GV.OC-02: Internal and external stakeholders are understood, and their needs and expectations regarding cybersecurity risk management are understood and considered

GV.OC-02 is a governance requirement disguised as a relationship-management task. Auditors and customers rarely fail you for not knowing who your stakeholders are; they fail you for not proving that stakeholder expectations are captured, translated into actionable requirements, and routinely used to steer cybersecurity risk decisions.

For a CCO or GRC lead, the fastest path is to operationalize GV.OC-02 as a lightweight, controlled workflow: identify stakeholders (internal and external), capture their cybersecurity risk expectations in a consistent format, reconcile conflicts, and route the outputs into the places that matter (risk appetite, policy, control priorities, third-party requirements, incident communications, and executive reporting). Then, preserve a clean evidence bundle each cycle.

This page gives you requirement-level implementation guidance: who owns what, what artifacts to create, how to run the process, and what exam teams typically probe. All citations in this document reference NIST Cybersecurity Framework 2.0 source materials (NIST CSF 2.0; NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes).

Regulatory text

Excerpt (GV.OC-02): “Internal and external stakeholders are understood, and their needs and expectations regarding cybersecurity risk management are understood and considered.” (NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes)

Operator interpretation (what you must do)

You must be able to demonstrate, with records, that:

1. You have identified the relevant internal and external stakeholders who shape or are impacted by cybersecurity risk decisions.
2. You have captured their needs and expectations in a structured way (not scattered emails).
3. You consider those expectations in governance and operational decisions (risk acceptance, priorities, investments, third-party requirements, incident communications, and reporting). (NIST CSF 2.0; NIST CSWP 29)

“Considered” is the key word. It means your cybersecurity risk program shows traceability from stakeholder expectations to decisions and actions, including when you choose not to meet an expectation and document the rationale.

Plain-English interpretation of the requirement

Maintain a current map of who cares about cybersecurity risk (and why), what they require from you, and how your program responds. If stakeholders disagree, document the conflict and how leadership resolved it. If you claim you meet an expectation, prove it with metrics or operating evidence.

Who it applies to

This requirement applies to any organization running a cybersecurity program that must align to business objectives and external obligations, including:

• Critical infrastructure operators coordinating cybersecurity risk across operations, safety, reliability, and regulators.
• Service organizations that must satisfy customer security expectations, contractual terms, and third-party oversight requests.
• Organizations with formal GRC practices where risk decisions require accountable approvals and repeatable reporting. (NIST CSF 2.0)

Operationally, GV.OC-02 becomes “real” anywhere you:

• Accept or transfer risk (risk acceptance, insurance, outsourcing).
• Provide services or handle customer data (contractual security requirements).
• Coordinate incident response communications (customers, regulators, law enforcement, insurers).
• Rely on third parties for critical systems (cloud, MSSP, software suppliers, contractors).

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

Step 1: Name an owner and define the workflow boundaries

Assign a single accountable owner (often GRC, enterprise risk, or the CISO’s office) for:

• Maintaining the stakeholder register
• Running the stakeholder expectation review
• Publishing outputs to risk and control governance forums

Define what “stakeholder” means in your environment:

• Internal: Board/committee, CEO/COO, CIO/CTO, CISO, Legal, Privacy, Compliance, Finance, Product, Engineering, IT Ops, Security Ops, HR, Procurement/TPRM, Business unit leaders, Internal Audit.
• External: Customers, regulators (as applicable), key third parties (processors, cloud providers), insurers, critical partners, sector bodies, and sometimes investors.

Step 2: Build a stakeholder register (single source of truth)

Create a register with fields that make it operational:

Field	What “good” looks like
Stakeholder name + type	Internal/external, role, business unit
Decision influence	What decisions they approve, fund, or can block
Cybersecurity expectations	Specific requirements, reporting needs, risk tolerance, response time expectations
Evidence source	Contract clause reference, board minutes, policy requirement, customer security addendum, questionnaire, meeting notes
Reconciliation notes	Conflicts and resolution path
Review cadence + last review	Shows it’s maintained, not created once
Owner	Person accountable for updates and follow-ups

Keep it tight. If the register becomes a directory, it stops working.

Step 3: Capture “needs and expectations” as testable requirements

Convert vague statements into measurable or verifiable requirements. Examples:

• “Customers expect strong security” → “Customer contracts require breach notification within the contract-defined period; Security must maintain an incident communications playbook aligned to those obligations.”
• “Board wants visibility” → “Quarterly cyber risk reporting includes top risks, KRIs, material exceptions, and risk acceptances requiring approval.”
• “Engineering wants speed” → “Documented risk-based exception process for release gates, with time-bound remediation plans.”

Where possible, encode expectations into:

• Policy requirements (what must happen)
• Standards/baselines (how it happens)
• Metrics and reporting templates (how you prove it)
• Decision rights (who approves exceptions and risk acceptance)

This directly addresses a common maturity gap: acknowledging outcomes conceptually without converting them into measurable governance and operating actions. (NIST CSF 2.0)

Step 4: Reconcile conflicts and document tradeoffs

Conflicts are normal: product wants minimal friction, compliance wants strict controls, a customer wants bespoke terms, and IT wants standardization.

Use a simple decision matrix:

• Non-negotiables: legal/regulatory obligations, signed contract terms, safety/reliability constraints.
• Risk-based negotiables: controls that can be met via compensating controls, phased rollout, or scoped commitments.
• Explicit exceptions: what you will not do, plus residual risk and acceptance authority.

Record outcomes in meeting minutes or risk committee decisions, and update the register.

Step 5: Route expectations into your operating processes

Make stakeholder expectations visible inside the machinery of your program:

Governance and risk

• Risk appetite / risk tolerance statements
• Risk acceptance workflow with named approvers
• Control prioritization and security roadmap decisions

Third-party risk management

• Contract security clauses and addenda
• Third-party due diligence requirements aligned to customer/regulatory expectations
• Critical third-party monitoring and escalation

Incident response and communications

• Stakeholder-specific notification requirements
• Contact trees and pre-approved messaging paths (Legal/Comms/Exec)

Assurance

• Internal audit scope alignment
• Evidence planning and control testing cadence

Step 6: Run periodic performance reviews and track exceptions

Operate GV.OC-02 as a living governance control:

• Review stakeholder expectations on a defined cadence and after major events (new product, acquisition, major incident, new customer segment).
• Track exceptions with remediation plans and due dates.
• Keep records of management review and decisions. (NIST CSF 2.0)

A practical pattern: include a “stakeholder expectations review” agenda item in your existing security steering committee, risk committee, or TPRM governance forum.

Step 7: Maintain an evidence bundle per review cycle

Keep a concise packet that stands on its own:

• Stakeholder register (current version + change log)
• Meeting agenda/minutes showing review and decisions
• Metrics/reporting provided to stakeholders (board deck excerpt, customer trust report, KRI dashboard)
• Exceptions log with remediation owners and dates
• Samples showing outputs flowed into policies, contracts, IR plans, or risk acceptances (redacted if needed) (NIST CSF 2.0)

This directly addresses another common gap: weak evidence of control operation and management review. (NIST CSF 2.0)

Required evidence and artifacts to retain

Minimum set (auditor-ready):

• Stakeholder register with version control
• Stakeholder expectation statements (board reporting requirements, customer contractual security requirements, third-party obligations, insurer questionnaires, etc.)
• Governance records: steering committee minutes, risk committee approvals, board materials showing cyber risk reporting
• Risk acceptance and exception records tied to stakeholder expectations
• Third-party artifacts: standard security addendum, key third-party due diligence outputs, escalations
• Incident communications mapping: notification matrix, IR comms workflow approvals

If you use Daydream, treat it as the system of record for the register, decision log, and evidence bundles so you can answer diligence requests quickly without re-assembling artifacts from email and slide decks.

Common exam/audit questions and hangups

What reviewers ask (and why it matters):

1. “Show me your stakeholders.” They want a maintained register, not a list made for the audit.
2. “How do you know what they expect?” They want sources: contracts, minutes, policies, questionnaires.
3. “Where did those expectations change a decision?” They want traceability into risk acceptance, roadmaps, exceptions, and reporting.
4. “How do you handle conflicting expectations?” They want documented governance and decision rights.
5. “How do you keep this current?” They want a cadence, triggers, and ownership.

Hangups:

• External stakeholders are listed but not integrated into governance.
• Customer expectations exist only in Sales/Legal silos.
• “Considered” is asserted without proof.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Treating the stakeholder list as an org chart	No link to risk decisions	Add “decision influence” and “expectations” fields
Capturing expectations as generic goals	Not testable, not auditable	Rewrite as requirements, metrics, or decision rights
Ignoring third parties as stakeholders	Supply chain risk and contractual exposure	Include key third parties and contract owners
No conflict-resolution record	Auditors see unmanaged risk tradeoffs	Use a decision matrix and record approvals
Evidence scattered across tools	High audit friction; inconsistent answers	Build a per-cycle evidence bundle (NIST CSF 2.0)

Enforcement context and risk implications

NIST CSF 2.0 is a framework, not a regulator by itself, so enforcement typically comes indirectly: contractual disputes, customer claims of misrepresentation, or regulatory findings under other applicable rules when governance is weak. GV.OC-02 reduces those risks by making stakeholder commitments explicit, governed, and traceable to execution. (NIST CSF 2.0; NIST CSWP 29)

Practical 30/60/90-day execution plan

First 30 days: Stand up the control

• Assign owner and identify the governance forum that will review stakeholder expectations.
• Draft the stakeholder register and populate the initial internal list.
• Collect external expectation sources already on hand (customer security addenda templates, top customer questionnaires, insurer requirements, key third-party contracts).
• Define the evidence bundle structure and storage location.

Days 31–60: Convert expectations into operating requirements

• Normalize stakeholder expectations into testable statements (reporting, approvals, contractual obligations, third-party requirements).
• Map expectations to where they land: policy, risk acceptance, third-party due diligence, incident communications, metrics.
• Identify conflicts and route them to the right decision-makers; document decisions.

Days 61–90: Prove operation and close gaps

• Run the first formal stakeholder expectations review in your governance forum.
• Publish at least one reporting artifact aligned to stakeholder expectations (board/KRI pack, customer-facing security posture summary, or internal risk dashboard).
• Start the exceptions/remediation log; track follow-ups to closure.
• Package the first evidence bundle and do a mock audit walkthrough.

Frequently Asked Questions

Do we need to include customers as stakeholders even if we have many small customers?

Yes, but you can manage them as segments. Capture shared expectations through standard contract terms, security addenda, and common questionnaires, then document how those inputs shape your controls and reporting.

Are third parties “stakeholders” under GV.OC-02?

They can be. Critical third parties affect your ability to meet cybersecurity expectations, and they often impose requirements on you (security terms, notification paths, technical constraints).

What counts as proof that expectations are “considered”?

Decision evidence. Examples include risk acceptance records referencing a stakeholder expectation, steering committee minutes approving a tradeoff, or a security roadmap item created to meet a contractual requirement. (NIST CSF 2.0)

How detailed should the stakeholder register be?

Detailed enough to drive action. If a stakeholder entry does not lead to a requirement, decision right, metric, or reporting obligation, remove it or rewrite it.

What if stakeholders disagree on acceptable risk?

Treat it as a governance issue. Document the conflict, assess the risk, propose options (including compensating controls), and record who approved the final position and why.

Can we meet GV.OC-02 without new tooling?

Yes. A controlled register, meeting cadence, and evidence bundle can run in standard GRC tools or even a disciplined document repository. Tooling helps when you need consistent traceability and fast responses to customer diligence requests.