GV.OV-02: The cybersecurity risk management strategy is reviewed and adjusted to ensure coverage of organizational requirements and risks

GV.OV-02 requires you to run a repeatable governance cadence where the cybersecurity risk management strategy is formally reviewed, updated, and re-approved so it continues to cover your current business requirements and risk landscape. Operationalize it by setting triggers, assigning accountable owners, documenting decisions, and retaining meeting-grade evidence of what changed and why.

Key takeaways:

• Treat the “strategy review” as a governed process with inputs, decision rights, and recorded outcomes, not a slide deck refresh.
• Define review triggers (business change, incidents, third-party shifts, new tech) and tie them to explicit updates in risk appetite, priorities, and control coverage.
• Keep audit-ready artifacts: dated strategy versions, decision logs, approvals, and mapping from requirements/risks to strategic initiatives and controls.

The gv.ov-02: the cybersecurity risk management strategy is reviewed and adjusted to ensure coverage of organizational requirements and risks requirement is a governance control disguised as a strategy statement. Examiners and auditors do not want a “cyber strategy” that sits unchanged while the organization moves to new clouds, adopts AI tooling, expands third-party dependencies, or changes its product and regulatory footprint. They want proof that your strategy is alive: it ingests real inputs, it adapts to real change, and leadership can show decisions and tradeoffs.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to define a lightweight but defensible operating rhythm: who owns the strategy, who must review it, what must be considered each cycle, what forces an out-of-cycle review, and what evidence you retain. Then connect the strategy to your risk register, policies, and program roadmap so a reviewer can trace: “requirement/risk → strategy position → funded work → implemented controls → residual risk.”

This page gives requirement-level guidance aligned to NIST CSF 2.0 governance outcomes ¹ and transition context ².

Regulatory text

Excerpt (GV.OV-02): “The cybersecurity risk management strategy is reviewed and adjusted to ensure coverage of organizational requirements and risks.” ¹

What the operator must do:
You must (1) establish a defined review mechanism for the cybersecurity risk management strategy, (2) periodically and event-driven reassess whether it still covers current organizational requirements and risks, and (3) make documented adjustments with appropriate approval. This outcome is part of CSF 2.0’s governance focus on keeping cyber risk management aligned to business reality, not last year’s assumptions ¹.

Plain-English interpretation

Your cybersecurity risk management strategy must stay accurate as your organization changes. You need a standing process that forces the right stakeholders to re-check the strategy against:

• what the business is doing (products, markets, mergers, key initiatives),
• what you rely on (critical systems, data, third parties),
• what has changed in risk (incidents, near misses, threat shifts),
• what obligations you have (contracts, customer requirements, regulatory expectations).

If there is a mismatch, you update the strategy and record the decision. If you decide not to change it, you still document why the existing strategy remains adequate.

Who it applies to

Entities: Any organization operating a cybersecurity program and using NIST CSF 2.0 for governance, assurance, customer commitments, or internal risk management ¹.

Operational contexts where GV.OV-02 becomes “exam visible”:

• Rapid business change: new product lines, acquisitions, new geographies, major outsourcing.
• Material technology change: cloud migration, identity redesign, endpoint platform changes, new AI/ML systems.
• High third-party dependency: SaaS-heavy stacks, managed security providers, critical suppliers.
• Regulated or contract-heavy environments: customer security addenda that require ongoing program updates.

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

1) Define the “strategy” scope (so reviews are testable)

Write down what your cybersecurity risk management strategy includes and excludes. Minimum components that make reviews meaningful:

• Risk appetite / tolerance statements for cyber (in business terms).
• Priority risks and assumptions (top risks, crown jewels, threat model at a high level).
• Strategic pillars and program focus (identity, resilience, third-party risk, secure SDLC).
• Coverage statement: what requirements and risk domains the strategy claims to cover.
• Governance: decision rights, escalation, and how exceptions are handled.

Keep it short enough to review, but specific enough that gaps are obvious.

2) Assign accountable owners and decision rights

Create a simple RACI for strategy review:

• Accountable: security executive (CISO or equivalent) or risk owner for cyber.
• Responsible: GRC lead to run the cadence, collect inputs, publish drafts.
• Consulted: IT, engineering, privacy, legal, procurement/TPRM, finance, business unit leaders.
• Informed/Approver: senior leadership committee or board-level risk committee (as applicable).

This is where many programs fail: “security owns it” without documenting who must approve changes.

3) Set a review cadence plus “out-of-cycle” triggers

Define:

• A planned review rhythm (your choice) and
• Mandatory event-driven triggers.

Practical triggers that auditors accept because they map to real risk change:

• Major incident or repeated near misses.
• Material changes in critical systems, identity, network architecture, or data flows.
• Launch of a materially different product (new data types, new customer segment).
• Material third-party change (new critical provider, major outsourcing, concentration risk).
• Contractual/regulatory requirement changes that affect security obligations.

Document triggers in the procedure so “we didn’t think to revisit strategy” is no longer plausible.

4) Build the input pack (so the review is evidence-driven)

For each review, compile a standard input pack. Keep it consistent so you can prove repeatability:

• Updated enterprise risk register entries tied to cyber.
• Incident/metrics summary (trends, root causes, control failures).
• Third-party risk summary (critical third parties, issues, renewals, systemic findings).
• Technology and business change log (initiatives that changed exposure).
• Exceptions/risk acceptances granted since last review.
• Open audit issues and remediation status.

If you use Daydream, this is a natural place to automate reminders, collect recurring evidence, and maintain the mapping from GV.OV-02 to owners, procedures, and artifacts so the review does not depend on one person’s calendar.

5) Run the review meeting like a control, not a workshop

Use a standard agenda with decisions:

• Confirm whether business requirements changed.
• Confirm whether key risks changed (likelihood/impact or new risk categories).
• Validate whether strategic priorities still cover the risk set.
• Decide adjustments (add/remove strategic initiatives, change priorities, revise risk appetite language, adjust resourcing asks).
• Assign actions with owners and due dates.

Record decisions as decisions. Avoid vague minutes like “discussed strategy.”

6) Update and re-approve the strategy with version control

Operationalize versioning:

• Version number/date
• Summary of changes (“what changed and why”)
• Approval record (who approved, when, and in what forum)

Then cascade impacts:

• Update policy statements if the strategy changes direction (for example, third-party access requirements).
• Update the roadmap and control implementation plan.
• Update risk register residual risk and treatment plans when strategy choices shift.

7) Prove “coverage of organizational requirements and risks”

This is the heart of GV.OV-02. Coverage is easiest to defend with a mapping table:

Example mapping (minimum viable):

Organizational requirement/risk driver	Source	Strategy response	Program artifact
Customer security addendum requires MFA	Contract	“Identity-first” pillar prioritizes MFA enforcement	IAM standard + rollout plan
Critical SaaS concentration risk	TPRM	“Third-party resilience” pillar adds exit/BCP testing	Critical third-party register + tests
Recent phishing-led compromise attempt	Incident review	Prioritize email and identity hardening	Training + technical controls roadmap

You do not need perfect traceability across every control on day one. You need a defensible method that shows you check coverage and close gaps.

Required evidence and artifacts to retain

Retain artifacts that answer: “Was it reviewed, did it consider the right inputs, and what changed?”

Minimum evidence set:

• Cybersecurity risk management strategy document with version history.
• Strategy review procedure (cadence, triggers, required inputs, required attendees).
• Calendar invite/agenda and attendance record for each review.
• Input pack (risk register extract, incident summary, third-party risk summary, change log).
• Meeting minutes that capture decisions and rationale.
• Action tracker with owners and outcomes (roadmap updates, policy updates).
• Approval evidence (committee minutes, sign-off email, governance ticket).
• Mapping from requirements/risks to strategy priorities and to control roadmap.
• A record of out-of-cycle reviews triggered by major events (even if no changes were made).

Common exam/audit questions and hangups

Expect these questions and prepare answers with artifacts:

1. “Show me the last strategy review and what changed.”
   Hangup: no version diff, no decision log.
2. “What triggers an out-of-cycle review?”
   Hangup: triggers exist informally but not written.
3. “How do you know the strategy covers third-party risk?”
   Hangup: strategy talks about “security” but ignores third parties as a risk driver.
4. “Who approves the strategy, and how does leadership oversee it?”
   Hangup: no named approver; board/committee not engaged.
5. “How do strategy changes translate into funded work?”
   Hangup: roadmap not tied to strategy; remediation backlog unmanaged.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Treating the strategy as a once-a-year deck.
  Fix: publish a procedure with triggers and require decision-grade minutes.
• Mistake: No linkage to business requirements (contracts, products, M&A).
  Fix: add a “business change log” input section and require business stakeholder sign-off.
• Mistake: Updating language without updating execution artifacts.
  Fix: require roadmap/policy/risk register updates as closing steps for any strategy change.
• Mistake: No evidence package.
  Fix: standardize the input pack and store it with the minutes and versioned strategy.
• Mistake: Strategy says “we manage third-party risk,” but no operational proof exists.
  Fix: maintain a critical third-party inventory and show how it influenced strategy priorities.

Enforcement context and risk implications

NIST CSF is a framework, not a regulator, and the provided sources do not include public enforcement cases tied to GV.OV-02. The practical risk is indirect but real: if your strategy is stale, you will miss new obligations and exposures, and you will struggle to defend governance in customer audits, insurer due diligence, and regulator exams that evaluate risk management effectiveness.

Practical 30/60/90-day execution plan

First 30 days (stabilize the control)

• Name an executive owner and a GRC operator for GV.OV-02.
• Define what “strategy” includes for your organization (1–2 pages is fine).
• Write the strategy review procedure, including triggers and required inputs.
• Create the first input pack template and a decision-log template.
• Schedule the first formal review session and define approvers.

Days 31–60 (run the first review and generate artifacts)

• Collect inputs: risk register, incidents, third-party changes, major initiatives.
• Run the review meeting; capture decisions and action items.
• Update the strategy with version control and approvals.
• Produce the mapping table showing coverage of requirements/risks to strategy priorities.
• Push resulting actions into the roadmap and assign owners.

Days 61–90 (make it repeatable and audit-ready)

• Test an out-of-cycle trigger (tabletop or simulated trigger) and document the process.
• Add GV.OV-02 evidence collection to your recurring compliance calendar.
• Connect the strategy review outputs to policy management and risk acceptance workflows.
• If you use Daydream, configure the control record with owner, procedure link, evidence requests, and recurring reminders so collection and review stay consistent over time.

Frequently Asked Questions

What counts as a “cybersecurity risk management strategy” for GV.OV-02?

A documented statement of how your organization identifies, prioritizes, treats, and governs cyber risk, including priorities and decision rights. If you only have a project roadmap, add risk appetite language and a coverage mapping so it functions as a strategy.

How often do we need to review and adjust the strategy?

NIST CSF 2.0 does not prescribe a specific frequency in the provided excerpt ¹. Set a planned cadence that fits your change rate, and add clear event-driven triggers so material changes force a review.

Who should approve strategy changes?

The approver should be a leadership forum with authority over risk acceptance and resourcing (for example, an executive risk committee). Document the approver in the procedure and retain the approval evidence.

We reviewed the strategy and made no changes. Is that compliant?

Yes, if you can show the review occurred, the required inputs were considered, and the decision to keep the strategy unchanged was recorded with rationale. Auditors mainly challenge missing evidence and missing consideration of obvious change drivers.

How do we show “coverage of organizational requirements and risks” without building a massive mapping program?

Start with a focused mapping of your top requirements and top risks to strategy pillars and the program roadmap. Expand coverage over time, but make sure the method is consistent and reviewable.

Where does third-party risk fit into GV.OV-02?

Third-party dependence is a core driver of organizational risk and should appear in your strategy assumptions, priorities, and roadmap. Your evidence should include third-party risk inputs and show any strategic decisions made in response (for example, concentration risk reductions or contract control changes).

Footnotes

1. NIST CSWP 29

2. NIST CSF 1.1 to 2.0 Core Transition Changes