GV.RM-03: Cybersecurity risk management activities and outcomes are included in enterprise risk management processes

To meet the gv.rm-03: cybersecurity risk management activities and outcomes are included in enterprise risk management processes requirement, you must formally connect cybersecurity risk work (assessments, risk decisions, and results) to your ERM intake, scoring, reporting, and governance cadence. Operationally, that means shared taxonomy, defined handoffs, and repeatable evidence that cyber risk is reviewed and acted on alongside other enterprise risks.

Key takeaways:

• Cyber risk must enter ERM through the same “pipes” as other risks: intake, scoring, ownership, reporting, and acceptance.
• Evidence matters: you need traceability from cyber assessments to ERM entries, decisions, and follow-through.
• Assign explicit ownership for the integration, not just for cybersecurity controls.

GV.RM-03 is a governance requirement disguised as a process requirement: cybersecurity risk management cannot live in a parallel universe. If your security team runs risk assessments, tracks vulnerabilities, and briefs leadership, but ERM reporting ignores those outcomes, you will fail the intent of this requirement even if your security program is strong.

For a CCO, GRC lead, or ERM leader, the fastest path to operationalizing GV.RM-03 is to design a clean interface between cybersecurity risk management and ERM: define what qualifies as an “enterprise cyber risk,” translate cyber findings into the ERM risk taxonomy, route material items into the ERM register, and create a standing cadence where ERM governance bodies review cyber risk posture and decisions. That interface must be auditable. You should be able to show an examiner how a specific cyber risk was identified, scored, escalated (or not), owned, treated, and reported through ERM channels.

This page gives requirement-level implementation guidance anchored to NIST CSF 2.0 source text and transition guidance, with an operator’s focus on roles, steps, artifacts, and exam-ready evidence. ¹

Regulatory text

Requirement (GV.RM-03): “Cybersecurity risk management activities and outcomes are included in enterprise risk management processes.” ¹

What the operator must do: ensure cybersecurity risk work products (risk assessments, key risk indicators, incident learnings, control effectiveness outcomes, and risk acceptance decisions) are captured and governed through ERM mechanisms. Concretely, ERM should reflect cyber risk in its risk register (or equivalent), include cyber risk posture in its regular reporting, and record decisions with accountable owners and timelines.

Plain-English interpretation

You comply with GV.RM-03 when:

• Cyber risks are expressed in the same ERM language as other enterprise risks (risk statements, impact, likelihood, owner, treatment plan).
• Material cyber risks are visible to ERM leadership forums, not only to the CISO or security steering committee.
• ERM decisions (accept, mitigate, transfer, avoid) explicitly cover cyber risks, and cybersecurity provides the inputs and outcomes that justify those decisions.

If cybersecurity risk remains confined to security tooling dashboards, vulnerability lists, or a security-only risk register, you have a governance gap under GV.RM-03 even if controls are strong.

Who it applies to

Entity scope: any organization running a cybersecurity program where enterprise risk management exists or is expected (formal ERM function, risk committee, board risk reporting, internal audit risk universe). ²

Operational contexts where this requirement becomes “exam relevant”:

• Regulated firms with board-level risk oversight expectations (financial services, healthcare, critical infrastructure).
• Organizations with a formal ERM program, risk register, or internal audit planning based on enterprise risk ranking.
• Businesses with significant third-party reliance where cyber incidents can create enterprise operational and legal risk (payments, SaaS, manufacturing supply chain).

Roles typically involved:

• ERM owner (CRO, head of ERM): owns enterprise taxonomy, risk register structure, governance cadence.
• CISO / security risk lead: supplies cyber risk assessments, KRIs, incident and control outcomes, and treatment plans.
• CCO / GRC lead: ensures alignment with policy obligations, regulatory commitments, and audit readiness.
• Business risk owners: accountable for accepting and treating risks that affect their operations (including cyber risks).

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

Use this sequence to operationalize GV.RM-03 quickly and defensibly.

Step 1: Define the integration “contract” between cybersecurity and ERM

Document a short procedure (one to three pages) that answers:

• What is a “cyber risk” vs. an “IT issue” vs. a “control deficiency”?
• What triggers ERM intake (materiality thresholds, systemic exposure, repeated control failure, significant third-party exposure)?
• Who can submit, who must approve, and who owns the risk in ERM?

Practical tip: write this as a RACI plus a one-page workflow. Auditors want clarity on handoffs.

Step 2: Align risk taxonomy and scoring so cyber can be compared to other risks

Your ERM model likely uses impact and likelihood. Cyber teams often use different severity systems (CVSS, qualitative heat maps, control maturity). Map cybersecurity inputs to ERM scoring without destroying nuance:

• Define impact categories relevant to cyber (availability, confidentiality, integrity, safety, regulatory exposure, third-party disruption).
• Define likelihood factors (threat activity, control coverage, exposure window, dependency concentration).
• Create a translation table so a cyber assessment results in an ERM-compatible score and narrative.

Keep the mapping stable. Constant “score model churn” is an audit hangup because results stop being comparable over time.

Step 3: Create an ERM intake path for cybersecurity risk outcomes

Cyber risk management activities that should feed ERM include:

• Periodic cyber risk assessments (enterprise-wide, BU-specific, system-specific)
• Control effectiveness outcomes (testing, assurance, internal audit findings)
• Incident postmortems with root causes and residual risk
• Third-party security assessments that create enterprise exposure
• Risk acceptance requests that exceed security’s delegated authority

Mechanically, this means creating ERM records (risk register entries or issues linked to risks) with:

• Risk statement written in business language
• In-scope assets/processes and business owner
• Current controls and gaps
• Treatment plan, milestones, and target state
• Residual risk and acceptance rationale (if accepted)

Step 4: Establish a cadence where ERM governance reviews cyber risk

You need an operating rhythm where cybersecurity risk is reviewed alongside enterprise risks:

• Add cyber risk to the standard ERM reporting pack (top risks, trend, key drivers, notable acceptances, treatment status).
• Ensure cyber is discussed in the same committees that govern other enterprise risks (risk committee, exec risk forum).
• Document decisions, not just discussion: approvals, escalations, and required actions.

This is where many programs fail GV.RM-03: cyber reports exist, but they are not part of ERM’s decisioning system.

Step 5: Embed cyber risk into ERM outputs (not just inputs)

GV.RM-03 requires activities and outcomes. Outcomes include:

• Changes to enterprise risk profile driven by cyber events or assessments
• Updated risk appetite or tolerances that explicitly address cyber categories
• Approved risk treatments with assigned owners and tracked completion
• Accepted risks recorded in ERM with time bounds and review triggers

If ERM is used to set internal audit priorities, confirm cyber risks influence that planning. Traceability matters: “cyber briefed the board” is weaker than “ERM recorded and tracked.”

Step 6: Assign one accountable owner for the integration control

Treat GV.RM-03 like a control with an owner, a procedure, and recurring evidence. Your owner may sit in ERM or GRC, but they must have authority to enforce intake and reporting standards.

Where Daydream fits naturally: Daydream helps you map GV.RM-03 to policy, procedure, a control owner, and a recurring evidence collection routine, so audits don’t devolve into screenshot hunts and meeting-memory debates.

Required evidence and artifacts to retain

Keep artifacts that prove (1) the process exists, and (2) it operates.

Governance and process

• ERM-cyber integration procedure (workflow + RACI)
• Risk taxonomy/scoring mapping document between cyber assessments and ERM scoring
• Risk appetite/tolerance statements that include cyber risk categories, if your ERM program uses them

Operational records (choose representative samples)

• Risk register entries for cyber risks, with owners and treatment plans
• Meeting agendas/materials showing cyber risk included in ERM forums
• Minutes/decision logs showing approvals, acceptances, and assigned actions
• Risk acceptance records with rationale, approver, scope, and review triggers

Traceability packs (auditor-friendly)

• For selected cyber risks: source assessment → ERM entry → decision → treatment tracking → closure or periodic review
• Linkage between third-party findings and ERM risk entries where exposure is enterprise-level

Common exam/audit questions and hangups

What auditors ask

• “Show me your ERM risk register entries that originated from cybersecurity risk assessments.”
• “How do you decide which cyber risks are escalated into ERM vs. handled within security?”
• “Who owns cyber risks in ERM: the CISO or the business?”
• “Show evidence that ERM committees reviewed cyber risk posture and made decisions.”
• “How do you ensure cyber risk scoring is consistent with enterprise risk scoring?”

Common hangups

• ERM treats cyber as a “technology sub-risk” with no business owner.
• Cyber produces metrics, but ERM receives no risk statements, no residual risk, and no decision points.
• Risk acceptance happens in security with no ERM record, so enterprise leadership cannot see accumulated accepted risk.

Frequent implementation mistakes (and how to avoid them)

1. Maintaining two unlinked risk registers (security vs. ERM).
   Fix: define a single system of record for enterprise risks, and treat the security register as a feeder or working backlog.

2. Confusing vulnerability severity with enterprise risk.
   Fix: require a business-impact risk statement and an accountable business owner before ERM intake.

3. No defined escalation criteria.
   Fix: create criteria based on business service criticality, systemic exposure, third-party concentration, and inability to remediate within agreed timelines.

4. Cyber risk reporting without decisions.
   Fix: add decision fields to ERM reporting (accept/mitigate/transfer/avoid), and require documented approvals for acceptances above delegation.

5. Evidence gaps (“we discuss it, but nothing is written down”).
   Fix: standardize agendas, minutes, and decision logs; store them with the risk records they govern.

Enforcement context and risk implications

NIST CSF is a framework, not a regulator, and the provided sources do not include public enforcement actions tied to GV.RM-03. Your practical exposure is still real: if cyber risk is not incorporated into ERM, leadership decisions can be made on incomplete information, and auditors or regulators can characterize governance as ineffective. The operational risk is predictable: unmanaged risk accumulation, inconsistent acceptances, and missed cross-functional dependencies that turn security issues into enterprise incidents. ²

Practical 30/60/90-day execution plan

Because the source materials do not provide time-based benchmarks, treat this as a pragmatic sequencing plan, not a sourced timeline.

First 30 days (foundation and alignment)

• Name the GV.RM-03 control owner and approve a lightweight integration procedure.
• Inventory existing cyber risk outputs (assessments, KRIs, acceptance logs, incident postmortems).
• Agree on ERM intake triggers and an initial taxonomy/scoring mapping.
• Select a small set of “enterprise cyber risks” and create ERM risk register entries with business owners.

Days 31–60 (operationalize and prove repeatability)

• Add cyber risk to ERM committee agendas and reporting packs.
• Implement a standard ERM risk record template for cyber risks (risk statement, controls, gaps, treatment, residual risk).
• Pilot traceability packs for a few risks end-to-end (source → ERM entry → decision → treatment tracking).
• Train ERM analysts and security risk staff on the translation model and intake workflow.

Days 61–90 (scale and audit-proof)

• Expand intake to recurring sources (third-party findings, internal audit results, major projects, significant incidents).
• Formalize risk acceptance governance: delegation thresholds, approvers, and review triggers recorded in ERM.
• Add recurring evidence collection: committee minutes, risk register exports, acceptance logs, treatment status reports.
• Run an internal “mock exam” walkthrough: pick one cyber risk and demonstrate the full ERM lifecycle with artifacts.

Frequently Asked Questions

Do all cybersecurity findings have to go into the enterprise risk register?

No. GV.RM-03 expects cyber risk management outcomes to be included in ERM processes, not that every vulnerability becomes an enterprise risk. Define escalation criteria so only enterprise-relevant cyber risks enter ERM, and document that rule. ²

Who should own a cybersecurity risk in ERM, the CISO or the business?

ERM ownership should sit with the business leader accountable for the impacted process or service, with the CISO as a key stakeholder and subject matter expert. This prevents “IT-owned enterprise risk” and makes treatment plans executable.

We already brief cyber risk to the board. Is that enough for GV.RM-03?

Board briefings help, but GV.RM-03 is about inclusion in ERM processes. You need traceable records that cyber risks entered the ERM register (or equivalent), were scored consistently, and had documented decisions and follow-through. ²

How do we translate technical risk (like CVSS) into ERM scoring without losing fidelity?

Keep CVSS for technical triage, but require a separate ERM risk statement tied to business impact and exposure. Use a mapping table so cyber assessments produce ERM-compatible likelihood and impact ratings, then preserve technical detail in linked notes or attachments.

What evidence is most persuasive in an audit?

A traceability pack: a cyber risk assessment that produced an ERM risk entry, committee minutes showing review and a decision, and treatment tracking showing status over time. Auditors respond well to “one risk, end-to-end” proof plus a broader register extract.

How can Daydream help without turning this into a tooling project?

Use Daydream to map GV.RM-03 to a control owner, a short procedure, and a recurring evidence checklist. Start with your current ERM system of record, then use Daydream to keep artifacts organized and consistent across cycles.

Footnotes

1. NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes

2. NIST CSWP 29