Safeguard 16.2: Establish and Maintain a Process to Accept and Address Software Vulnerabilities

Safeguard 16.2 requires you to run a repeatable intake-and-response process for software vulnerabilities, so your organization can receive vulnerability reports, validate them, prioritize fixes, and track remediation to closure. To operationalize it quickly, stand up a single intake channel, define triage SLAs and ownership, and retain end-to-end evidence of each report’s handling. ¹

Key takeaways:

• You need an always-on way to accept vulnerability reports and a documented workflow to triage, remediate, and close them. ¹
• Auditors will look for proof of operation: tickets, timestamps, decisions, and closure evidence, not just a policy. ¹
• The fastest path is to integrate intake into your existing ticketing, change management, and patch processes, then add the missing governance and evidence capture. ¹

The safeguard 16.2: establish and maintain a process to accept and address software vulnerabilities requirement is about operational readiness, not documentation for its own sake. You are expected to have a working mechanism that lets internal teams, third parties, and security researchers report software vulnerabilities to you, and you must be able to prove what happened next. ¹

For most compliance leaders, the gap is not scanning; it is intake, triage discipline, and consistent closure evidence. Vulnerabilities arrive from many sources: internal testing, external researchers, bug bounty programs, third-party suppliers, penetration tests, customer reports, and automated tooling. If those signals do not flow into one governed process, issues get lost, fixes become ad hoc, and you cannot show control operation during an exam. ¹

This page translates Safeguard 16.2 into an operator checklist: who owns intake, what “address” means in practice, how to prioritize without creating bottlenecks, and what artifacts you retain so an auditor can trace a sample from report to remediation. It also flags the common hangups: scope confusion (product vs enterprise IT), inconsistent SLAs, and weak exception handling. ¹

Regulatory text

Framework requirement (excerpt): “CIS Controls v8 safeguard 16.2 implementation expectation (Establish and Maintain a Process to Accept and Address Software Vulnerabilities).” ¹

What the operator must do:
You must maintain a defined, repeatable process that (1) accepts vulnerability reports for software you develop, distribute, or run, and (2) drives those reports through validation, prioritization, remediation, and closure with documented outcomes. “Maintain” implies the process is active, owned, and used in day-to-day operations, not a shelf document. ¹

Plain-English interpretation

If someone tells you, “your software has a security flaw,” you need a predictable way to:

• Receive the report (without it getting buried in an inbox).
• Confirm whether it is real and what it affects.
• Decide what to do (fix, mitigate, accept risk, or reject with rationale).
• Track the work through engineering or IT change processes.
• Close the loop with evidence (what changed, when, and who approved). ¹

This safeguard is equally about responsiveness (issues move) and governance (decisions are recorded and defensible). ¹

Who it applies to (entity and operational context)

Safeguard 16.2 applies broadly to enterprises and technology organizations using CIS Controls v8 as a security baseline. ¹

Operationally, scope it to:

• Internally developed software (apps, APIs, scripts, infrastructure-as-code).
• Deployed software you operate (COTS and open source in production).
• Customer-facing products if you publish or distribute software.
• Third-party components where you must route upstream disclosures into your internal response workflow (including coordinated disclosure with vendors/maintainers). ¹

A common scoping failure is treating this as “the patch team’s job” and excluding product engineering. If you ship code, product security and engineering ownership must be explicit. ¹

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

1) Name the process owner and RACI

Set a clear control owner (often Product Security, Security Operations, or Vulnerability Management) and define who:

• Receives reports
• Performs initial triage
• Assigns engineering owners
• Approves risk acceptance
• Communicates externally when needed (legal/comms) ¹

Practical rule: one accountable owner, many contributors.

2) Stand up an intake mechanism (single front door)

Implement at least one sanctioned intake channel that is monitored and survivable through staffing changes:

• A dedicated email alias routed into a case system
• A web form that creates a ticket
• A bug bounty / coordinated disclosure mailbox integrated to ticketing ¹

Document what is in scope for reporting (systems, products, environments) and what information you need (affected version, reproduction steps, proof of concept, logs). ¹

3) Define triage steps and decision outcomes

Write a short triage playbook that produces consistent outcomes:

• Validate: confirm reproducibility and impact.
• Classify: affected assets, exposure, and exploitability.
• Prioritize: align to your risk method (severity + business context).
• Decide one of: remediate, mitigate, accept risk (with approval), or reject (false positive / out of scope). ¹

Decision control point: risk acceptance must be an explicit workflow step with an approver and expiry/review condition.

4) Route remediation into normal delivery and change controls

Your intake process should not invent a parallel engineering system. Instead:

• Create/associate work items in your SDLC tool (engineering backlog).
• Tie production changes to change management records where applicable.
• For third-party software, route into patch management or vendor escalation workflows. ¹

Make “closure” depend on objective evidence (merged PR, deployed version, patch applied, compensating control implemented). ¹

5) Close the loop and retain a complete audit trail

For each report/case, capture:

• Intake timestamp and source
• Triage notes and validation results
• Severity/prioritization rationale
• Assignment and due dates (if you set them)
• Remediation evidence and deployment reference
• Exception/risk acceptance approvals
• Closure date and closure reason (fixed/mitigated/accepted/rejected) ¹

If you accept reports from outside the company, define what communications are permitted and how you handle sensitive information. ¹

6) Run the process on a cadence (quality control)

Operate basic governance:

• Periodic review of open items and stale cases
• Trend review (recurring weakness classes, repeated affected components)
• Process tuning (intake quality, handoff friction, recurring exceptions) ¹

Where Daydream fits: if your team struggles to prove operation, Daydream can map Safeguard 16.2 to your ticketing workflow and automate recurring evidence capture (for example, pulling case lists, timestamps, approvals, and closure artifacts into an audit-ready package). ¹

Required evidence and artifacts to retain

Auditors commonly sample “a few vulnerabilities” and ask you to show end-to-end handling. Retain:

• Vulnerability intake procedure (1–3 pages) and ownership/RACI ¹
• Central log/case system export (open/closed cases) ¹
• Example case packets: report, triage notes, priority decision, assignment, remediation proof, closure note ¹
• Risk acceptance records, including approver identity and review conditions ¹
• Evidence of monitoring of intake channel (queue views, on-call rotation, mailbox to ticket automation evidence) ¹
• Metrics dashboard screenshots are helpful, but do not replace case-level evidence. ¹

Common exam/audit questions and hangups

Expect these lines of questioning:

• “Show me where a vulnerability report comes in, and who sees it.” ¹
• “How do you decide priority, and who can accept risk?” ¹
• “Prove remediation happened in production (or prove mitigation).” ¹
• “How do you prevent lost reports during vacations and turnover?” ¹
• “What is in scope: internal apps, customer product, open source components?” ¹

Hangups that stall audits:

• Vulnerabilities tracked in multiple places with no system of record.
• “Fixed” status without deployment evidence.
• Risk acceptance via chat or email with no durable record. ¹

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Intake scattered across inboxes and DMs	Reports get lost; no audit trail	Create a single intake route that always generates a case record. 1
No defined “reject” and “out of scope” handling	Teams waste time; reporters get no answer	Add standard dispositions with required rationale fields. 1
Risk acceptance is informal	Hard to defend decisions; exceptions never revisited	Require approval in the case system and add a review trigger. 1
Closure without proof	“We fixed it” cannot be validated	Make closure dependent on objective remediation evidence. 1
Product vulnerabilities treated like IT patching	Ownership confusion; slow remediation	Define separate routing paths for product engineering vs enterprise IT. 1

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite enforcement examples.

Risk-wise, Safeguard 16.2 reduces the chance that a known vulnerability remains untracked, unprioritized, or unaddressed. From a GRC standpoint, the biggest exposure is evidentiary: you may be doing work, but cannot prove a controlled process under exam conditions. ¹

Practical 30/60/90-day execution plan

First 30 days (stand up the minimum viable process)

• Assign a control owner and publish RACI for intake, triage, remediation, and risk acceptance. ¹
• Create a single intake channel and ensure it creates a case/ticket automatically. ¹
• Define case fields and required dispositions (fixed/mitigated/accepted/rejected). ¹
• Draft a one-page triage playbook and approval rule for risk acceptance. ¹

Next 60 days (integrate and make it auditable)

• Integrate with SDLC tooling and patch/change processes so tickets cannot close without remediation evidence. ¹
• Run a table-top on two realistic scenarios: product vuln disclosure and third-party component issue. ¹
• Start recurring reporting for open cases and overdue items (even if “overdue” is based on internal targets). ¹
• Configure Daydream (or your GRC system) to capture recurring evidence: case exports, sample packets, and approval logs. ¹

Next 90 days (operational maturity)

• Add quality checks: random case sampling for completeness, consistent severity rationale, and closure proof. ¹
• Formalize third-party coordination steps (upstream vendor notifications, tracking vendor patches, customer advisories where appropriate). ¹
• Use trend reviews to drive preventive work (coding standards, dependency management, secure configuration baselines). ¹

Frequently Asked Questions

Does Safeguard 16.2 mean we need a public vulnerability disclosure program?

CIS 16.2 requires a process to accept and address vulnerabilities, but the framework excerpt provided here does not mandate public-facing program elements. You can meet the intent with an internal process, though many organizations choose a public intake method for external reporters. ¹

What systems should be in scope: enterprise IT, product code, or both?

Scope should include any software you develop or run where vulnerabilities can create risk to the organization. In practice, define routing for both enterprise IT vulnerabilities and product/software engineering vulnerabilities so cases do not bounce between teams. ¹

How do we handle vulnerabilities in third-party software we do not control?

Track them in your process as cases with clear dispositions: patch/upgrade, mitigate, or accept risk with approval. If remediation depends on a third party, document escalation and track compensating controls until an update is available. ¹

What evidence is strongest in an audit for “addressed”?

Case-level traceability is strongest: intake record, triage notes, severity rationale, assignment, remediation proof (deployment/patch reference), and a closure note tied to approvals. A policy alone rarely satisfies testing of operating effectiveness. ¹

We already have vulnerability scanning. Why isn’t that enough?

Scanning finds issues, but Safeguard 16.2 focuses on accepting and addressing vulnerabilities across sources and proving controlled follow-through. Many findings originate outside scanners, and audits often fail on missing workflow evidence and ownership. ¹

Can we keep using email as the intake channel?

Yes, if email reliably feeds a system of record and is monitored with backup coverage. The audit risk comes from unmanaged inboxes where reports cannot be tracked, prioritized, or evidenced to closure. ¹

Footnotes

1. CIS Controls v8; CIS Controls Navigator v8