Exercise program governance

The exercise program governance requirement means you must run planned business continuity exercises under defined oversight, with clear objectives, documented results, and tracked corrective actions. To operationalize it quickly, establish an exercise charter, a risk-based annual calendar, role-based approvals, consistent evaluation criteria, and a remediation workflow that closes gaps and reports status to leadership ¹.

Key takeaways:

• Governance is the control: defined ownership, approvals, and decision rights for continuity exercises ¹.
• Evidence matters as much as execution: plans, scenarios, attendance, results, and remediation tracking must be retained ¹.
• Your program should be planned and repeatable: an annual calendar tied to business priorities beats ad-hoc tabletop meetings ¹.

Exercise program governance is where many continuity programs fail audits: teams run a tabletop, talk through a scenario, and move on without structured oversight, defined success criteria, or a mechanism to fix what broke. ISO 22301 expects continuity exercises to be planned and governed, which means you can explain who approved the exercise plan, why you chose those scenarios, what you learned, and how you ensured the organization actually improved afterward ¹.

For a Compliance Officer, CCO, or GRC lead, the operational goal is simple: make exercises a managed program, not an event. Managed programs have a charter, a calendar, scoped objectives, repeatable execution steps, and a corrective action process with owners and due dates. They also have reporting that lets leadership make decisions about risk, resourcing, and residual exposure.

This page translates the exercise program governance requirement into concrete steps, artifacts, and audit-ready evidence. It is written for operators who need to stand up or mature the program quickly, including organizations that depend on third parties for critical services and need assurance that continuity plans work beyond paper.

Requirement: exercise program governance requirement (ISO 22301)

Plain-English interpretation: You must run planned continuity exercises and place them under governance oversight so the program is approved, executed consistently, reviewed, and improved over time ¹.

“Governance oversight” is what prevents common failure modes:

• exercises that don’t map to real risks,
• exercises that never test critical dependencies (including third parties),
• lessons learned that never turn into fixes,
• repeat findings because the organization cannot prove control operation.

Regulatory text

Provided excerpt (framework-level summary): “Baseline implementation-intent summary derived from publicly available framework overviews; licensed standard text is not reproduced in this record.” ¹

Operator translation of what you must do: Implement a planned continuity exercise program with defined governance. That means: (1) schedule exercises intentionally, (2) define objectives and evaluation criteria before execution, (3) run the exercises, (4) document outcomes, and (5) track remediation to closure with oversight and reporting ¹.

Who it applies to

This requirement applies to any organization implementing ISO 22301-aligned business continuity management, especially where operational disruption creates material risk. Typical contexts include ¹:

• Critical service operators: Organizations delivering services where interruption harms customers, safety, financial stability, or contractual commitments.
• Service organizations: Organizations providing services to customers that rely on continuity capabilities (for example, technology platforms, outsourced operations, or shared services).

Operationally, it applies across:

• Business units that own critical processes and recovery objectives.
• IT and security teams that run incident response, disaster recovery, and cyber recovery exercises.
• Facilities and operations for site-level disruptions.
• Third-party owners responsible for continuity dependencies (cloud providers, payment processors, call centers, logistics providers, critical SaaS).

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

Step 1: Establish exercise program governance (documented and approved)

Create a short Exercise Program Charter that answers, in one page:

• program owner (single accountable role),
• steering/oversight group (who reviews and approves),
• decision rights (who can accept residual continuity risk),
• scope (which locations, processes, systems, and third parties),
• required cadence logic (risk-based; you define the rule),
• documentation and retention expectations.

Practical tip: If you already have a BCMS steering committee, use it. If not, assign governance to an existing risk or operational resilience forum to avoid creating a “paper committee.”

Step 2: Build an annual exercise plan (calendar + rationale)

Create an Annual Exercise Plan that includes:

• a calendar of exercise events,
• each exercise type (tabletop, simulation, technical failover, communications test, third-party participation test),
• scoped participants (including alternates),
• mapped business services/processes and dependencies,
• pre-defined objectives and success criteria for each exercise,
• constraints and assumptions.

Tie plan entries to real drivers:

• top enterprise risks,
• major changes (new sites, new platforms, new third parties),
• prior exercise findings,
• critical peak periods for your business.

Step 3: Standardize execution with a runbook package

For each exercise, prepare a consistent Exercise Runbook:

• scenario and injects,
• roles (facilitator, observers, scribe, incident commander role if used),
• communications channels and escalation rules,
• scope boundaries (“we will simulate X; we will not actually fail over Y”),
• data handling rules (avoid exposing sensitive data in shared materials),
• evaluation method (what evidence proves the objective was met).

Include third parties where they are a true dependency. For example, if the recovery plan assumes a cloud provider ticket response, test the operational path: contacts, escalation, communications, and coordination steps.

Step 4: Run the exercise and capture evidence in real time

During execution, capture:

• attendance and roles (who actually participated),
• timeline of key decisions and actions,
• issues observed (control gaps, process breaks, unclear ownership),
• metrics you defined (pass/fail against success criteria; avoid vanity measures).

A common hangup: teams only record “discussion notes.” Auditors and customers want to see objective results tied to pre-set criteria.

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

Within a short operational window after the exercise, publish an After-Action Report that includes:

• objectives vs. outcomes (met / partially met / not met),
• what worked (keep),
• what failed (fix),
• contributing causes (training gap, missing procedure, third-party dependency, outdated contact list),
• corrective actions with owners and due dates,
• residual risks requiring formal acceptance.

Step 6: Track remediation to closure with governance reporting

Create a continuity corrective action register (or integrate into your existing GRC issue management workflow). Governance oversight means:

• actions have owners,
• actions have due dates,
• status is reviewed regularly,
• overdue actions are escalated,
• closures are validated (not self-attested without evidence).

How Daydream fits naturally: If you already manage risk issues and third-party actions in Daydream, create a continuity exercise issue category, link AAR findings to controls, and use workflow status plus evidence attachments to make audit packages consistent across business units.

Step 7: Periodically review program effectiveness and adjust

At least once per planning cycle, governance should review:

• whether the exercise plan covered critical services and top risks,
• repeat findings themes,
• third-party participation and failures,
• changes needed in scenarios, scope, or escalation paths.

Required evidence and artifacts to retain (audit-ready)

Maintain a single “exercise evidence pack” per exercise plus program-level governance documents.

Program-level artifacts

• Exercise Program Charter (approval record)
• Annual Exercise Plan / calendar (approval record)
• Standard templates (runbook, AAR, sign-in sheet, evaluation checklist)
• Corrective action register and governance reporting

Exercise-level artifacts

• Approved exercise scope and objectives
• Runbook and scenario/inject list
• Attendance roster and roles
• Execution logs (timeline, decision notes, communications artifacts where appropriate)
• After-Action Report
• Corrective action tickets with closure evidence (revised procedures, screenshots, training completion, third-party confirmations)

Retention approach: Align retention with your broader BCMS and risk record retention rules. Consistency matters more than a specific duration.

Common exam/audit questions and hangups

Expect auditors, customers, or internal audit to ask:

• “Show me the approved exercise plan and how it maps to critical services.” ¹
• “Who governs the program and who signs off on remediation closure?” ¹
• “How do you prove exercises are planned, not ad hoc?” ¹
• “Show the last exercise, the AAR, and evidence that actions were completed.” ¹
• “How do third-party dependencies participate or get tested?” ¹

Hangups that trigger findings:

• No documented objectives or success criteria.
• No consistent templates; every business unit does it differently.
• AAR exists but corrective actions are not tracked to closure.
• “We tested DR” but cannot show governance review or management reporting.

Frequent implementation mistakes (and how to avoid them)

Mistake 1: Treating tabletop exercises as a checkbox.
Fix: Require pre-set objectives and an outcomes section with pass/partial/fail plus evidence.

Mistake 2: No governance decision rights.
Fix: Define who can accept residual risk when remediation is deferred. Put it in the charter and meeting minutes.

Mistake 3: Scenarios don’t reflect real dependencies.
Fix: Build scenarios that include critical third parties and shared services, then validate contact paths and escalation steps during the exercise.

Mistake 4: Actions live in meeting notes, not a system.
Fix: Create a corrective action register with ownership, due dates, and closure evidence. If you already have a GRC tool, use it consistently.

Mistake 5: Repeating the same scenario every cycle.
Fix: Rotate scenario types: facility outage, cyber disruption, staff unavailability, key supplier outage, data integrity event, communications failure.

Enforcement context and risk implications

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

Operational risk implications remain concrete:

• Poor exercise governance increases the chance that continuity plans fail under stress.
• Weak evidence increases audit and customer assurance risk, especially for service organizations that must prove resilience to clients and assessors.
• Untracked remediation creates repeat failures and accumulates unowned risk.

Practical 30/60/90-day execution plan

Days 0–30: Stand up governance and standardize the basics

• Assign accountable owner and governance forum (names and roles).
• Publish Exercise Program Charter and get documented approval.
• Create standard templates: runbook, attendance, evaluation checklist, AAR, corrective action ticket format.
• Draft an annual exercise plan skeleton tied to critical services and known dependencies.

Deliverables: charter, templates, draft calendar, corrective action register structure.

Days 31–60: Execute first governed exercises and prove the loop closes

• Run at least one exercise using the standardized package.
• Produce AAR with corrective actions and assign owners/dates.
• Hold a governance review meeting: approve AAR, prioritize actions, decide on any risk acceptance.
• Start building an evidence library organized by exercise and by business service.

Deliverables: completed exercise evidence pack, governance minutes, action tickets opened.

Days 61–90: Expand coverage and operationalize reporting

• Run additional exercises targeting different risk categories and dependencies (include at least one critical third party dependency test if applicable).
• Implement recurring status reporting for corrective actions (dashboard or meeting agenda item).
• Conduct a program effectiveness review: adjust scenarios, scope, and plan based on findings.
• Prepare an “audit packet” that can be handed to internal audit or customers without rewriting.

Deliverables: updated calendar, repeatable reporting, closed actions with validation evidence, audit-ready packet.

Frequently Asked Questions

Do we need a dedicated continuity exercise committee?

No, but you do need defined oversight. Many organizations assign governance to an existing BCMS steering committee or operational risk forum, as long as approvals and follow-up are documented ¹.

What counts as “planned” versus ad hoc?

Planned means the exercise is on an approved calendar or plan, has defined objectives before execution, and follows your standard process for evaluation and remediation tracking ¹.

How do we handle third parties in continuity exercises?

Include third parties when your recovery assumptions depend on them. At minimum, test contact paths, escalation, and coordination steps; document outcomes and any gaps as corrective actions.

Can we reuse incident response exercises as continuity exercises?

Yes if the exercise also tests continuity outcomes and recovery objectives, and you document governance oversight, results, and remediation the same way as other continuity exercises ¹.

What evidence is most likely to satisfy an auditor quickly?

An approved annual exercise plan, a completed runbook + AAR for the most recent exercise, and a corrective action register showing closure evidence and governance review ¹.

What if business units resist participating?

Put participation expectations in the charter, have governance approve the calendar, and tie open corrective actions to operational risk reporting so leaders see the impact of non-participation.

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Footnotes

1. ISO 22301 overview