GV.SC-09: Supply chain security practices are integrated into cybersecurity and enterprise risk management programs, and their performance is monitored throughout the technology product and service life cycle

GV.SC-09 requires you to embed supply chain security into your cybersecurity program and enterprise risk management (ERM) program, then continuously measure whether those supply chain controls work across the full product and service life cycle. Operationalize it by assigning ownership, integrating third-party and supplier risks into ERM, defining performance metrics, and collecting recurring evidence. ¹

Key takeaways:

• Treat supply chain security as a first-class risk domain in both cyber governance and ERM, not a procurement-only workflow. ¹
• Build life-cycle controls that start at intake and continue through renewals, changes, incidents, and offboarding, with monitoring and metrics. ¹
• Audit-readiness depends on traceability: requirement-to-policy mapping, control owners, and repeatable evidence collection. ²

GV.SC-09 is a governance requirement, not a technical configuration item. If your supply chain security practices live only in a third-party risk management (TPRM) questionnaire, you will fail the intent. NIST CSF 2.0 expects supply chain security to be integrated into how you run cybersecurity and how leadership governs enterprise risk, with performance monitored over time, across the technology product and service life cycle. ¹

For a Compliance Officer, CCO, or GRC lead, “integrated” translates into concrete program mechanics: documented ownership, a single risk taxonomy shared by cyber and ERM, risk acceptance and escalation paths, and management reporting that shows whether supply chain controls are operating. “Monitored throughout the life cycle” means you do not stop at onboarding. You track changes in supplier posture, contract obligations, product updates, incidents, and end-of-life transitions, and you can prove you did it with retained artifacts. ¹

This page focuses on fast operationalization: what to build, who must participate, what evidence you need for auditors, and where programs commonly break in real organizations.

Regulatory text

Excerpt (GV.SC-09): “Supply chain security practices are integrated into cybersecurity and enterprise risk management programs, and their performance is monitored throughout the technology product and service life cycle.” ¹

Operator interpretation (what you must do):

1. Integrate supply chain security into the governance and operating rhythm of (a) cybersecurity and (b) ERM, so risks are identified, assessed, treated, accepted, and reported the same way other enterprise risks are handled. ¹
2. Monitor performance of supply chain security controls continuously across the technology life cycle, not just at onboarding, with defined measures and recurring evidence. ¹
3. Make it auditable by mapping GV.SC-09 to policy, procedure, control owners, and repeatable evidence collection. ²

Plain-English interpretation of the requirement

You need a program where third-party and supplier security risks are:

• Part of cyber governance: owned, controlled, tested, and reported like any other cybersecurity risk. ¹
• Part of ERM: captured in the enterprise risk register (or equivalent), assigned inherent/residual ratings, and escalated to the right risk forum. ¹
• Measured over time: you track whether suppliers meet obligations (security controls, incident notice, patching, access governance, SBOM where applicable, subcontractor flow-downs) from intake through renewal and offboarding, and you respond when performance drops. ¹

Who it applies to (entity and operational context)

Applies to: any organization operating a cybersecurity program that depends on external technology products or services. ¹

Common in-scope relationships:

• SaaS, IaaS/PaaS, managed service providers, IT outsourcing
• Software publishers and open-source dependencies embedded in products
• Hardware and network equipment suppliers
• Data processors, call centers, payroll/HR platforms
• Professional services with privileged access (consultants, integrators)

Operational contexts where auditors focus:

• High-impact systems, regulated data, critical business services
• Concentration risk (single provider supports multiple critical functions)
• Subcontractor chains (fourth parties) and marketplace add-ons
• Fast procurement paths (startups, pilots, “shadow SaaS”)

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

1) Establish governance and ownership (integration starts here)

• Name a control owner for GV.SC-09 (often Head of TPRM, Security GRC, or Risk Management) and document RACI across Security, Procurement, Legal, Privacy, Product, IT, and ERM. ²
• Define decision rights: who can approve onboarding, who can accept risk, who can grant exceptions, and when the CISO/CCO/ERM committee must review. ¹
• Create a single intake path so Procurement does not bypass risk review (tie purchasing channels to required TPRM steps).

Deliverable: GV.SC-09 control statement + RACI + risk acceptance workflow.

2) Embed supply chain risk into ERM mechanics

• Align taxonomy: map supplier risks into your ERM categories (e.g., cyber, operational resilience, legal/regulatory, financial, strategic).
• Write risk register entries for top suppliers and systemic dependencies (cloud provider, identity provider, payments processor), including inherent risk, key controls, residual risk, and risk owner. ¹
• Define escalation triggers (examples: critical finding unresolved, major incident, repeated SLA failures, material change in service, acquisition, sanctions exposure). Keep triggers explicit so escalation is repeatable.

Deliverable: ERM risk register entries and escalation criteria for supply chain risks.

3) Build life-cycle controls (not just onboarding)

Create a “life-cycle control map” that ties each stage to required activities and evidence.

Minimum life-cycle stages to cover:

• Pre-contract / intake: classification, inherent risk scoring, due diligence scope, security requirements.
• Contracting: security addendum, right-to-audit, incident notification, subcontractor flow-downs, access terms, data handling.
• Implementation/change: architecture review, access provisioning, logging/monitoring hooks, change management integration.
• Operate/monitor: periodic reassessment, continuous monitoring signals, KPI/KRI tracking, issue management.
• Incident: coordinated response, notification timelines per contract, lessons learned fed into ERM.
• Renew/offboard: reassessment, exit plan, data return/destruction attestations, access removal, continuity planning.

Deliverable: Supplier life-cycle procedure with stage gates and control checklists. ¹

4) Define performance monitoring (make “monitored” measurable)

Pick a small set of KPIs/KRIs that reflect control performance and business impact. Avoid vanity metrics.

Examples you can defend in audits:

• Due diligence completion status for in-scope third parties (by risk tier)
• Time to remediate critical supplier issues (by severity)
• Contract coverage for key clauses (incident notice, audit rights, subcontractor requirements)
• Reassessment and renewal completion status
• Exceptions count, aging, and approval level
• Incidents attributable to third parties and post-incident corrective actions

Run these metrics through your cyber governance forums and your ERM forums so integration is visible in minutes and reporting packs. ¹

Deliverable: KPI/KRI definitions, reporting cadence, and governance minutes showing review.

5) Build evidence collection as a recurring control

Auditors will ask, “Show me.” Prepare evidence flows that are repeatable.

• Create an evidence register: artifact name, owner, frequency, system of record, retention period (set by your policy), and sampling approach.
• Automate where you can: ticketing, GRC workflows, contract repository tags, and continuous monitoring feeds.

Daydream fits naturally here as the system to map GV.SC-09 to your policy and procedures, assign control owners, and run recurring evidence requests with a clean audit trail, instead of ad hoc spreadsheets and inbox chasing. ²

Required evidence and artifacts to retain

Use this as a minimum evidence checklist.

Evidence	What it proves for GV.SC-09	Owner (typical)
Supply chain / third-party risk management policy mapped to GV.SC-09	Integration into the cyber program	Security GRC
ERM methodology showing third-party risk category + sample risk register entries	Integration into ERM	Enterprise Risk
RACI + risk acceptance and exception procedure	Defined accountability and decisioning	Compliance / Risk
Supplier inventory with criticality/risk tiering	Defined scope and prioritization	Procurement + TPRM
Due diligence packages for sampled third parties	Life-cycle “intake” operation	TPRM
Contract templates / executed addenda with security clauses	Requirements embedded into contracting	Legal
Reassessment schedule + completed reassessments	Monitoring through life cycle	TPRM
KPI/KRI dashboard + meeting minutes where reviewed	Performance monitoring and governance	CISO office / ERM
Issues log (findings, remediation plans, closures)	Corrective action and follow-through	TPRM + Security
Offboarding checklists (access removal, data disposition)	End-of-life control operation	IT + Privacy

Common exam/audit questions and hangups

“Where is the integration with ERM documented?”
Auditors want to see third-party risks in the enterprise risk register and evidence they are reviewed in ERM forums. Meeting minutes matter. ¹

“How do you monitor supplier performance after onboarding?”
If you only have an annual questionnaire, expect pushback. Show reassessments, continuous monitoring signals, SLA reporting, incident learnings, and issue management. ¹

“How do you cover the full life cycle?”
They will sample: a new supplier, a renewed supplier, a supplier with a major change, and an offboarded supplier. Missing the last two is common.

“Who can accept supplier risk?”
If Procurement or a project manager accepts risk informally, that is a governance gap. Document approval levels and exception tracking.

Frequent implementation mistakes and how to avoid them

1. TPRM is isolated from ERM.
   Fix: require ERM entries for critical suppliers and concentration risks; route metrics to ERM committees. ¹

2. One-and-done onboarding.
   Fix: implement reassessment triggers tied to renewal, material change, incidents, and critical findings.

3. No control ownership.
   Fix: assign a named control owner and define RACI; store it centrally and review during annual policy refresh. ²

4. Contracts don’t match security expectations.
   Fix: standard security addendum with fallback language and an exception path that requires risk acceptance.

5. Evidence is scattered.
   Fix: maintain an evidence register and automate collection workflows (a GRC platform like Daydream helps you keep this audit trail consistent). ²

Enforcement context and risk implications

NIST CSF is a framework, not a regulator, so enforcement usually arrives indirectly through sector regulators, contractual obligations, customer audits, and post-incident scrutiny. Your practical risk is that a third-party incident exposes you to claims of weak governance if you cannot show integration with ERM and ongoing monitoring artifacts. ¹

A practical 30/60/90-day execution plan

First 30 days (stabilize scope and ownership)

• Assign GV.SC-09 control owner and publish RACI. ²
• Produce a scoped supplier inventory with risk tiering and identify critical suppliers.
• Define ERM integration points: which committee, which report, which risk register fields.

Days 31–60 (build life-cycle controls and reporting)

• Document life-cycle procedure with stage gates: intake, contracting, change, operate, incident, offboard. ¹
• Standardize security contracting language and the exception path.
• Stand up a KPI/KRI dashboard and schedule recurring governance review in both cyber and ERM forums. ¹

Days 61–90 (operate, test, and harden evidence)

• Run sampling: pick a set of third parties across tiers and walk them through onboarding, reassessment, and change triggers.
• Validate evidence completeness and fix weak spots (missing minutes, missing risk acceptances, contract gaps).
• Implement recurring evidence workflows in your GRC system (Daydream) so audits do not become a manual scramble. ²

Frequently Asked Questions

Does GV.SC-09 require continuous monitoring tools for all third parties?

GV.SC-09 requires performance monitoring across the life cycle, but it does not prescribe a specific tool. Many teams combine periodic reassessment, contract/SLA monitoring, and targeted continuous monitoring for critical suppliers. ¹

What counts as “integration into ERM” in practice?

Auditable integration usually means supplier risks appear in the enterprise risk register with owners, ratings, and treatment plans, and that ERM governance bodies review material supplier risks. Keep minutes and reporting packs. ¹

How do we handle fourth parties (subcontractors)?

Treat them as part of supply chain risk: require flow-down obligations in contracts, request visibility into critical subcontractors, and escalate when a supplier cannot meet transparency or notification expectations. ¹

Our procurement team owns third-party onboarding. Can Security still satisfy GV.SC-09?

Yes, if cybersecurity and ERM requirements are embedded as mandatory stage gates with defined decision rights and evidence. Procurement can run the workflow, but risk acceptance and monitoring must be governed through cyber and ERM. ¹

What’s the minimum evidence set an auditor will expect?

Expect to show a mapped policy/procedure, an inventory with tiering, due diligence records, contract security terms, reassessments or monitoring records, and governance reporting that reaches ERM. Missing any one of these usually creates a control design or operating effectiveness gap. ²

How do we operationalize this if we have many SaaS tools adopted by departments?

Start by reconciling spend and SSO logs to build a complete inventory, then enforce an intake gate for new tools and bring the highest-risk existing tools into the life-cycle process first. Use exceptions with time-bound remediation plans so work can continue under documented risk acceptance. ¹

Footnotes

1. NIST CSWP 29

2. NIST CSF 1.1 to 2.0 Core Transition Changes