GV.RR-02: Roles, responsibilities, and authorities related to cybersecurity risk management are established, communicated, understood, and enforced

To meet the gv.rr-02: roles, responsibilities, and authorities related to cybersecurity risk management are established, communicated, understood, and enforced requirement, you must assign clear cybersecurity risk ownership (who decides, who does, who approves), document it in governance artifacts, communicate it to affected teams, and prove it works through enforcement actions like access approvals, exception handling, and performance management.

Key takeaways:

• Define “authority” explicitly (decision rights, budget/priority, risk acceptance) and tie it to named roles, not teams.
• Auditors look for operational proof: approvals, meeting minutes, training attestations, and escalations, not org charts.
• Maintain a living RACI and risk-acceptance workflow that matches how work actually moves across security, IT, legal, and the business.

GV.RR-02 sits in the Governance function of NIST CSF 2.0 and is one of the fastest ways an assessor will decide whether your cybersecurity risk program is real or aspirational. If roles and authorities are fuzzy, risk decisions get made in side channels, controls drift, and incident response turns into improvisation.

This requirement is straightforward but commonly under-implemented. Many organizations can produce a security policy, an org chart, and a committee list. Far fewer can show consistent evidence that: (1) the right people are accountable for cybersecurity risk decisions, (2) those people understand their responsibilities, and (3) the organization enforces those responsibilities when delivery pressure rises.

This page gives requirement-level implementation guidance you can execute quickly: what to define, where to document it, how to socialize it, and what artifacts you need to retain for audits and internal assurance. It is written for a Compliance Officer, CCO, or GRC lead who needs a defensible operating model with evidence, not a theoretical governance diagram.

Regulatory text

Excerpt: “Roles, responsibilities, and authorities related to cybersecurity risk management are established, communicated, understood, and enforced.” (NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes)

Operator interpretation: You need a documented, working assignment of cybersecurity risk management duties and decision rights across leadership, security, technology, and the business. People must know what they own, and you must be able to show consequences and escalation paths when responsibilities are missed or when risk acceptance exceeds defined boundaries. (NIST CSWP 29)

Plain-English interpretation (what this requirement really demands)

GV.RR-02 asks four things, and you should treat them as four testable control objectives:

1. Established: Roles and responsibilities exist in writing (policy, standards, charters, job responsibilities, RACI).
2. Communicated: The right audiences receive the information (new hires, control owners, approvers, executives, third parties where relevant).
3. Understood: People can explain their role in practice (interviews match artifacts; approvals follow the model).
4. Enforced: The organization acts when responsibilities aren’t met (issues are tracked, exceptions are approved, access and change controls reflect authority, performance expectations are real).

A useful internal phrase is: “If we had to defend a risk decision six months from now, could we prove who had authority, what they approved, and why?”

Who it applies to (entity and operational context)

Entities: Any organization operating a cybersecurity program or aligning to NIST CSF 2.0, including regulated and non-regulated organizations that use CSF as the control baseline. (NIST CSWP 29)

Operational contexts where GV.RR-02 is examined hardest:

• Risk acceptance and exception handling: Who can accept residual risk, and at what level.
• Security control ownership: Who owns each control and provides evidence.
• Identity and access management: Who approves privileged access and segregation-of-duties conflicts.
• Vulnerability and patch governance: Who decides on deferrals, compensating controls, and timelines.
• Incident response: Who declares an incident, who approves customer notifications, who engages law enforcement/forensics.
• Third-party risk decisions: Who can onboard a third party with open findings, and who signs off on compensating controls.

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

Step 1: Define the minimum set of cybersecurity risk roles

Create a short list of roles that must exist for your environment. Avoid listing dozens of titles; auditors want clarity. Typical minimum roles to define:

• Board or delegated board committee (oversight)
• Executive risk owner (often CEO/COO/CRO depending on model)
• CISO / Head of Security (program leadership)
• CIO/CTO / IT leadership (technology execution)
• Business unit risk owners (risk acceptance for their processes)
• Control owners (named individuals for key controls)
• System/data owners (classification, access approvals)
• Legal/Privacy (notification and regulatory response authorities)
• Internal audit or independent assurance (testing authority)

Document role definitions in a Cybersecurity Governance Standard or Cybersecurity Risk Management Policy addendum that is easy to point to in an exam. (NIST CSWP 29)

Step 2: Write decision rights (authorities), not just responsibilities

For each role, specify:

• What they can approve (policy exceptions, risk acceptances, go-live with open issues)
• What they can block (production releases, onboarding a high-risk third party)
• What they can require (compensating controls, independent testing, retesting)
• Escalation triggers (material incidents, repeated control failures, unremediated critical findings)

This is where most programs fail: they describe “accountability” but not “authority.” Without authority, responsibility is performative.

Step 3: Build a RACI mapped to your control framework and key workflows

Create a RACI that ties directly to how cybersecurity risk is managed day to day. Minimum rows should include:

• Risk assessment (enterprise and system-level)
• Control design and control operation
• Evidence collection and review
• Exception/risk acceptance
• Vulnerability intake and remediation governance
• Incident response roles (commander, comms, legal, forensics)
• Third-party due diligence and ongoing monitoring

Keep the RACI aligned to the NIST CSF categories you report on so you can show traceability during assessments. (NIST CSWP 29)

Step 4: Operationalize “communicated and understood”

Pick mechanisms that create evidence without excess overhead:

• Add role/accountability to job descriptions for control owners and security leadership.
• Require control owner attestations (simple acknowledgment of responsibilities and evidence cadence).
• Include governance onboarding in new manager onboarding and security training for approvers.
• Publish governance artifacts in a controlled repository with read access for relevant teams.

During interviews, consistency matters: if your RACI says the business risk owner approves risk acceptance, your tickets and approvals must reflect that.

Step 5: Implement enforcement through workflow controls

Enforcement is easiest if systems require the “right” approvals:

• Configure your GRC/workflow tool so risk acceptance requires the correct approver based on risk tier.
• Require documented approval for exceptions (policy, vulnerability, access, change).
• Track overdue remediation with escalation to the defined authority.
• Link repeated non-compliance to performance management processes (without overstating punitive actions; focus on documented accountability).

If you use Daydream, set recurring evidence tasks per control owner, enforce due dates, and route exceptions to the correct authority with an immutable audit trail. This turns “enforced” into something you can demonstrate on demand.

Step 6: Prove it works with a quarterly governance test

Run a lightweight test that answers:

• Were risk acceptances approved by the correct authority?
• Did control owners provide evidence on schedule?
• Were overdue items escalated as defined?
• Did committees meet and record decisions?

Document results and corrective actions. This creates the practical “understood and enforced” evidence set auditors ask for. (NIST CSWP 29)

Required evidence and artifacts to retain

Use this as your audit-ready checklist:

Core governance artifacts

• Cybersecurity risk management policy/standard with role definitions and authorities (NIST CSWP 29)
• Cybersecurity governance charter(s) (security steering committee, risk committee) with membership and decision scope
• RACI matrix mapped to key cybersecurity risk workflows
• Delegation of authority matrix for risk acceptance and exceptions

Operational evidence

• Risk acceptance tickets/records with approver, rationale, compensating controls, and expiry/review date
• Exception register (policy exceptions, patch deferrals, access exceptions)
• Meeting agendas, minutes, and decision logs for governance forums
• Training/attestation records for control owners and approvers
• Evidence collection logs showing assigned owners and completion history

Assurance evidence

• Periodic governance effectiveness review (internal control test, audit, or management review)
• Issues register showing escalation and resolution for repeated ownership failures

Common exam/audit questions and hangups

Questions you should be ready to answer with artifacts:

• “Show me who can accept cybersecurity risk for a revenue system and where that authority is documented.”
• “How do you ensure control owners know what evidence they must produce?”
• “Provide an example where an exception was denied or escalated.”
• “How does your governance model apply to third-party onboarding decisions?”
• “If the CISO disagrees with a business owner, who is the tie-breaker?”

Hangups that trigger follow-ups:

• RACI exists but is not mapped to controls or workflows.
• Approvals happen in email/Slack with no controlled record.
• “Committee oversight” is claimed, but minutes don’t show decisions.
• Job titles changed and the RACI wasn’t updated.

Frequent implementation mistakes and how to avoid them

1. Mistake: Using an org chart as governance.
   Fix: Keep an org chart, but anchor GV.RR-02 in a delegation-of-authority and RACI tied to decisions (risk acceptance, exceptions, go-live). (NIST CSWP 29)

2. Mistake: Assigning responsibilities to teams, not people.
   Fix: Name role holders (by position, and optionally by name) and define backups. Update on role change.

3. Mistake: No enforcement mechanism beyond “policy says.”
   Fix: Implement workflow gating (who must approve) and maintain an exceptions register with expiry and review.

4. Mistake: Control owners don’t exist outside security.
   Fix: Assign control ownership to the function that operates the control (IT, engineering, HR, finance), with security providing oversight.

5. Mistake: Risk acceptance has no boundaries.
   Fix: Define thresholds for who can accept which risks and require time-bound acceptances with review.

Enforcement context and risk implications

NIST CSF is a framework, not a regulator, so GV.RR-02 does not map to a single penalty statement in the provided sources. Your risk is indirect but real: weak role clarity and weak enforcement become findings under whichever regulator or customer assurance regime you operate under (SOC 2, ISO 27001, sector rules), and they materially increase incident impact because escalation and decision-making slow down. (NIST CSWP 29)

Practical 30/60/90-day execution plan

First 30 days (stabilize governance)

• Inventory current artifacts: policies, committee charters, job descriptions, approval workflows.
• Identify the decisions that matter (risk acceptance, exceptions, privileged access, incident declaration).
• Draft a one-page delegation of authority for cybersecurity risk decisions and get executive sign-off.
• Publish a first-pass RACI for the top workflows and assign control owners.

Days 31–60 (make it operational and evidenced)

• Implement or refine exception/risk acceptance workflow with required approvers.
• Roll out control owner attestation and evidence collection schedule.
• Start decision logging for security/risk committees (agenda, minutes, action items).
• Train approvers and control owners on what they approve and what evidence they must provide.

Days 61–90 (prove “understood and enforced”)

• Run a governance effectiveness test: sample approvals, exceptions, and escalations.
• Remediate gaps: misrouted approvals, missing backups, outdated RACI entries.
• Bake governance checks into onboarding for new leaders and system owners.
• Establish a standing cadence to review role/authority changes after org changes and major incidents. (NIST CSWP 29)

Frequently Asked Questions

Do we need a formal RACI to satisfy GV.RR-02?

You need a clear, documented assignment of responsibilities and authorities; a RACI is the simplest way to show it. If you use another format, it must still map people to decisions and control operation in a way you can evidence. (NIST CSWP 29)

What does “authority” mean in practice?

Authority is decision rights: who can approve risk acceptance, grant exceptions, block releases, and require remediation or compensating controls. Document authority boundaries and show they are enforced through workflow approvals and escalation records. (NIST CSWP 29)

How do we prove roles are “understood” without running a big training program?

Use targeted attestations for control owners and approvers, and retain evidence from day-to-day workflows (approved exceptions, meeting minutes, escalations). Interviews during audits should match your artifacts and the approvals you can produce.

Our security team is small. Can one person hold multiple roles?

Yes, as long as you document the role stacking and manage conflicts (for example, independent review for high-risk approvals). Auditors focus on clarity and consistency of decision-making, not headcount.

How does GV.RR-02 apply to third-party risk decisions?

Define who can onboard a third party with open security findings, who can accept residual third-party risk, and who owns ongoing monitoring. Keep the approval trail and exceptions register as evidence of enforcement.

What should we do when the written RACI doesn’t match reality?

Update the governance artifacts to match how decisions are actually made, then adjust workflows so approvals follow the documented authority. A “paper RACI” that conflicts with tickets and meeting decisions creates audit exposure fast.