GV.RM-05: Lines of communication across the organization are established for cybersecurity risks, including risks from suppliers and other third parties

GV.RM-05 requires you to establish and run clear, repeatable communication paths so cybersecurity risks move quickly between teams, leadership, and the people managing third-party relationships. To operationalize it, define who reports what risk to whom, by when, in what format, and prove it with routable artifacts (RACI, escalation matrix, meeting minutes, and third-party risk reporting).

Key takeaways:

• Document end-to-end cybersecurity risk communication paths, including supplier and other third-party risks, with named owners and escalation triggers.
• Operationalize communication through recurring forums, defined reporting outputs, and incident/issue escalation procedures that include Procurement/TPRM.
• Retain evidence that communication happens (not just policy), and test it with tabletop exercises and post-incident reviews.

GV.RM-05 sits in the “Govern” function of NIST CSF 2.0 and is a requirement about organizational plumbing: how cybersecurity risk information actually travels. Most programs fail this requirement in a predictable way. They have risk registers, vendor reviews, and security tools, but no defined pathway to move material findings from Security to Procurement, from TPRM to system owners, and from operations to executives fast enough to change decisions.

For a Compliance Officer, CCO, or GRC lead, the fastest route to “done” is to treat GV.RM-05 as a communications control with measurable outputs. You’re building (1) role clarity (who must communicate), (2) routing clarity (where risk goes), (3) timing clarity (how fast, and on what cadence), and (4) proof (what artifacts show it’s working). The third-party element is non-negotiable: supplier incidents, SaaS misconfigurations, critical vulnerabilities in provider infrastructure, and contract gaps must have a path to your internal decision-makers.

This page gives requirement-level implementation guidance you can execute immediately, with a step-by-step build, an evidence list, common audit traps, and a practical plan.

Regulatory text

Requirement (GV.RM-05): “Lines of communication across the organization are established for cybersecurity risks, including risks from suppliers and other third parties.” ¹

Operator interpretation: You must define and operate formal communication pathways so cybersecurity risks are identified, routed, escalated, and resolved across business functions. Those pathways must explicitly include third-party risk signals (for example, supplier incidents, control deficiencies, contract/SLA gaps, and concentration risk) and ensure they reach the right decision-makers in time to act.

Plain-English interpretation (what “good” looks like)

You meet GV.RM-05 when:

• People know where to send cybersecurity risks and what happens next.
• Cyber risk information moves between Security, IT, Legal, Procurement/TPRM, Privacy, Engineering, and business owners without bottlenecks.
• Third-party risk isn’t trapped in a vendor questionnaire folder; it is communicated to system owners and leadership in a consistent, decision-ready format.
• Escalations happen based on defined triggers (severity, business impact, regulatory exposure, affected data, critical vendor status).
• You can show auditors evidence of communication (reports, minutes, tickets, escalations), not just a policy statement.

Who it applies to (entity and operational context)

Applies to: Any organization running a cybersecurity program that must govern risk across multiple functions ².

Most relevant operational contexts:

• Central security team with distributed IT/engineering delivery.
• Regulated environments (financial services, healthcare, critical infrastructure) where third-party incidents and reporting obligations must route quickly to Legal/Compliance.
• Heavy SaaS/outsourcing environments where material operations depend on third parties.
• M&A, rapid vendor onboarding, or decentralized purchasing, where shadow IT creates communication gaps.

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

Step 1: Define your risk communication “objects”

Pick a small set of items that must be routable across the org. Keep it tight so teams comply.

• Risk acceptance requests (including third-party exceptions).
• Third-party assessment findings (gaps, missing controls, high residual risk).
• Third-party incidents and near misses (breach notices, outages, suspicious activity).
• Material vulnerabilities/exposures that affect critical third parties or services you rely on.
• Contractual/security addendum deviations (refused clauses, missing audit rights, weak SLAs).

Deliverable: “Cyber Risk Communication Standard” (1–2 pages) listing the objects and required fields.

Step 2: Create a communication map (RACI + routes)

Build a single table that answers: who initiates, who approves, who must be informed, and how it escalates. Include third-party stakeholders explicitly: Procurement, TPRM/Vendor Management, Legal, and the business owner for the service.

Minimum routes to define:

• Security → TPRM/Procurement (findings that require contract action)
• TPRM → System Owner (risk in the vendor supporting their system)
• Security/IT → Legal/Compliance (reportable incident indicators; contractual notice requirements)
• Security → Executive Risk Committee/Board reporting channel (material risks and trends)
• Any employee → Security (intake channel for suspected vendor incidents or risky behavior)

Deliverable: RACI + escalation matrix (owned by GRC or Security Governance).

Step 3: Set escalation triggers (so it’s not subjective)

Define triggers that force routing, regardless of personal judgment. Examples:

• Third party supports a critical business process.
• Third party processes sensitive data (customer, employee, regulated data).
• High residual risk after assessment, or repeated failure to remediate.
• Incident notice received from a supplier or subcontractor.
• Contract deviates from baseline security requirements (no audit rights, weak breach notice).

Deliverable: Written trigger list mapped to actions (inform, escalate, pause onboarding, require remediation plan, require risk acceptance).

Step 4: Operationalize with recurring forums and standard outputs

Define the standing meetings (or equivalent async approvals) where cyber risk communications are reviewed and decisions are recorded.

Recommended operating model:

• Weekly/biweekly triage: GRC + Security + TPRM review new third-party findings and decide routing.
• Monthly risk review: trend reporting, top risks, overdue remediation, key third-party issues.
• Quarterly executive reporting: material cyber risks, third-party concentration/systemic risks, major exceptions.

Deliverables:

• Meeting agendas with defined sections for third-party risk
• Decision logs (approve, reject, accept, remediate, renegotiate contract)
• Action item tracker with owners and due dates

Step 5: Embed communications into workflows (tickets, intake, and contract gating)

Policies do not move information; workflows do.

• Add a third-party risk intake form (e.g., in GRC tool or ticketing) that routes to Security + TPRM.
• Require a security review gate in onboarding for specific categories (criticality/data type).
• Create a vendor incident intake process: who receives notifications, how they get logged, and who is paged.
• Tie exceptions to formal risk acceptance with approvers defined (business owner + security + compliance as needed).

Deliverables: Intake form, ticket queue, onboarding checklist, risk acceptance workflow.

Step 6: Prove it works (test and adjust)

Run tabletop exercises that include third parties. Example scenario: “Key SaaS provider reports a security incident; outage plus potential data exposure.”

• Confirm routing works from vendor notice → Security → Legal/Compliance → business owner → exec comms.
• Validate contractual notice timelines are understood internally.
• Capture lessons learned and update triggers/routes.

Deliverable: Tabletop report and updated comms map.

Required evidence and artifacts to retain

Auditors will ask for proof that communication lines exist and operate. Keep artifacts that show both design and performance.

Design evidence (static):

• Cyber Risk Communication Standard (scope, objects, required fields)
• RACI matrix for cyber risk communications
• Escalation matrix and trigger criteria
• Third-party incident communications procedure
• Third-party onboarding/security review procedure
• Risk acceptance procedure including third-party exceptions

Operating evidence (dynamic):

• Samples of third-party assessment reports routed to stakeholders
• Ticket/export showing third-party risk intake through closure
• Meeting minutes/decision logs with third-party risk topics
• Executive/board reporting packets including third-party risk content
• Incident communications logs for third-party events (timestamps, recipients, decisions)
• Tabletop exercise materials and after-action report

Common exam/audit questions and hangups

Expect these questions (and have a crisp artifact ready):

1. “Show me how third-party risk findings reach the business owner.”
   Hangup: Findings stay in Security/TPRM. Fix: route to system owner with required acknowledgement/plan.
2. “Who can accept third-party cyber risk, and where is it recorded?”
   Hangup: informal email approvals. Fix: standardized risk acceptance record with approver roles.
3. “How do supplier incidents get escalated to Legal/Compliance?”
   Hangup: notices go to a shared inbox with no SLA. Fix: defined monitoring + paging/escalation.
4. “Show evidence this runs on a cadence.”
   Hangup: meetings happen ad hoc. Fix: standing agendas, minutes, and action tracking.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Writing a policy that says “we communicate” without routes.
  Avoid it: publish a one-page route map plus triggers and owners.
• Mistake: Treating Procurement/TPRM as optional recipients.
  Avoid it: make TPRM a default stakeholder for third-party risks and contract deviations.
• Mistake: No defined “decision record.”
  Avoid it: require a decision log entry for accept/remediate/renegotiate/terminate outcomes.
• Mistake: Assuming incident response covers supplier incidents automatically.
  Avoid it: add supplier notification intake, contract notice checks, and customer comms coordination steps.
• Mistake: Over-engineering severity models that nobody follows.
  Avoid it: start with simple triggers tied to criticality, data sensitivity, and incident events.

Enforcement context and risk implications

NIST CSF 2.0 is a framework, not a regulator, so this requirement is typically enforced indirectly: customers, auditors, and regulators evaluate whether your governance actually routes risk to decision-makers. The operational risk is straightforward: if third-party incidents or assessment gaps do not reach Legal/Compliance and business owners quickly, you lose time for containment, notification analysis, contract enforcement, and executive decision-making. That delay can create downstream regulatory exposure under other regimes, but GV.RM-05 itself is your governance control that prevents the “we didn’t know” failure mode. ²

Practical 30/60/90-day execution plan

First 30 days (establish the minimum viable routes)

• Identify stakeholders: Security, GRC, TPRM/Procurement, Legal, Privacy, IT/Engineering, key business owners.
• Draft and approve: RACI + escalation matrix with third-party triggers.
• Stand up: third-party risk intake channel and vendor incident intake channel.
• Start evidence: begin capturing meeting minutes/decision logs.

Days 31–60 (make it operational and repeatable)

• Implement onboarding gates for critical/high-data third parties.
• Standardize reporting outputs: third-party findings template and risk acceptance template.
• Launch recurring forums: triage and monthly risk review with fixed agenda sections for third-party risks.
• Train stakeholders: short role-based training on “what to send, where, by when.”

Days 61–90 (prove performance and harden)

• Run a tabletop exercise that includes a supplier incident path and executive comms routing.
• Audit a sample set of third-party assessments for evidence of routing, decisions, and remediation tracking.
• Tune triggers and thresholds based on friction points and missed escalations.
• Package “audit-ready” evidence: index of artifacts, samples, and a narrative walkthrough.

Tooling note (where Daydream fits)

If your bottleneck is evidence and routing discipline, Daydream can help by mapping GV.RM-05 to a named control owner, linking the requirement to policies and procedures, and automating recurring evidence collection so you can show that communications happened and decisions were recorded. This aligns with the recommended control approach of mapping GV.RM-05 to policy, procedure, control owner, and recurring evidence collection. ¹

Frequently Asked Questions

Does GV.RM-05 require a dedicated “cyber risk committee”?

No. It requires established lines of communication that operate in practice. A committee is one way to do that, but you can also meet the requirement with defined routes, escalation triggers, and decision records.

What counts as “third parties” for this requirement?

Treat any external entity that can affect your confidentiality, integrity, or availability as a third party, including SaaS providers, contractors, consultants, partners, and key suppliers. Ensure your communication routes explicitly include TPRM/Procurement and business owners for those relationships.

How do we prove “lines of communication” to an auditor?

Show the design (RACI, escalation matrix, procedures) and show operation (tickets, minutes, decision logs, incident comms logs). Auditors typically want samples that demonstrate routing, escalation, and documented outcomes.

Our procurement team owns vendor management. Does Security still need to be involved?

Yes, for cybersecurity risks. Procurement can own the relationship and contracting workflow, but Security/GRC must have a defined path to receive vendor risk signals and to communicate required security actions back to Procurement and the business.

What’s the minimum viable artifact set if we’re behind?

Start with a one-page RACI plus escalation matrix, a third-party incident intake procedure, and a decision log template. Then collect a small set of completed examples to prove the process runs.

How do we handle “shadow IT” vendors that bypass TPRM?

Add an intake/reporting path for employees and IT to flag unapproved third parties, and route those to TPRM plus the system owner for remediation. Tie it to contract gating and access controls so unreviewed third parties cannot easily persist.

Footnotes

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

2. NIST CSWP 29