Cybersecurity workforce capability development

The cybersecurity workforce capability development requirement means you must define the cybersecurity competencies your organization needs, assess current staff against them, close gaps through training and staffing actions, and keep evidence that the program sustains your cybersecurity maturity goals ¹. Operationalize it by mapping roles to competencies, tracking completion and proficiency, and proving readiness through repeatable reporting.

Key takeaways:

• Define role-based cybersecurity competencies tied to your maturity targets, then measure people against them ¹.
• Run capability development as an operating process: assess, plan, train/hire, validate, and re-assess ¹.
• Keep audit-ready artifacts: role/competency matrix, training records, readiness metrics, and management review outputs.

“Cybersecurity workforce capability development” is easy to agree with and hard to prove. C2M2’s requirement is short, but auditors and internal stakeholders will expect you to show a repeatable system that produces competent coverage of critical security work, not a one-time training campaign ¹. For a Compliance Officer, CCO, or GRC lead, the practical goal is to convert this into a small set of controls you can test: defined expectations (competencies), measured attainment (assessments and completion), and sustained performance (readiness tracking and management review).

This page gives you requirement-level implementation guidance for the cybersecurity workforce capability development requirement, anchored to the DOE Cybersecurity Capability Maturity Model (C2M2) ¹. It focuses on what you need to stand up quickly: a role-to-competency model, a training and staffing plan tied to risk, and a documentation package that survives scrutiny. If you already run HR learning programs, this requirement is about connecting them to cybersecurity outcomes, evidence, and accountability.

Regulatory text

C2M2 requirement (C2M2-08): “Develop workforce competencies needed to sustain cybersecurity maturity goals.” ¹

Operator meaning: You need a defined set of cybersecurity competencies (knowledge/skills/abilities) for the roles that deliver your security program, plus a living process to build and maintain those competencies over time so your target maturity doesn’t decay from turnover, tool changes, new threats, or new regulatory obligations ¹.

Plain-English interpretation (what the requirement really asks for)

A compliant program answers four questions with evidence:

1. What competencies do we require? Role-based expectations for cybersecurity work (SOC, IAM, vulnerability management, incident response, OT security, GRC, engineering).
2. Who is accountable for meeting them? Named role owners and managers.
3. Are people meeting them today? Measured via training completion, skill validation, and operational readiness signals.
4. What do we do when they are not? A documented improvement plan (training, mentoring, hiring, third-party support) and follow-up checks.

Your program must be sustainable. A spreadsheet created for an audit, without ongoing updates and management action, will fail the “sustain maturity goals” test ¹.

Who it applies to (entity and operational context)

Entities: C2M2 is commonly used by critical infrastructure operators and energy sector organizations ¹. In practice, any organization adopting C2M2 as an internal standard, regulator expectation, customer requirement, or board-level maturity goal should treat this as in-scope.

Operational context (what gets pulled into scope):

• Cybersecurity functions performed by employees, contractors, and other third parties who operate or defend your environments. If a managed security service provider performs monitoring, their staff capability becomes part of your capability story through contracting, due diligence, and performance evidence.
• IT and OT environments if applicable to your operations. If OT security activities exist, include OT-specific competencies (for example, safe change control and incident handling constraints).
• Business-critical systems and identity planes (directory services, privileged access workflows, cloud control planes) where mistakes have outsized impact.

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

Step 1: Define your cybersecurity maturity goals and translate them into “critical work”

Deliverable: a short statement of maturity goals and the security outcomes they require ¹.

Practical approach:

• Pull your current cybersecurity strategy, risk register, and top control objectives.
• Identify “critical work” that must be performed consistently (patch governance, alert triage, incident command, access reviews, backup recovery testing, secure configuration management).
• Assign each workstream a primary owner and backup.

Step 2: Build a role-to-competency matrix (minimum viable version first)

Deliverable: a matrix mapping cybersecurity roles to required competencies and proficiency levels.

Minimum viable fields:

• Role name (by function, not job title)
• Required competencies (bullet list)
• Proficiency expectation (use a simple scale such as baseline / working / advanced)
• Evidence method (training completion, lab validation, manager sign-off, certification, tabletop participation)

Keep it pragmatic. If you boil the ocean, you will never get adoption.

Step 3: Baseline current capability (skills inventory + gap assessment)

Deliverable: a dated snapshot of current workforce capability against the matrix.

Data sources you can use:

• HR/LMS completion records (security, privacy, secure coding, incident response)
• Access and responsibility mapping (who has admin rights, who is on-call, who can approve changes)
• Self-assessments with manager validation for high-impact roles
• Operational metrics that indicate proficiency (for example, ability to execute runbooks, quality of incident documentation)

Treat this as a control: documented method, recorded results, and sign-off.

Step 4: Create a capability development plan that closes gaps

Deliverable: a plan with actions, owners, and due dates.

Your plan should include:

• Training plan by role (what, who, by when)
• Staffing plan (hire, backfill, succession, cross-training)
• Third-party coverage plan where internal capability is not realistic (with oversight)
• Time allocation expectations agreed with leadership so training is not “extra credit”

A common pattern is to prioritize gaps that affect incident response, privileged access, and vulnerability remediation first because those are frequently tested operationally.

Step 5: Execute and track completion + proficiency (not just attendance)

Deliverable: a tracking mechanism showing progress and outcomes.

Track at least:

• Training assigned vs. completed by role
• Skill validation outcomes for key roles (tabletop participation, technical exercises, runbook walk-throughs)
• On-call readiness (coverage, rotations, escalations)
• Critical role coverage (primary/backup identified)

This aligns directly with the recommended control: track role competencies, training completion, and staffing readiness ¹.

Step 6: Prove sustainment through management review and refresh cycles

Deliverable: recurring management review notes and updated matrices/plans.

A sustainment process should trigger updates when:

• tooling changes (new SIEM, EDR, cloud platform)
• threat profile changes
• audit findings identify performance gaps
• turnover occurs in critical roles
• new systems come online

If you need a system of record, Daydream can act as the evidence hub by linking role expectations, training attestations, and staffing readiness into a single control narrative that an auditor can follow without guesswork.

Required evidence and artifacts to retain

Keep artifacts in an audit-ready package organized by role and time period:

1. Cybersecurity role catalog (in-scope roles, owners, backups)
2. Role-to-competency matrix with version history
3. Skills baseline and gap assessment results (dated, with approver)
4. Capability development plan (training + staffing actions, owners, due dates)
5. Training records (LMS exports, attendance logs, completion certificates)
6. Proficiency validation evidence (tabletop agendas and attendance, exercise outcomes, lab validation results, manager sign-offs)
7. Staffing readiness evidence (on-call schedules, coverage mapping, hiring requisitions tied to gaps, contractor SOWs for skill coverage)
8. Management review outputs (meeting notes, action items, status reports)

Audit reality: the strongest evidence connects competency gaps to concrete remediation actions and shows follow-through.

Common exam/audit questions and hangups (what reviewers ask)

Expect questions like:

• “Show me how you determine required cybersecurity competencies for each role.” ¹
• “How do you know the SOC/on-call team can execute incident response tasks?” ¹
• “Is training mapped to role requirements, or is it generic?” ¹
• “How do you handle turnover and ensure continuity?” ¹
• “Where is the proof that this is sustained over time?” ¹

Hangups that slow exams:

• No consistent definition of “competency” (training-only vs. demonstrated ability)
• Training completion exists, but no mapping to critical roles
• Heavy reliance on a third party without oversight evidence (SLAs, reporting, validation of staff capability)

Frequent implementation mistakes and how to avoid them

Mistake 1: Treating annual security awareness training as “workforce capability development.”
Avoid it: awareness is necessary, but C2M2 expects role-based competencies tied to maturity goals ¹.

Mistake 2: Building a perfect framework that no one maintains.
Avoid it: start with critical roles and expand. Add governance: ownership, review cadence, and a change trigger list.

Mistake 3: Measuring activity, not capability.
Avoid it: require some validation for high-risk roles (incident commanders, privileged access administrators, OT security engineers). Use tabletop exercises or runbook walk-throughs and keep the evidence.

Mistake 4: Ignoring contractors and managed service providers.
Avoid it: include them in the role/competency model through contract requirements, onboarding, and performance reporting.

Mistake 5: No linkage to risk and maturity goals.
Avoid it: explicitly map competencies to the “critical work” that sustains your target maturity outcomes ¹.

Enforcement context and risk implications

No public enforcement cases are provided in the supplied source catalog for this specific C2M2 requirement. Treat the risk as assurance and operational failure risk: if you cannot show how you build and maintain cybersecurity competency, you may fail customer assurance reviews, regulator examinations that reference maturity expectations, and internal audits. Operationally, weak capability development shows up as missed alerts, inconsistent patching, fragile incident response, and over-reliance on a few individuals.

Practical 30/60/90-day execution plan

Days 1–30: Establish the minimum viable program

• Name an executive sponsor and an operational owner (CISO, Head of Security Ops, or GRC).
• Define in-scope cybersecurity roles and identify primary/backup for each critical function.
• Draft the first version of the role-to-competency matrix for critical roles only.
• Pull training and staffing data to create a baseline capability snapshot.
• Open gaps as tracked actions (owner, due date, remediation type).

Days 31–60: Close high-risk gaps and add proficiency validation

• Assign role-based training plans and start completion tracking.
• Implement at least one proficiency validation mechanism for key roles (for example, incident response tabletop and runbook walk-through).
• Formalize third-party coverage expectations where internal skills are missing (SOW language, reporting expectations, escalation paths).
• Produce a monthly readiness report: role coverage, open gaps, completion status.

Days 61–90: Operationalize sustainment and evidence quality

• Run a management review focused on gaps, staffing readiness, and maturity impact ¹.
• Expand the matrix to additional roles (engineering, IAM, vulnerability management, OT as applicable).
• Add change triggers and ownership for updates (tool changes, turnover, audit findings).
• Package evidence in an auditor-friendly structure with versioning and sign-offs. If you use Daydream, link each competency area to artifacts and test results so you can answer audits with one traceable control record.

Frequently Asked Questions

Does this requirement mean we need certifications for every cybersecurity role?

No. C2M2 requires you to develop and sustain competencies, not to mandate specific certifications ¹. Certifications can be one evidence type, but you can also use training completion, exercises, and manager-validated skill checks.

How do we handle cybersecurity capability development for a managed security service provider?

Treat the provider as part of your capability coverage and require evidence through contracting: role expectations, training requirements where appropriate, performance reporting, and incident response participation. Keep artifacts that show you oversee the third party’s readiness, not just their invoices.

What’s the minimum evidence an auditor will accept?

A defensible minimum set is a role/competency matrix, a baseline gap assessment, a development plan, and tracked completion and readiness reporting ¹. Add validation evidence for high-impact roles to avoid “checkbox training” pushback.

How do we define “competency” without creating an HR science project?

Use a small set of observable capabilities tied to critical work, such as “can execute the incident triage runbook” or “can perform privileged access reviews correctly.” Keep proficiency levels simple and document how you validate them.

Our team is small; can one person cover multiple roles?

Yes, but document coverage explicitly and plan for continuity risk. Auditors will focus on single points of failure for on-call response, privileged access administration, and key security operations tasks.

How often should we re-assess competencies?

Re-assess on clear triggers (turnover, tool changes, major incidents, audit findings) and on a recurring internal schedule you can sustain. The key is consistency and evidence that reassessment drives action ¹.

Related compliance topics

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• Access and identity controls
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• Access control lifecycle management

Footnotes

1. DOE C2M2