Maintaining information security and privacy is a primary role for IT security professionals, compliance officers and risk managers in government agencies and non-government organizations. Unfortunately, there’s no one cure-all solution for cybersecurity concerns you can leverage to keep an organization’s IT system 100% immune to threats. That’s why implementing a risk management framework to help you sequentially identify and mitigate different data risks and create an incident response plan is so important.
And this is where the NIST Risk Management Framework (RMF) comes in. This framework has become the go-to solution for organizations worldwide as they seek effective measures of preventing data breaches, which exposed 422 million records globally in the third quarter or 2024 alone. Before we explain this framework and its overwhelming significance to IT systems, let’s first define what is NIST RMF and its history.
What is the NIST Risk Management Framework?
The NIST RMF was established under the Federal Information Security Modernization Act of 2014 (FISMA), which established a joint task force that included the National Institute of Standards and Technology (NIST). NIST was assigned the responsibility of creating a risk management and incident guideline framework to govern federal information processing standards and those agencies handling federal data and federal information systems.
NIST developed a seven-step Risk Management Framework, known as the NIST RMF. This establishes a comprehensive standard containing over 1,000 security controls that organizations can leverage to assess and manage cybersecurity risks to maintain data security and privacy.
The NIST RMF is primarily for federal agencies, entities/vendors handling government data and all government contractors. It helps these parties ensure their information systems comply with Federal Information Security Management Act (FISMA) requirements by guiding them to integrate cybersecurity risk management processes during the initial stages of a system’s lifecycle.
This framework has two main standards — NIST 800-53 Risk Management Framework and NIST Risk Management Framework 800-37. NIST 800-53 focuses mainly on security and privacy controls and implementation standards, while NIST 800-37 concentrates on providing implementation guidelines for developing a risk management program.
Non-Compliance Risks Under FISMA and NIST RMF
For federal agencies, contractors and vendors handling government data, FISMA compliance and adherence to the NIST Risk Management Framework (NIST RMF) are not optional, but are instead legal requirements. Failing to meet these cybersecurity and risk management standards can expose organizations to severe operational, financial and reputational consequences, including:
- Contract termination and debarment: Non-compliance with NIST RMF or FISMA can lead to canceled government contracts and disqualification from bidding on future federal projects.
- Loss of federal funding: Agencies and contractors that fail to meet NIST RMF requirements risk losing access to federal grants or funding tied to information security performance.
- Excessive audit and oversight: The government may impose harsher regulatory oversights on non-compliant organizations and impede their turnaround time on project deliverables.
- Legal and regulatory liability: In the event of a data breach or security incident, non-compliant organizations may face lawsuits, civil penalties or enforcement actions under federal data protection laws.
- Higher remediation costs: Recovering from a cybersecurity breach is often far more expensive than proactively implementing NIST Risk Management Framework controls. Costs may include system restoration, third-party audits and compliance re-certification.
- Reputational damage: Data breaches tied to non-compliance can severely erode public trust. Agencies and contractors viewed as unreliable in protecting sensitive federal information may struggle to rebuild credibility with partners and stakeholders.
By maintaining continuous alignment with the NIST Risk Management Framework, organizations not only ensure FISMA compliance but also strengthen cybersecurity resilience and protect their eligibility for future federal contracts.
Private-Sector Adoption of NIST Risk Management Frameworks
The NIST RMF is a vital guideline primarily developed for federal agencies, government contractors, and entities managing government data, but it is also widely adopted by private organizations to safeguard sensitive information, meet compliance requirements such as FISMA, and proactively mitigate cybersecurity threats by integrating risk-based security, privacy and cyber supply chain risk management processes throughout the system development life cycle.
Having discussed what the NIST RMF is and its history, let’s now outline the main components and step-by-step process of implementing this framework, which is primarily defined by NIST Special Publication 800-37 and closely linked to NIST Special Publication 800-53.
Five Key Components of the NIST Risk Management Framework (RMF)
One reason the NIST Risk Management Framework (RMF) is so widely adopted is its structured, adaptable design. The framework is divided into key components that build upon each other to create a continuous and repeatable cybersecurity risk management process. Each phase helps organizations identify, assess, mitigate and govern risks to protect their data and systems effectively.
Risk Identification
The first component of the NIST RMF involves identifying the assets, operations, and data that are essential to an organization’s mission, and pinpointing the potential threats that could compromise them. Risks may stem from various areas, including technology, compliance, operations or human error.
Establishing current risks to existing digital assets and information system processes shapes an organization’s perspective toward risk management. Risk identification and threat-hunting should be continuous because risks evolve with time as organizations grow.
Risk Measurement and Assessment
Once key risks are identified, the next step is to evaluate their potential impact. This includes determining the likelihood of each threat and the severity of its consequences. This component establishes the foundation for implementing the NIST Risk Management Framework, helping teams prioritize cybersecurity investments and mitigation strategies based on risk magnitude. The goal is to focus resources on high-impact risks that could significantly disrupt business continuity, data security or compliance obligations.
Risk Mitigation
During risk mitigation, organizations take action to prevent, reduce or control the risks identified and assessed earlier. The NIST RMF outlines four main approaches to risk mitigation:
- Risk avoidance: By following the NIST Risk Management Framework (RMF), you avoid the risk by skipping the actions that trigger it. For instance, you can choose to skip a new system launch or update if there’s a malware risk.
- Risk transfer: You shift the risk to a third party through a formal, legally binding agreement. For instance, before launching a new system, engage a software compliance company to perform an audit to certify the system. Such engagements transfer some risks to the audit company.
- Risk acceptance: Acknowledge that the risk exists but determine it is tolerable under the NIST Risk Management Framework, given its limited potential impact or the high cost required to mitigate it.
- Risk control: You come up with mitigation strategies and recovery plans to control the risk and its associated losses. For instance, if there’s a malware risk because of a system update, you should invest in an effective antivirus software that scans and fixes potential malware before it spreads to your system.
Risk Reporting and Monitoring
The NIST RMF requires you to report risk profiles and control strategies to relevant stakeholders who would be affected in case of a breach. You must also continually monitor risks to identify and report new outliers that need further mitigation actions.
Risk Governance
The final component of the NIST Risk Management Framework ascertains that risk management strategies are well-implemented and integrated into an organization’s information system throughout its lifecycle. It also focuses on enhancing systems by implementing the improvements learned from successful mitigation strategies in the past.
Risk governance ensures accountability, enforces compliance and promotes continuous improvement by integrating lessons learned from previous assessments and mitigation activities. It connects every stage of the NIST RMF process, ensuring consistent alignment between business goals, regulatory obligations and security objectives.
Seven-Step Process of the NIST Risk Management Framework (RMF)
Most organizations follow these seven steps of the NIST Risk Management Framework to achieve the optimal results that this framework is designed to deliver. Let’s explore each step and the key tasks that happen in each:
1. Prepare
The main goal of this NIST RMF step is to prepare your organization’s system for the implementation of security and privacy risk strategies. All activities of this step are designed to lay a strong foundation for the execution and continuous monitoring of your designated risk-management strategies. The core tasks you perform are:
- Evaluating your organization’s risk magnitude and tolerance
- Crafting an official risk management strategy that includes risk control and continuous monitoring techniques
- Defining critical risk management roles and delegating responsibility to specific teams
2. Categorize
The primary aim here is to segment an organization’s system according to the impact level the segment would experience if the information processed, stored and transmitted by the system got breached. You conduct this impact analysis by following the CIA triad that summarizes the three pillars of information security—confidentiality, integrity and availability (CIA).
The core tasks include:
- Cataloguing the characteristics of the system
- Classifying the system based on security impact level (i.e., low, moderate or high)
- Authorizing officials assess and green-lighting your categorizations
3. Select
The goal here is to select the most appropriate risk controls and tailor them to each system categorization as part of the NIST RMF process. The key tasks involved in this step include:
- Referencing NIST SP 800-53 to identify and choose baseline controls
- Creating an in-house control selection process if you don’t use NIST SP 800-53
- Customizing chosen controls according to specific factors, such as risk tolerance, system threats and security and privacy threat levels
- Categorizing risk controls as common, hybrid or system-specific
- Harmonizing security and privacy plans with their matching system elements
- Creating a continuous system-monitoring strategy
4. Implement
This is where the rubber meets the road in the NIST Risk Management Framework (RMF). You apply the selected security and privacy plans according to their designated process. In addition to executing your risk controls, this step involves documenting the implementation, updating controls as needed and recording the inputs and expected outcomes throughout the process.
5. Assess
You monitor the performance of the NIST security controls you’ve rolled out to gauge if you implemented them correctly and whether the results are up to par. The main tasks in this step are:
- Allocating the assessment process to a dedicated team with the expertise and capacity to conduct a bias-free appraisal
- Developing a comprehensive assessment plan
- Documenting assessment outcomes, observations, potential improvement areas and lessons learned
- Preparing a plan of action and milestones (POA&M) to correct any deficiencies observed
6. Authorize
Seek authorization to operate (ATO) once you’ve established that your risk mitigation plan is acceptable to all stakeholders. The core tasks in this step include:
- Preparing the appropriate documents needed for ATO approval (they include system security and privacy plan, POA&M, executive summary and assessment reports)
- Completing risk determination
- Denying or approving authorization
- Informing relevant officials and stakeholders of the authorization decision
7. Monitor
The main goal is to establish a monitoring strategy to continually appraise your information system to ensure it’s operating efficiently and scan new risks that may curtail the system’s performance. Key duties in this last step include:
- Monitoring and reporting the system’s performance
- Determining that risk levels and mitigation plans remain acceptable
- Updating pertinent documentation after each security assessment
NIST RMF Implementation Best Practices
The most effective NIST Risk Management Framework application strategy should be spot-on and customized to your organization’s risk categorizations. However, selecting the ideal risk management strategies is only the first step. Implementing them correctly is just as important. Follow these best practices to get it right.
Integrate the Risk Management Framework (RMF) Process Early and Keep Improving
Begin integrating the NIST Risk Management Framework (RMF) during the initial phases of the system development lifecycle and continue optimizing throughout the system’s lifecycle. Early integration is cost-effective and provides ample time to conduct risk assessments and make necessary adjustments along the way.
Seek Stakeholder and Management Buy-In
This mostly applies to organizations that aren’t required to follow FISMA law. In such entities, your NIST risk management framework implementation plans may face resistance from teams or individuals who downplay RMF effectiveness or dismiss it as only applicable to federal agencies. Selling the need for RMF implementation to such groups cultivates goodwill and makes the implementation process much smoother.
Document Each Step To Create a Chronological Audit Trail
Recording and archiving your RMF integration steps gives you a data-filled audit trail you can reference for future implementations. It also creates a source point for error correction and redundancy checks, which makes system assessments much easier.
Invest in Staff Reskilling and Upskilling
NIST RMF implementation is a team effort, given the many dependent components and steps. Staff in different departments have designated RMF roles to play, and they require expertise to fulfill the roles effectively. Training staff expedites RMF implementation and reduces errors.
Embrace Automation
Smart RMF automation solutions ease controls selection as they automatically filter through the over 1,000 controls designed by NIST. Smart systems also test the effectiveness of these controls and identify potential system vulnerabilities even when they’re subtly embedded in your system.
NIST RMF: The Parent of Risk Management and Incident Response
The efficiency of NIST RMF makes it a trusted risk assessment and management framework utilized by companies globally. While we’ve discussed RMF’s constituents and the implementation steps in detail, you’ll need expert assistance at some point to establish and implement risk strategies the right way. You’ll need professional knowledge of data analysis and application to run a successful campaign.
Fortunately, you can count on Onspring to implement NIST RMF and other necessary standards like the NIST Cybersecurity Framework. Contact us today, and let us be your resourceful RMF automation partner.
