ID.IM-04: Incident response plans and other cybersecurity plans that affect operations are established, communicated, maintained, and improved

ID.IM-04 requires you to have incident response and other cybersecurity operational plans formally defined, communicated to the people who must execute them, kept current, and continuously improved based on lessons learned and change. Operationalize it by assigning owners, defining plan scope tied to critical services, running exercises, tracking updates, and retaining evidence of adoption.

Key takeaways:

• You need more than a written incident response plan; you need a managed lifecycle: publish, train, test, update, repeat.
• “Other cybersecurity plans that affect operations” includes continuity, disaster recovery, ransomware, crisis communications, and third-party response playbooks.
• Audit readiness depends on evidence: approvals, training, exercises, after-action items, and version-controlled updates (not PDFs that never change).

The target keyword for this page is id.im-04: incident response plans and other cybersecurity plans that affect operations are established, communicated, maintained, and improved requirement. For a CCO, Compliance Officer, or GRC lead, the practical challenge is not writing a plan. It is proving the plan is operational: the right teams know their roles, escalation paths work under stress, and the plan evolves as your environment changes.

ID.IM-04 sits in NIST CSF 2.0’s Identify function and focuses on implementation management: the discipline of making cybersecurity “real” inside operations, not a shelf artifact. Your exam risk is straightforward. If you cannot show that plans exist, were communicated, are current for today’s systems and third parties, and were improved after exercises or incidents, an assessor can reasonably conclude the control is not operating.

This page gives requirement-level implementation guidance: who owns what, what artifacts to produce, how to build a plan inventory that includes non-IR cybersecurity plans, and how to create a repeatable update loop that stands up in audits and post-incident reviews.

Regulatory text

Requirement excerpt: “Incident response plans and other cybersecurity plans that affect operations are established, communicated, maintained, and improved” (NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes).

Operator interpretation (what you must do):

1. Established: Create documented, approved plans for incident response and other operational cybersecurity scenarios (for example, disaster recovery and crisis communications) that reflect how your organization actually runs.
2. Communicated: Ensure the people who must execute the plans have access, understand their responsibilities, and know how to trigger escalations.
3. Maintained: Keep plans current with systems, org structure, third parties, and tooling. Version control and review triggers matter.
4. Improved: Update plans based on exercises, real incidents, near misses, and material changes to operations (NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes).

Plain-English interpretation of the requirement

ID.IM-04 is a lifecycle requirement. Auditors will treat a plan as ineffective if it is outdated, untested, unknown to responders, or disconnected from how you deliver critical services.

The phrase “other cybersecurity plans that affect operations” is where many programs fail. It means incident response is necessary but not sufficient. You should expect to maintain a set of operationally meaningful plans, such as:

• Incident Response Plan (IRP) and severity classification
• Ransomware/extortion playbook (including decision support and evidence handling)
• Disaster Recovery (DR) and IT service restoration runbooks
• Business Continuity (BCP) interfaces that rely on cyber-triggered outages
• Crisis communications plan (internal, customer, regulator, law enforcement)
• Third-party incident coordination plan (SaaS outages, MSP compromise, data processor breach)
• Vulnerability/patch emergency change plan (for exploited vulnerabilities)

Who it applies to (entity and operational context)

Applies to: Any organization running a cybersecurity program aligned to NIST CSF 2.0, including regulated and non-regulated entities, because the control is framed as a framework expectation rather than a sector rule (NIST CSWP 29).

Operational contexts where it becomes “exam material”:

• You provide critical services (payments, healthcare delivery, manufacturing, logistics) where downtime or data loss triggers operational harm.
• You depend on third parties for core systems (cloud hosting, identity provider, EDR/MDR, MSP, payroll, claims processing).
• You have distributed operations (multiple sites, call centers, plants) where communications and authority boundaries complicate response.

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

1) Build a “cyber operations plan inventory”

Create a register of operational cybersecurity plans. Keep it small enough to manage, but complete enough to cover operational risk. For each plan, record:

• Plan name and scope (systems/services covered)
• Owner (accountable) and deputies
• Audience (who must know it)
• Activation criteria (what triggers the plan)
• Dependencies (IR tooling, IAM, backups, third parties)
• Review triggers (org changes, new systems, major vendor change)
• Last review date and change log location

Practical tip: treat this like a control library entry, not a document repository. The inventory is how you prove governance.

2) Define minimum content standards per plan

Set a template so plans are consistent and executable. Minimum sections that usually hold up under scrutiny:

• Purpose, scope, assumptions, and exclusions
• Roles and decision rights (who can declare a major incident; who can take systems offline)
• Escalation paths and contact methods (primary/secondary, including after-hours)
• Technical workflows (containment, forensics, restoration, validation)
• Communications workflows (internal leadership, employees, customers, third parties)
• Evidence handling and documentation expectations
• Post-incident review and improvement workflow

3) Formally approve and publish

Establish the plan with:

• A documented approval workflow (Security leader + IT Ops + Legal/Privacy + Comms as applicable)
• Controlled distribution (read-only repository, versioned)
• A method for emergency updates when contact lists or tooling change

Avoid “approval theater.” Approvers must understand their operational obligations in the plan.

4) Communicate with role-based training

Communication means more than emailing a PDF. Use role-based enablement:

• Executors: SOC, IR, IT Ops, IAM admins, network team. They need runbooks and access.
• Decision-makers: CIO, CISO, General Counsel, Privacy, business leaders. They need severity model, escalation, and decision logs.
• Frontline teams: Service desk, customer support. They need scripts and routing.

Retain training completion evidence and a record of who is in scope for each plan.

5) Exercise and validate against real dependencies

Run a mix of:

• Tabletop exercises for decision-making, communications, third-party coordination
• Technical simulations for restore, segmentation, identity compromise response
• Call-tree tests for after-hours escalation

Tie exercises to your plan inventory and produce an after-action report with tracked remediation items.

6) Maintain: set review triggers and a change control loop

A plan maintenance program needs defined triggers. Typical triggers include:

• Material system changes (new IAM, new EDR, new cloud region)
• Reorgs and leadership changes
• New critical third party or change in a critical third party’s service model
• Lessons learned from incidents, exercises, near misses

Use version control and require a short “reason for change” entry for each update.

7) Improve: implement a closed-loop corrective action process

Improvement is measurable when:

• After-action items are assigned owners and due dates
• Items are tracked to closure
• Plan updates reference the lesson learned
• Future exercises verify the fix

If you use Daydream, map ID.IM-04 to the policy, procedure, control owner, and recurring evidence collection so audits pull from a consistent system of record rather than scattered folders (NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes).

Required evidence and artifacts to retain

Keep evidence that proves each verb in the requirement.

Established

• Plan inventory/register
• Final approved plans (versioned)
• Approval records (ticket, workflow output, or signed approval)

Communicated

• Distribution list or access logs (who has access)
• Training materials and completion records
• Org-wide or role-based communications announcing updates

Maintained

• Review schedule and trigger definitions
• Change log with version history
• Periodic review attestations by owners

Improved

• Exercise schedule and results
• After-action reports
• Corrective action tracker (with closure evidence)
• Updated plan versions referencing improvements

Common exam/audit questions and hangups

Expect assessors to probe these points:

• “Show me your full list of cybersecurity operational plans, not only incident response.”
• “Who is accountable for each plan, and how do you ensure backups/deputies?”
• “How do you know the plan is communicated to the people who must execute it?”
• “What changed in the last update, and why?”
• “Show me proof you improved the plan after an exercise or real incident.”
• “How do third parties fit into response (SaaS outage, data processor breach, MSP compromise)?”

Hangup pattern: teams present a mature IRP but cannot show training, exercises, or improvements, or they treat DR/BCP as separate and never integrate cyber-triggered scenarios.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails ID.IM-04	Fix
One “master IR plan” with no operational runbooks	Responders cannot execute under time pressure	Add role-based runbooks and decision trees tied to severity
Plans stored in a shared drive with no owner	No maintenance, no improvement loop	Assign accountable owner, deputy, and review triggers in the plan register
Contact lists embedded in PDFs	They go stale immediately	Store contacts in a maintained system and reference it from the plan
Exercises happen, but results don’t change plans	No “improved” evidence	Require after-action items and plan updates as an exit criterion
Third-party incidents treated as “vendor management’s problem”	Operational impact still hits you	Add third-party coordination steps, contract contacts, and evidence expectations

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat enforcement risk as indirect: organizations are criticized after incidents when plans were missing, outdated, or not followed. Operationally, ID.IM-04 reduces loss severity by shortening decision cycles, preventing role confusion, and improving restoration outcomes (NIST CSWP 29).

A practical 30/60/90-day execution plan

First 30 days (Immediate stabilization)

• Name a single accountable program owner for the plan lifecycle (often Security GRC or IR lead).
• Build the plan inventory and identify gaps (missing ransomware playbook, third-party coordination, crisis comms).
• Collect current documents and verify they reflect current tooling, org chart, and key third parties.
• Define minimum plan template and approval workflow.

By 60 days (Operationalization)

• Update the IRP and top operational plans to the template and push through approvals.
• Publish plans in a controlled repository with versioning.
• Deliver role-based communications and targeted training for responders and decision-makers.
• Run at least one tabletop covering: declaration criteria, legal/privacy engagement, third-party coordination, and executive comms.

By 90 days (Evidence and improvement loop)

• Produce an after-action report and create a corrective action tracker with owners.
• Update plans based on exercise findings and record the change log.
• Set review triggers and recurring review cadence in the plan register.
• Automate evidence collection where possible (training exports, ticket approvals, version history). If you use Daydream, connect ID.IM-04 to control ownership and recurring evidence requests so you can answer audits with a consistent evidence package (NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes).

Frequently Asked Questions

What counts as “other cybersecurity plans that affect operations” besides the incident response plan?

Plans that govern how you keep services running during cyber events, restore systems, and manage communications. Common examples include ransomware playbooks, DR restoration runbooks, crisis communications, and third-party incident coordination.

Do we need separate plans for IR, DR, and BCP?

You can combine documents if they stay executable, but you must cover distinct objectives: containment and investigation (IR), technical restoration (DR), and business process continuity (BCP). Auditors care that responsibilities and steps are clear, not how many files you have.

What’s the minimum evidence that “communicated” is real?

Training completion records for in-scope roles plus proof the current plan is accessible (and people know where). A single email distribution is weak unless backed by attestations or role-based enablement.

How do we prove “improved” if we haven’t had a major incident?

Use exercises and near-miss reviews as the improvement driver. Keep after-action reports, corrective action tracking, and plan version updates that explicitly reference what changed.

How should third parties be included in these plans?

Add a third-party coordination section: who contacts the provider, what evidence you request, how you handle shared logging and timelines, and how you communicate customer impact. Keep an up-to-date contact method for critical third parties outside of a static PDF.

Can we satisfy ID.IM-04 with policies only?

No. Policies set expectations, but ID.IM-04 expects operational plans that people can execute, plus evidence of communication, maintenance, and improvement (NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes).