RS.MA-05: The criteria for initiating incident recovery are applied

RS.MA-05 requires you to use defined, pre-approved criteria to decide when to shift an incident from response into recovery, and to prove you applied those criteria in real events. Operationalize it by documenting recovery “start” triggers, assigning decision authority, embedding the criteria into incident workflows, and retaining timestamped evidence from tickets, approvals, and post-incident reviews. ¹

Key takeaways:

• Define recovery initiation criteria that are measurable, role-owned, and tied to services and business impact. ¹
• Build the criteria into incident tooling so decisions are consistent and auditable, not ad hoc. ¹
• Retain evidence that shows the criteria were actually applied during incidents and exercises. ¹

RS.MA-05: the criteria for initiating incident recovery are applied requirement sounds simple, but most audit findings come from inconsistency: teams “start recovery” informally, do not record the decision, or cannot explain why recovery began at a specific time. In NIST CSF 2.0, this requirement sits in the Respond function and focuses on disciplined management of the transition into recovery. ¹

For a CCO or GRC lead, the goal is operational proof. You need (1) clear criteria that define what “initiate recovery” means for your environment, (2) a repeatable decision path with named authority, and (3) evidence artifacts that show the organization followed its own rules under pressure. That evidence has to survive scrutiny even when responders rotate, incidents are messy, and multiple third parties are involved.

This page gives you requirement-level implementation guidance you can execute quickly: who owns it, how to define triggers and thresholds without over-engineering, how to embed it into your incident process and tools, what auditors ask, and which mistakes cause “paper compliance” failures.

Regulatory text

Regulatory excerpt: “The criteria for initiating incident recovery are applied.” ¹

What the operator must do: You must (a) define criteria that determine when incident recovery begins, and (b) apply those criteria consistently during incidents (and ideally exercises) so the start of recovery is a controlled decision, not an informal handoff. Expect to show documentation and records proving the criteria were used for at least a sample of incidents. ¹

Plain-English interpretation

“Initiating recovery” is the point where you stop only containing/eradicating and begin executing the plan to restore services, data, and normal operations. RS.MA-05 requires you to decide that moment using predefined triggers (impact, readiness, risk, dependencies), not gut feel.

A practical interpretation you can defend:

• Recovery starts when restoration actions are formally authorized and recovery objectives (what to restore first, in what order, with what constraints) are set.
• The authorization is based on criteria you wrote down ahead of time, and you can show the decision record later.

Who it applies to

Entity scope: Any organization running a cybersecurity program and aligning to NIST CSF 2.0. ¹

Operational scope (where RS.MA-05 shows up):

• Central incident response and crisis management teams (SOC, IR, IT Ops, SRE, BC/DR).
• Business service owners who approve downtime, degraded modes, or failover.
• Legal/compliance and privacy teams when restoration choices affect evidence preservation or regulated data.
• Third parties: cloud providers, MSSPs, forensics firms, key SaaS vendors, and outsourcers whose actions are part of recovery execution.

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

1) Define “recovery initiation” for your environment

Write a short definition in your incident response and recovery procedures:

• What event marks the start (e.g., “Recovery Initiated” status in the incident ticket).
• Who can declare it.
• What minimum information must exist before declaration (e.g., affected services identified, containment status assessed, restoration approach selected).

This prevents teams from calling “recovery” anything from “we’re thinking about restoring” to “we rebuilt production.”

2) Build a recovery initiation criteria matrix

Create criteria that are observable and that align with business services. Keep it short enough to use during a live incident.

A usable matrix format:

Criteria category	Trigger examples (customize)	Evidence you expect
Service impact	Customer-facing service unavailable; critical internal workflow down	Monitoring alerts, status page, incident severity
Data integrity risk	Suspected unauthorized changes to data; integrity checks failing	Hash/integrity reports, app logs, DB audit logs
Containment readiness	Malicious activity contained to defined scope; IOC blocking in place	EDR/SIEM notes, firewall changes, containment checklist
Recovery path readiness	Restore method chosen (failover, rebuild, restore from backup) and prerequisites met	Runbook reference, change ticket, backup validation
Governance/constraints	Forensics hold satisfied; legal/compliance sign-off obtained where needed	Approval record, counsel guidance, evidence preservation note
Third-party dependencies	Cloud/provider confirms platform stability; vendor provides recovery steps	Vendor comms, support ticket, SLA update

Your criteria do not need to be identical for every incident type. You can define sets (e.g., ransomware, cloud outage, insider misuse) as long as you can show the right set was selected and applied. ¹

3) Assign decision authority and escalation

Document decision rights using a simple RACI:

• Responsible: Incident Commander (or IR Lead) runs the decision meeting.
• Accountable: Service Owner (or Crisis Manager) authorizes recovery initiation for that service.
• Consulted: Security, IT Ops/SRE, BC/DR, Legal/Compliance, Privacy (as applicable).
• Informed: Executive leadership, Communications, impacted business units.

Add a clear escalation path for disagreements (e.g., if Security wants to delay restoration to preserve evidence, but business wants service back). The control weakness auditors see most is “everyone assumed someone else approved.”

4) Embed the criteria into your workflow and tooling

Make it hard to skip:

• Add an incident ticket field: “Recovery Initiated? (Y/N)” with timestamp.
• Add a required link to the criteria checklist used.
• Require an approval step in your ITSM or incident management tool for “Recovery Initiated.”
• Tie recovery initiation to a change workflow when restoration includes config changes, rebuilds, or failover actions.

Daydream can help by mapping RS.MA-05 directly to the policy/procedure owner, then scheduling recurring evidence pulls from your incident tooling so you are not chasing screenshots during audit season.

5) Train and test with tabletop scenarios

Run a tabletop where the only objective is: “Decide whether to initiate recovery, and prove it.” Capture:

• Which criteria were referenced.
• Who approved.
• What information was missing and how you will collect it next time.

6) Operate and continuously improve

After each real incident:

• Confirm the decision record exists and is complete.
• Update criteria if responders repeatedly ignore a trigger because it is unrealistic or too vague.
• Track exceptions (with rationale) instead of silently deviating.

Required evidence and artifacts to retain

Retain evidence that proves both design (criteria exist) and operation (criteria were applied):

Design artifacts

• Incident Response Plan and Recovery/Restoration Procedure referencing recovery initiation criteria. ¹
• Recovery initiation criteria matrix/checklist (version-controlled).
• RACI / decision authority document.
• Tooling configuration evidence (ticket fields, workflow gates, approval steps).

Operational artifacts ²

• Incident ticket showing:
  • severity classification,
  • “Recovery Initiated” timestamp,
  • approver identity,
  • checklist completed or linked.
• Meeting notes or chat export capturing the decision and rationale.
• Change tickets for recovery actions (failover, restore, rebuild).
• Post-incident review showing whether criteria were met, and corrective actions.

Evidence quality matters more than volume. Auditors want a clean story: criteria existed before the incident, and the team followed them. ¹

Common exam/audit questions and hangups

Expect questions like:

• “Show me your documented criteria for initiating recovery. Where is it approved and how often is it reviewed?” ¹
• “Walk me through the last incident. When did recovery begin, who approved it, and what criteria were met?”
• “How do you prevent responders from restoring systems before containment is adequate?”
• “How do third parties fit into your recovery initiation decision if they host key services?”
• “What happens if you must start recovery but criteria are partially unmet?”

Common hangups:

• No consistent timestamp for “recovery start.”
• Criteria exist in a slide deck but are not in the incident workflow.
• Decision authority is ambiguous across Security, IT, and the business.

Frequent implementation mistakes and how to avoid them

1. Mistake: Criteria are aspirational (“when safe”).
   Fix: Use observable conditions (containment checklist completed, backup integrity verified, service owner approval recorded).

2. Mistake: Recovery initiation is confused with DR invocation.
   Fix: Define both. DR invocation may be one recovery path, but recovery initiation can also mean controlled restoration within the primary environment.

3. Mistake: No exception handling.
   Fix: Add an “override” path requiring documented rationale and approval, then review it in the post-incident process.

4. Mistake: Third-party recovery is unmanaged.
   Fix: Require vendor communications to be attached to the incident record, and define when vendor confirmation is a prerequisite trigger for recovery initiation.

Risk implications (why operators get burned)

If you cannot prove you applied recovery initiation criteria, you create three practical risks:

• Technical risk: Restoring too early can reintroduce threat activity or corrupt restored data.
• Governance risk: You cannot show controlled decision-making under stress.
• Audit risk: Your program looks “documented but not operated,” which often expands audit sampling and remediation scope.

Practical 30/60/90-day execution plan

First 30 days (establish minimum viable control)

• Name the control owner and decision authority (Incident Commander + Service Owner accountability).
• Draft a one-page recovery initiation criteria checklist and publish it in the IR runbook repository. ¹
• Add a “Recovery Initiated” field and timestamp requirement to the incident ticket template.
• Run one tabletop focused on the recovery initiation decision and evidence capture.

Day 31–60 (make it repeatable and auditable)

• Convert the checklist into a workflow gate (approval or required fields).
• Create incident-type addenda (ransomware-like, cloud outage, data integrity incident) with tailored triggers.
• Train on-call leaders and service owners on how to document the decision.
• Start a monthly evidence pull: select a closed incident and validate the artifacts are complete.

Day 61–90 (harden and integrate)

• Integrate third-party dependencies: add “vendor/platform confirmation” evidence requirements for hosted critical services.
• Tie recovery initiation to change management for restoration actions.
• Add post-incident review questions: “Were criteria applied? Any overrides? What changed?”
• Use Daydream to map RS.MA-05 to the policy/procedure, assign ownership, and automate recurring evidence collection so audit requests become a packaged export rather than an inbox fire drill.

Frequently Asked Questions

What counts as “initiating incident recovery” versus “incident response”?

Treat recovery initiation as the formal point you authorize restoration actions and set restoration priorities for affected services. Response activities like detection, scoping, containment, and eradication can continue, but the decision to restore should be explicitly recorded. ¹

Do the criteria have to be the same for every incident?

No. You can maintain different criteria sets by incident type or service tier, as long as each set is documented and you can show which one you applied during the event. ¹

Who should approve the start of recovery?

Assign accountability to the business or service owner for the impacted service, with the Incident Commander responsible for running the decision process. Security, IT Ops, and Legal/Compliance typically advise based on containment, integrity, and evidence constraints.

What if we must restore service quickly but cannot meet all criteria?

Use an exception path that requires documented rationale, explicit approval, and a follow-up action plan. Auditors generally accept controlled exceptions more readily than undocumented deviations. ¹

How do we handle third-party outages where we can’t control the underlying fix?

Your criteria should include third-party signals as prerequisites (vendor incident notice, estimated restoration timeline, confirmation of platform stability) and require you to attach those communications to the incident record.

What’s the minimum evidence set to satisfy an audit request?

For a sampled incident, provide the incident ticket with the recovery initiation timestamp, the checklist or criteria reference used, the approver identity, and the post-incident review entry confirming the criteria were applied or overridden with rationale.

Footnotes

1. NIST CSWP 29

2. NIST CSF 1.1 to 2.0 Core Transition Changes