GV.RM-07: Strategic opportunities (i.e., positive risks) are characterized and are included in organizational cybersecurity risk discussions

Most cybersecurity risk programs are built to prevent bad outcomes: incidents, outages, fraud, regulatory findings, and customer harm. NIST CSF 2.0 GV.RM-07 expands the conversation. It expects you to also surface and manage “positive risks,” meaning uncertainty that could benefit the organization if handled deliberately. That includes opportunities created by new security capabilities (for example, stronger identity controls enabling product expansion), risk-informed technology modernization, or third-party ecosystem changes that open safer, faster ways to deliver services.

For a Compliance Officer, CCO, or GRC lead, the practical problem is simple: opportunities die in the gaps between security, product, finance, and ERM. GV.RM-07 pushes you to close that gap with a lightweight, auditable mechanism to characterize opportunities and include them in cybersecurity risk discussions. The exam-readiness angle is evidence. Auditors rarely accept “we talk about it informally.” They want artifacts that show the organization defined positive risk, evaluated it consistently, and routed it through governance.

This page gives you requirement-level implementation guidance you can put into a procedure, assign to an owner, and evidence on a recurring cadence.

Regulatory text

Requirement (GV.RM-07): “Strategic opportunities (i.e., positive risks) are characterized and are included in organizational cybersecurity risk discussions.” ¹

What the operator must do:

1. Characterize cybersecurity-related strategic opportunities in a consistent way (definition, attributes, assumptions, uncertainty, and expected value).
2. Include those opportunities in the same formal risk discussions where leadership reviews cybersecurity risk (committees, ERM reporting, executive/board updates), so decisions are documented and accountable. ²

Plain-English interpretation (what GV.RM-07 is really asking)

You need a documented method to identify and describe “upside” cybersecurity opportunities, then show that leadership actually discusses them as part of risk governance.

This is not a requirement to “take more risk.” It is a requirement to make upside visible and to treat it with the same discipline you apply to downside risk:

• clear ownership,
• decision rights,
• rationale,
• follow-through,
• and records.

What counts as a “strategic opportunity” in cybersecurity (examples you can use)

Use examples that map to business outcomes and governance decisions:

• Security capability enabling revenue: adopting stronger identity assurance that allows entry into regulated markets or higher-trust customer segments.
• Risk-informed modernization: moving a legacy system to a managed platform that reduces operational risk while improving release velocity.
• Third-party optimization: consolidating third parties to fewer, more secure providers to reduce exposure and improve resilience.
• Control investment with measurable benefit: expanding monitoring that reduces time-to-detect and also enables better customer reporting and contractual commitments.

Avoid labeling routine control work as an “opportunity” unless it connects to a strategic objective and requires a decision.

Who it applies to (entity and operational context)

GV.RM-07 applies to any organization running a cybersecurity program and governance process under NIST CSF 2.0, especially where:

• cybersecurity risk is reported to an executive risk committee, audit committee, or board;
• ERM processes exist (or are emerging);
• technology strategy includes major change (cloud migrations, M&A integration, digital product expansion);
• the organization depends on third parties for critical services or data processing.

Operationally, this requirement lands with:

• CISO/security leadership (content and technical framing),
• GRC/risk (taxonomy, workflow, records),
• ERM (alignment to enterprise risk language),
• Finance/Strategy (value framing),
• Product/IT (execution and dependency management).

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

Step 1: Define “positive cybersecurity risk” in policy language

Add a short section to your Cybersecurity Risk Management Policy (or ERM risk policy extension) that includes:

• a definition of “strategic opportunity/positive risk” in cybersecurity;
• scope (what types of initiatives qualify);
• decision authorities (who can approve, who recommends, who is consulted);
• documentation requirements (minimum fields, review cadence).

Keep it tight. The goal is consistent capture, not philosophy. ²

Step 2: Add an “Opportunity Register” alongside your risk register

Create a register (spreadsheet, GRC tool object, or ERM module) that mirrors your risk register structure so it is easy to govern.

Minimum recommended fields:

• Opportunity title and description (plain language)
• Strategic objective supported (link to business goal)
• Opportunity hypothesis (what must be true)
• Cybersecurity dependencies and prerequisites (controls, architecture, third parties)
• Uncertainty/volatility factors (what could change)
• Potential value (qualitative is acceptable; quantify where your org can defend the model)
• Potential downside/guardrails (what you will not accept)
• Owner (named person) and supporting teams
• Decision needed (approve/hold/reject) and required by date (business-driven)
• Status and next checkpoint
• Links to related risks (downside) and issues

This meets “characterized.” It also prevents opportunities from being hand-wavy.

Step 3: Establish intake sources and triggers

Define where opportunities come from, and bake it into existing workflows:

• Security architecture reviews and design authority outcomes
• Major project intake (cloud, new apps, network redesign)
• Third-party onboarding and renewal decisions
• Incident postmortems (opportunities to improve and enable new commitments)
• Control gap remediation plans that unlock business options
• M&A and divestiture planning

Add a simple trigger: “If a cybersecurity initiative could change business capability, customer commitments, market access, or operating model, log an opportunity.”

Step 4: Add opportunities to your recurring cybersecurity risk discussions

Update meeting charters and agendas so opportunities have a standing slot:

• Cybersecurity risk committee agenda item: “Strategic opportunities & decisions”
• ERM quarterly risk update: include top opportunities with status and dependencies
• Board/Audit Committee materials: include a short opportunities section where material

You do not need to bring every opportunity to the board. You do need to show they are included in organizational cybersecurity risk discussions at the right level. ²

Step 5: Create a decision workflow with documented outcomes

For each opportunity discussed, record one of:

• Advance (approved): define milestones, funding path, required security conditions
• Hold: define what evidence is needed to reconsider
• Reject: document rationale (misaligned strategy, unacceptable tradeoffs, insufficient capability)

Tie the decision to:

• named attendees,
• date,
• and next action owner.

This is where audit defensibility comes from.

Step 6: Integrate with downside risk management (don’t run two disconnected systems)

Opportunities often introduce new exposures. Link them:

• Opportunity record links to one or more risk records (e.g., “expansion to new market increases identity fraud exposure”).
• Track guardrails as risk treatment requirements (e.g., “no launch until MFA coverage meets defined threshold,” stated as a launch criterion rather than a vague goal).

Step 7: Evidence collection and recurring control operation

Assign a control owner (usually GRC) to:

• collect agendas, minutes, and decision logs each cycle;
• ensure the opportunity register is updated;
• track follow-through on “Advance” decisions;
• report overdue actions to the risk committee chair.

If you use Daydream, map GV.RM-07 to a named control owner, a procedure, and recurring evidence requests so meeting artifacts and decision records are collected on schedule and stored consistently for audit readiness.

Required evidence and artifacts to retain (audit-ready)

Retain evidence that proves both parts of GV.RM-07: characterization and inclusion in discussions.

Core artifacts

• Cybersecurity Risk Management Policy section defining positive risk/opportunities and governance routing
• Opportunity Register export (with required fields populated)
• Meeting agendas showing opportunities as a standing topic (risk committee, ERM sync, or equivalent)
• Meeting minutes/notes capturing opportunity discussions and decisions
• Decision log entries (Advance/Hold/Reject) with rationale and owner
• Follow-up tracking (actions, milestones, status updates)

Supporting artifacts (pick what fits your operating model)

• Architecture review summaries that generated opportunities
• Business cases or investment memos tied to opportunities
• Third-party assessments that motivated an opportunity (e.g., consolidation, new security features)
• Board or executive reporting excerpts where opportunities were included

Common exam/audit questions and hangups

Auditors and assessors tend to probe the same friction points:

1. “Show me your definition of positive risk and where it’s documented.”
   Hangup: teams talk about innovation but never define it in governance terms.

2. “Where do opportunities appear in your risk discussions?”
   Hangup: opportunities exist in project planning decks, not in risk forums.

3. “How do you ensure consistency of characterization?”
   Hangup: one-off narratives with no standard fields, no owner, and no assumptions.

4. “Who decides, and how is the decision recorded?”
   Hangup: “consensus” with no accountable approver and no documented outcome.

5. “How do you link opportunity decisions to cybersecurity conditions/guardrails?”
   Hangup: decisions lack measurable prerequisites, so security becomes an afterthought.

Frequent implementation mistakes (and how to avoid them)

Mistake 1: Treating this as a brainstorming exercise

Fix: require structured entries (owner, hypothesis, dependencies, guardrails). If it can’t be written clearly, it’s not ready for governance.

Mistake 2: Keeping opportunities outside ERM and risk committee rhythms

Fix: add a standing agenda item and a simple “top opportunities” rollup. Governance is the point of GV.RM-07. ²

Mistake 3: Confusing “opportunity” with “project”

Fix: an opportunity is a decision-relevant uncertainty with potential strategic benefit. A project is an execution plan. You can have one without the other, but governance must track the opportunity until it becomes a committed initiative or is rejected.

Mistake 4: No linkage to downside risk

Fix: require a field for “related risks introduced or reduced.” This keeps leadership from approving upside without seeing tradeoffs.

Mistake 5: No evidence trail

Fix: predefine evidence capture in the procedure. Daydream-style recurring evidence tasks are helpful because they remove reliance on individual memory and inbox archaeology.

Enforcement context and risk implications

NIST CSF is a framework, not a law by itself. Your enforcement exposure usually comes from sector regulations, contractual obligations, and how your organization represents its governance maturity to customers, auditors, and regulators. The risk of ignoring GV.RM-07 is practical:

• leadership decisions about security investments become less defensible;
• opportunities get approved without security guardrails, increasing operational and compliance risk;
• audits flag governance gaps (“risk management program is incomplete”) because upside risk is missing from documented discussions. ²

Practical 30/60/90-day execution plan

First 30 days (Immediate)

• Assign an owner for GV.RM-07 (GRC lead or risk manager) and an executive sponsor (CISO or CRO).
• Add a policy/procedure addendum defining strategic opportunities (positive risk) and required documentation fields. ²
• Stand up an Opportunity Register with minimum fields and a simple intake form.
• Update the cybersecurity risk committee charter or agenda template to include “Strategic opportunities” as a standing item.

By 60 days (Near-term)

• Run intake across key sources: architecture reviews, major initiatives, third-party renewals, and ERM topics.
• Populate an initial backlog of opportunities, then triage to a smaller set for leadership discussion.
• Hold a formal review meeting; record decisions (Advance/Hold/Reject) and capture rationale in minutes and the decision log.
• Build linkages: for each “Advance,” list required security prerequisites and related downside risks.

By 90 days (Operationalize and stabilize)

• Integrate opportunities into ERM reporting (quarterly pack) and security governance reporting (monthly/quarterly).
• Set a recurring evidence collection routine: register export, meeting artifacts, decision log updates.
• Quality-check: sample opportunity entries for completeness (owner, hypothesis, dependencies, guardrails, decision status).
• If you use Daydream, configure GV.RM-07 mapping to the policy section, control owner, and automated evidence reminders so the process survives turnover and calendar drift.

Frequently Asked Questions

What’s the difference between a “strategic opportunity” and a normal security improvement?

A strategic opportunity connects a cybersecurity change to a business objective and requires a governance decision under uncertainty. Routine improvements can stay in the security roadmap unless they change business capability, commitments, or risk appetite.

Do we need to quantify the financial upside for every opportunity?

No. Start with qualitative value plus clear assumptions and guardrails. Quantify only where your finance or strategy team can defend the model and leadership expects it.

Who should own the opportunity register, security or ERM?

GRC commonly owns the register mechanics and evidence, while security and business owners supply content. If ERM has a mature platform, keep ownership there but ensure cybersecurity governance forums review it.

How do we prove “included in organizational cybersecurity risk discussions” to an auditor?

Keep agendas showing the topic, minutes capturing what was discussed, and a decision log with outcomes and owners. A register alone is not enough; you need evidence of review and decisions. ²

Can opportunities include third-party changes, like switching providers?

Yes. Third-party ecosystem decisions often create positive risk (faster time to market, improved resilience) and also introduce new exposures. Characterize both and document governance review.

What if leadership doesn’t want to talk about “opportunity” in a risk meeting?

Rename the agenda item to fit your culture (for example, “Risk-informed strategic enablement”) but keep the same mechanics: documented opportunity entries, recurring review, and recorded decisions. The requirement is substance and evidence, not a label. ²

Footnotes

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

2. NIST CSWP 29