organization must define the boundary itself. A low-risk documentation correction may be out of scope under one policy and in scope under another. The practical question is whether the change could alter a controlled item or its security or operational effect. If it could, the process applies at the level its classification assigns. If it clearly cannot, a documented scope decision is usually enough.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Common points where teams get this wrong
- The process is named for software. A release pipeline may be the only documented path, so the non-code change bypasses review. Check the policy scope, not the tool’s name.
- The change looks small. A single ACL or port change can expose a system. Assess effect rather than size.
- Configuration drift. Changes made directly on a system without a record can leave the recorded baseline wrong. Microsoft notes that configuration drift can create vulnerabilities, break functionality, or disrupt availability.
- Emergency fixes with no follow-up. An emergency path still needs a record and validation after the fact. Missing records are often the finding that matters most later.
- Documentation treated as outside scope. If a policy lists documentation or procedures as controlled artifacts, an edit to them can be a change in its own right.
The policies cited here are dated, and local rules may differ. Confirm the version in force for your organization before deciding how a specific change should be handled.
Frequently Asked Questions
Does a change management policy have to name non-code changes explicitly?
Not always. Some policies name hardware, firmware, documentation, or configuration items explicitly, while others leave scope to a general definition of system or configuration item. Where the text is silent, the decision rests on whether the affected item is one the organization has chosen to control, and that choice should be written down.
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Who decides whether a non-code change is in scope?
The owner of the governing policy, usually a change manager, configuration control board, or security function, decides. Individual engineers should document their reasoning and ask for a scope ruling when the boundary is unclear.
The Bottom Line
A change process covers non-code changes whenever the governing policy’s scope includes the affected system, service, or configuration item. Check the scope clause, identify what the change touches, and assess its effect. Record the decision either way.
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