3.6.2·critical·Component: Incident ResponseWhat this control requires
This control ensures that system security incidents are tracked, documented, and reported in a timely manner. It mandates reporting incidents to the organizational incident response team and relevant authorities within a specified time period. Additionally, it provides resources for system users to receive assistance in handling and reporting incidents, ensuring effective incident response and support. This control supports the Incident Monitoring and Reporting capability within the Incident Response (3.6) family.
In plain English
This control ensures that system security incidents are tracked, documented, and reported in a timely manner. In practice, this means you can prove you response management-level controls on a defined cadence.
Why it matters
DoD contractors and their subcontractors must implement all 100 SP 800-171 requirements to keep CUI handling contracts. Gaps are scored against the SPRS scoring methodology; below a 110-point starting score, each unmet requirement deducts points and a below-threshold score can disqualify a bid.
This control is rated critical in the source catalogue. Treat gaps here as production incidents in the risk register, not housekeeping.
What an auditor looks for
A C3PAO conducting a CMMC Level 2 assessment uses NIST SP 800-171A objectives. They expect a System Security Plan (SSP), Plan of Action & Milestones (POA&M) for any gaps, and objective evidence (configurations, ticket records, training records) for every requirement.
Within Incident Response, the assessor will trace your implementation back to the catalogue reference (Requirement 3.6.2) and look for objective evidence on the latest two assessment cycles.
How to implement
Incident Response
Runbook. Maintain a runbook keyed by incident type with named roles (IC, comms, scribe), an out-of-band comms channel, and a 72-hour timeline for external notification.
Tabletop. Run a quarterly tabletop exercise (ransomware, insider, supply-chain) and feed gaps back into the runbook.
Operational checklist
- Response. Document the trigger, the owner and the cadence.
- Time. Document the trigger, the owner and the cadence.
- System. Document the trigger, the owner and the cadence.
- Incident. Document the trigger, the owner and the cadence.
- Security. Document the trigger, the owner and the cadence.
- Scope: management, time, security, response.
Evidence to collect
- Ticketing Workflow.
ticketing_workflowevidence - Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.
Workflow metrics (ServiceNow, Jira) show approvals and remediation. Focus: Incident Monitoring, Reporting, and Response Assistance.
Common pitfalls
- Runbooks that name a role but no person, or list a paging channel that no longer exists.
How it maps to other frameworks
Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.
- NIST SP 800-53 Rev. 5 IR-5(1) — Automated Tracking, Data Collection, And Analysis
- SOC 2 (2017 TSC) CC7.4 — Incident Response
- ISO/IEC 27001:2022 A.5.27 — Learning from information security incidents
- CIS Controls v8 17.6 — Define Mechanisms for Communicating During Incident Response
- BSI C5:2020 SIM-03 — Documentation and reporting of security incidents
Related controls in NIST SP 800-171 Rev. 3
- Requirement 3.6.4 — Incident Response Training
- Requirement 3.14.1 — Flaw Remediation
- Requirement 3.3.6 — Audit Record Reduction and Report Generation
- Requirement 3.2.1 — Literacy Training and Awareness
- Requirement 3.6.5 — Incident Response Plan
- Requirement 3.6.1 — Incident Handling
References
- NIST Computer Security Resource Center — NIST SP 800-171 Rev. 3
- Catalogue identifier:
Requirement 3.6.2
Topics: incident responsechange managementcontinuous monitoring