Threat and vulnerability management

For a CCO or GRC lead, “threat and vulnerability management” is one of the quickest ways an assessor can separate a mature security program from a checkbox program. The requirement is simple to say, but hard to prove: you must show that you identify threats and vulnerabilities, assess what matters, and mitigate what you find ¹. That proof has to hold across IT, cloud, endpoints, and any operational technology (OT) in scope, plus third-party provided systems where you still carry operational risk.

This page translates the threat and vulnerability management requirement into an execution plan you can hand to security operations, IT, and asset owners. It prioritizes operational decisions that drive audit outcomes: defining scope, achieving scan coverage, setting remediation expectations, handling exceptions cleanly, and producing evidence that shows the program actually runs. It also flags the most common failure mode in examinations: lots of scanner output, weak prioritization, inconsistent remediation, and no defensible risk acceptance trail.

Target keyword: threat and vulnerability management requirement.

Regulatory text

C2M2 requirement (C2M2-03): “Identify, assess, and mitigate threats and vulnerabilities.” ¹

Operator interpretation (what you must do)

To meet C2M2-03, you must be able to demonstrate all three parts as an ongoing capability (not a one-time project) ¹:

1. Identify: You systematically find relevant threats (for your sector and environment) and vulnerabilities (in your assets, configurations, and software supply chain).
2. Assess: You triage and prioritize based on business impact and exploitability in your context, not just raw scanner severity.
3. Mitigate: You remediate, patch, harden, or implement compensating controls, and you track completion or formally accept risk with documented approvals.

A practical test: if you cannot show how a specific vulnerability moved from detection to closure (or approved exception) with timestamps, ownership, and evidence, your program will read as ad hoc even if scanning exists.

Plain-English requirement meaning (for compliance owners)

This threat and vulnerability management requirement expects a repeatable process that reduces real exposure over time. Your goal is not “zero vulnerabilities.” Your goal is: known exposure, prioritized work, disciplined exceptions, and measurable reduction of risk for critical assets and services.

What auditors typically look for in practice:

• Clear scope and asset coverage (what’s scanned, how often, and why).
• A defined method for prioritization (including what overrides CVSS).
• Remediation tracking with accountable owners and due dates.
• Exception handling that is time-bound and risk-approved.
• Evidence that leadership receives and acts on reporting.

Who it applies to (entity + operational context)

Entity types indicated in the source: Critical infrastructure operators and energy sector organizations ¹.

Operational contexts where this requirement becomes non-negotiable:

• Enterprise IT: endpoints, servers, network devices, directory services, identity providers.
• Cloud and SaaS: misconfigurations, exposed services, identity posture, container images.
• OT / ICS (if applicable): patch constraints, vendor support windows, compensating controls (segmentation, allow-listing) when patching is not feasible.
• Third parties: managed service providers, hosted platforms, software suppliers, and contractors with network access. Even when a third party “owns” patching, you still need visibility and assurance artifacts.

Ownership is usually shared: Security runs detection and governance; IT/OT owns remediation; GRC owns policy, exceptions, metrics, and audit evidence.

What you actually need to do (step-by-step)

Use this as a fast operating model for the threat and vulnerability management requirement.

1) Set scope and minimum control expectations

• Define in-scope asset classes (endpoints, servers, network gear, cloud accounts, container registries, OT zones).
• Define coverage targets by class (for example: “all production servers” vs “best-effort labs”). Treat gaps as risks with owners.
• Establish control objectives aligned to C2M2-03: identify, assess, mitigate ¹.

Deliverable: a one-page “Threat & Vulnerability Management Standard” that states scope, roles, and what “done” means for each step.

2) Build a defensible asset inventory (or connect to one)

If you cannot enumerate assets, you cannot prove you identify vulnerabilities across the environment.

• Pull from CMDB, EDR, cloud inventory, network discovery, and OT asset tools.
• Assign each asset: owner, environment (prod/non-prod), criticality, exposure (internet-facing, privileged path, safety impact).

Deliverable: an asset register or reconciled inventory feed with ownership and criticality tags.

3) Stand up continuous monitoring (detection inputs)

C2M2 points to operating continuous monitoring as a recommended control ¹. “Continuous” can be met through a combination of scheduled scanning and real-time telemetry, as long as it is routine and repeatable.

Detection sources to operationalize:

• Authenticated vulnerability scanning for servers and network devices.
• Endpoint visibility (EDR) for missing patches and risky configurations.
• Cloud security posture findings (misconfigurations, exposed storage, permissive IAM).
• Threat intelligence feeds relevant to your sector (track exploitation trends to adjust prioritization).
• Secure configuration assessment (benchmarks, hardening drift).
• Third-party advisories for critical products in your stack.

Deliverable: a documented list of detection sources, scope coverage, and who reviews findings.

4) Triage and prioritize findings in your context

Raw severity alone is not an operating model. Implement a prioritization method that an auditor can understand and that engineers will follow.

Minimum prioritization fields:

• Asset criticality (business/operational impact).
• Exposure (internet-facing, reachable from user networks, accessible from third party connections).
• Exploitability signals (known exploitation, weaponized exploit, active attack campaigns).
• Control state (is there a compensating control already in place?).

Deliverable: a triage rubric and a weekly (or routine) triage meeting with named decision-makers.

5) Drive remediation with clear ownership and tracking

Operationalize a closed-loop workflow:

• Create remediation tickets from findings (or integrate scanner → ITSM).
• Assign ticket owner (system owner, app owner, OT engineer).
• Define expected remediation timelines by priority (your internal SLAs).
• Track status through closure with validation (rescan, config check, or attestation with evidence).

Deliverable: a centralized vulnerability register (or ITSM reporting) showing status, owner, and closure evidence.

6) Handle exceptions and compensating controls without breaking auditability

Exceptions are allowed in practice; unmanaged exceptions break the requirement. Your exception process should require:

• Business justification (why remediation cannot occur now).
• Risk assessment summary (impact, likelihood in your environment).
• Compensating controls (segmentation, WAF rule, virtual patching, monitoring).
• Approval by an accountable risk owner (not the implementer).
• Expiration and review cadence; closure criteria.

Deliverable: an exception log with approvals and end dates; mapped compensating control evidence.

7) Report metrics that show the program works

Build a monthly pack for leadership and an audit-ready dashboard:

• Coverage: assets scanned vs in scope.
• Backlog: open findings by priority and age.
• Remediation performance: closed vs opened trends.
• Exceptions: count, aging, and high-risk exceptions.
• Hot spots: top vulnerable products, recurring misconfigurations.

Deliverable: dated reports, meeting notes, and action items showing governance.

8) Extend the program to third parties (practical minimum)

For critical third parties:

• Contractual requirement to patch within defined timelines or provide compensating controls.
• Right to receive vulnerability attestations, relevant penetration test summaries, or vulnerability management policy excerpts.
• Incident coordination for exploited vulnerabilities affecting shared environments.

Deliverable: third-party assurance artifacts stored with the vendor record (policy, attestation, SOC report excerpts, or remediation communications).

Required evidence and artifacts to retain (audit-ready checklist)

Keep artifacts that prove each verb in C2M2-03 ¹:

Identify

• Asset inventory extracts (dated) and scope statement.
• Scanner configuration and scope reports (IPs/accounts covered).
• Cloud posture tool exports or findings summaries (dated).
• Threat intel subscription list and intake procedure.

Assess

• Triage rubric and documented prioritization criteria.
• Triage meeting notes, including decisions and escalations.
• Risk ranking outputs that show business criticality influences priority.

Mitigate

• Remediation tickets with timestamps, owners, and closure notes.
• Patch deployment records (change tickets, deployment logs).
• Validation evidence (rescan results, config compliance reports).
• Exception log with approvals, compensating controls, and expiration.

Governance

• Policy/standard and RACI.
• Monthly metrics pack and steering committee minutes.

Common exam/audit questions and hangups

Expect these questions, and prepare a one-page answer plus evidence pointers:

1. “Show me coverage.” What percentage of in-scope assets are scanned, and how do you know the inventory is complete?
2. “How do you prioritize?” How do you account for critical systems, internet exposure, and active exploitation?
3. “Prove remediation.” Pick a critical finding and walk it from detection to closure or exception.
4. “What happens when you can’t patch?” Show your exception workflow and compensating controls.
5. “How do third parties fit?” If a third party manages a platform, what assurance do you obtain and how do you track their remediation?

Hangup pattern: teams can produce scanner reports, but cannot produce closure proof and risk acceptance decisions tied to accountable owners.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Treating scanner output as “the program”	Identification exists, assessment/mitigation is weak	Build ticketing + governance loop; measure closure
No asset ownership	Findings sit unassigned	Enforce owner tags in inventory and ITSM routing
Prioritization equals CVSS only	Misses real-world exposure drivers	Add asset criticality + exposure + exploit signals
Exceptions granted informally (email/Slack)	No audit trail; no expiration	Use a standardized exception record with approvals and end date
OT environments handled as “can’t patch, so ignore”	Accumulates silent risk	Document compensating controls and monitoring; track exceptions

Enforcement context and risk implications

No public enforcement cases were provided in the available source catalog for this requirement. Treat the risk as operational and systemic: weak threat and vulnerability management increases the likelihood that known issues remain exploitable in production, and it undermines defensibility during incident response and stakeholder reporting. For critical infrastructure operators, the impact extends beyond confidentiality to availability and safety outcomes ¹.

Practical 30/60/90-day execution plan

First 30 days: stand up governance and visibility

• Name a program owner and publish a short standard mapped to C2M2-03 ¹.
• Define in-scope asset classes and establish an inventory baseline with owners.
• Turn on or validate core detection sources (vuln scanning, EDR posture, cloud posture).
• Create the vulnerability register view (even if it is a report) and start a recurring triage meeting.
• Draft an exception template and approval workflow.

Next 60 days: close the loop and prove mitigation

• Integrate findings to ticketing and enforce assignment to asset owners.
• Implement prioritization rubric and document decisions in triage notes.
• Start remediation validation via rescan or config checks.
• Produce the first monthly leadership metrics pack and track actions.
• Bring critical third parties into scope: request vulnerability management attestations and patch commitments.

Next 90 days: harden, scale, and make it audit-proof

• Expand coverage to remaining asset classes and reduce unknown inventory.
• Formalize remediation expectations (internal SLAs) and exception expirations.
• Run a tabletop on “critical exploited vulnerability in key product” to test coordination across Security, IT/OT, and Communications.
• Perform an internal control test: sample findings and verify evidence from detect → triage → ticket → closure/exception.
• If you use Daydream for GRC workflows, map this requirement to your control library, attach evidence to the control, and automate recurring evidence collection prompts tied to reporting cycles.

Frequently Asked Questions

What counts as “continuous” for the threat and vulnerability management requirement?

“Continuous” means routine and repeatable detection that feeds triage and remediation, not a one-time scan export ¹. If findings do not consistently generate tickets, closures, or exceptions, an auditor will treat the process as immature.

We can’t patch some OT systems. Can we still meet the requirement?

Yes, if you document the constraint, assess the risk, and implement compensating controls with formal approval and an expiration or review trigger ¹. Keep evidence of segmentation, monitoring, and vendor support communications.

How do we prioritize vulnerabilities beyond CVSS without making it subjective?

Use a rubric with a small set of consistent factors: asset criticality, exposure, exploitability signals, and existing compensating controls. Record triage decisions in meeting notes or ticket fields so the reasoning is testable.

What evidence is most persuasive in an audit?

A closed-loop sample. Pick a high-risk vulnerability and show the detection record, triage decision, ticket assignment, change/patch record, and rescan validation ¹.

How should third parties be handled if they manage the infrastructure?

Put patch and vulnerability notification expectations into contracts, then collect assurance artifacts such as vulnerability management policy excerpts, attestations, and remediation communications. Track these artifacts alongside your internal exception process when remediation is delayed.

Do we need a dedicated tool to comply?

A tool helps, but the requirement is about outcomes and evidence: identification, assessment, and mitigation with governance ¹. If you can produce consistent artifacts and reporting from existing tools and ITSM, you can meet the requirement.

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control management

Footnotes

1. DOE C2M2