Exercise and validation

“Exercise and validation” is where continuity programs either become operationally real or stay as paperwork. ISO 22301 expects you to prove, with repeatable testing and evidence, that your continuity plans work against your organization’s stated objectives. The requirement is not satisfied by writing a plan, distributing it, or running an occasional tabletop without outcomes. You need a program: defined scenarios, defined success criteria, measured results, and a mechanism that forces remediation to closure.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to convert continuity objectives into testable criteria, schedule a mix of exercise types, and standardize artifacts. Auditors typically focus on two questions: (1) did you actually test what matters, and (2) did you fix what you found. If you cannot show closed-loop corrective actions, your exercise record becomes evidence of known weakness.

This page gives requirement-level implementation guidance you can put into motion quickly, including a step-by-step approach, evidence to retain, common audit hangups, and a 30/60/90-day execution plan aligned to ISO 22301’s intent ¹.

Regulatory text

Provided excerpt (summary record): “Baseline implementation-intent summary derived from publicly available framework overviews; licensed standard text is not reproduced in this record.” ¹
Implementation-intent summary: “Test continuity plans and validate readiness against objectives.” ¹

What the operator must do

You must run planned exercises to test your continuity arrangements (plans, procedures, roles, communications, tools, and dependencies) and validate that actual performance meets your defined objectives. Then you must document results, identify gaps, assign corrective actions, and track remediation through closure with proof ¹.

Plain-English interpretation (what “exercise and validation” really means)

• Exercise = a structured test of your continuity capability, performed in a controlled way (tabletop, simulation, failover, call-tree, restore test, etc.).
• Validation = confirming the test results meet pre-defined targets and that your capability is reliable enough to support business needs.

If you do not define success criteria before the test, you cannot validate. If you identify issues but do not close them, you have not proven readiness. If you only test IT recovery but ignore business operations, people, facilities, and third parties, you validate only a slice of continuity risk.

Who it applies to

This requirement applies to organizations implementing ISO 22301, including:

• Critical service operators whose continuity failure would disrupt essential services.
• Service organizations that provide services to customers and must demonstrate resilience and recovery capability ¹.

Operationally, it applies wherever continuity outcomes depend on:

• Business processes (order intake, customer support, claims, manufacturing steps, etc.)
• Technology (applications, infrastructure, identity, data recovery)
• People and facilities (work locations, remote work contingencies, staffing)
• Third parties (cloud/SaaS, payment processors, BPO/contact centers, logistics, MSSPs)

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

Step 1: Convert continuity objectives into test criteria

Create a short “validation matrix” that turns objectives into measurable checks. Include:

• Objective (e.g., “restore service within X hours”)
• System/process in scope
• Evidence expected (screen captures, logs, tickets, call logs, runbook timestamps)
• Pass/fail criteria
• Owner

Practical tip: auditors respond well to a one-page matrix that maps exercise results back to objectives. It shows discipline and makes sampling easier.

Step 2: Build an exercise program (not ad hoc tests)

Define an exercise plan that covers:

• Exercise types: tabletop, technical recovery test, communications drill, supplier outage simulation
• Scope selection method: risk-based (critical processes, high-impact services, known fragile dependencies)
• Roles: incident commander, recovery leads, observers, evidence recorder
• Frequency and triggers: schedule plus “event-driven” exercises after major changes or incidents (your policy should define what changes trigger validation)

Keep the program realistic: test what would break your ability to deliver your critical products and services, including handoffs across teams.

Step 3: Design scenarios that force real decisions

Write scenarios that stress:

• Loss of a key application or data store
• Loss of a site or network segment
• Identity provider outage preventing access
• Loss of a third party service that is embedded in your workflow

Scenario design rule: a scenario should produce time-bound actions and clear outcomes, not discussion-only narratives.

Step 4: Execute exercises with disciplined evidence capture

During the exercise:

• Start an exercise record (date/time, participants, systems/processes, scenario, objectives)
• Capture timestamps for key events (declaration, failover start, restore complete, business resumption)
• Record decision points (what was chosen, by whom, and why)
• Log communications (internal escalation, customer comms drafts, third party contacts)
• Capture technical proof (restore logs, monitoring snapshots, ticket IDs, change records)

Assign an “evidence scribe.” If you rely on participants to remember later, your artifact quality collapses.

Step 5: Produce an after-action report with corrective actions

Within a short window after the exercise, publish an after-action report that includes:

• What worked (and why)
• What failed or degraded
• Variances vs objectives (explicit pass/fail per objective)
• Root cause notes (technical, process, documentation, training, third party dependency)
• Corrective actions with owners and due dates
• Residual risk statement for any deferred items, with approval

This is where the requirement is often won or lost. A vague “lessons learned” paragraph is not validation.

Step 6: Track remediation through closure (and prove it)

Operate a simple but strict corrective action workflow:

• Ticket each issue (GRC system, ITSM, or a controlled register)
• Assign an owner and target date
• Require closure evidence (updated runbook, config change record, test rerun results)
• Escalate overdue items through governance

Recommended control aligned to the provided guidance: run exercises and track gaps through remediation closure ¹.

Step 7: Re-validate after material changes

Define what forces re-testing, such as:

• Major infrastructure migration
• Application re-architecture
• Key third party change (new provider, contract change, major product change)
• Significant incident that revealed a new failure mode

Change without re-validation is a common audit finding because it breaks the link between documented capability and current reality.

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

Retain artifacts in a controlled repository with versioning and access control:

1. Exercise program document (annual plan, scope method, roles/responsibilities)
2. Scenario scripts and test plans (objectives, success criteria, dependencies, prerequisites)
3. Attendance and role assignment records (who participated, who observed, who approved)
4. Exercise execution log (timeline, decisions, communications, escalation)
5. Technical evidence (restore logs, failover proof, monitoring snapshots, ticket/change IDs)
6. After-action report (results vs objectives, findings, corrective actions)
7. Corrective action register (status, owners, due dates, closure evidence)
8. Closure proof (updated procedures, training records, rerun test outputs)
9. Management review notes showing oversight of outcomes and risk acceptance (where applicable)

If you use Daydream to manage control evidence, map each artifact to the “exercise and validation requirement” so sampling becomes a one-click export instead of a file hunt.

Common exam/audit questions and hangups

Auditors and assessors typically press on:

• “Show me the objective you tested against.” If objectives exist only in a BIA or policy and aren’t tied to exercise criteria, validation looks subjective.
• “What changed since the last test?” If major systems changed without re-test, your evidence becomes stale.
• “Did you include third parties?” If a critical service depends on a third party, testing without that dependency is incomplete.
• “Prove closure.” Open findings with no closure evidence create the impression of unmanaged risk.
• “Was this a real test or a discussion?” Tabletop-only programs often fail to demonstrate technical recoverability.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Tabletop exercises with no metrics	Discussion does not validate recoverability	Add measurable success criteria and capture evidence against them
Testing only IT, ignoring business operations	Recovery can succeed technically but fail operationally	Add business process resumption steps and business owner sign-off
No corrective action tracking	Findings repeat and readiness declines	Use a corrective action register with escalation and closure evidence
Scenarios are too “happy path”	You validate a best-case that won’t happen	Include dependency failures and degraded-mode operations
Evidence scattered across chat and email	Audits stall; results look unverifiable	Standardize an exercise packet and store in a single repository

Enforcement context and risk implications

No public enforcement cases are provided in the source catalog for this requirement. Practically, the risk is still concrete: if you cannot demonstrate tested and validated continuity capability, you may fail customer due diligence, lose deals, or face adverse audit opinions in assurance engagements. Internally, the bigger risk is operational: untested plans tend to fail under stress, and unclosed findings become repeat incidents.

Practical 30/60/90-day execution plan

First 30 days: Stand up the structure

• Publish an exercise and validation policy standard: objectives-to-tests mapping, artifact requirements, and corrective action workflow.
• Build your validation matrix for critical services and top dependencies.
• Choose a single system of record for evidence and findings (GRC platform, ITSM, or a controlled repository).
• Schedule the next exercises and assign owners, scribes, and approvers.

Days 31–60: Run exercises that produce measurable outcomes

• Run at least one tabletop for a critical service with explicit pass/fail criteria.
• Run at least one technical validation (restore, failover, or recovery procedure execution) for a key system that supports a critical service.
• Publish after-action reports quickly and open corrective actions in your tracking system.
• Brief senior stakeholders on initial results and overdue risk decisions.

Days 61–90: Close the loop and mature coverage

• Drive corrective actions to closure with proof, then re-test any high-risk fixes.
• Expand scenarios to include third party dependency failure for a critical workflow.
• Add change-triggered re-validation gates to your change management or release process.
• Prepare an audit packet: exercise plan, two complete exercise records, corrective action register, and closure evidence.

Frequently Asked Questions

What counts as “validation” versus an “exercise”?

An exercise is the event. Validation is the proof that outcomes met pre-defined objectives, backed by evidence like timelines, logs, and sign-offs ¹.

Do tabletop exercises satisfy the exercise and validation requirement?

Tabletop exercises help validate roles, decision-making, and communications. They rarely validate technical recoverability unless paired with technical tests and measurable objectives tied to recovery outcomes.

How do we include third parties without running joint tests every time?

Validate third party readiness through a mix of approaches: joint exercises for critical dependencies, contract-required test attestations, incident drill participation, and evidence reviews tied to your service objectives.

What evidence is most persuasive to auditors?

A clear objective-to-result mapping, a time-stamped execution log, and corrective actions with closure proof. Auditors sample artifacts; they do not want narratives without records.

How do we handle failed tests without creating audit exposure?

Document the failure, open corrective actions, assign ownership, and track to closure with re-test evidence. A controlled remediation trail generally reads better than missing or sanitized records.

Can we track corrective actions in spreadsheets?

You can, if the spreadsheet is controlled (access, versioning, approvals) and you can show closure evidence. Many teams move findings into an ITSM or GRC workflow to avoid loss of accountability as volume grows.

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Footnotes

1. ISO 22301 overview