ID.RA-01: Vulnerabilities in assets are identified, validated, and recorded

To meet the id.ra-01: vulnerabilities in assets are identified, validated, and recorded requirement, you need a repeatable process that (1) finds vulnerabilities across your in-scope asset inventory, (2) validates findings to remove false positives and confirm exposure, and (3) records each vulnerability with enough detail to drive remediation and demonstrate control operation (NIST CSWP 29).

Key takeaways:

• “Identified” means you continuously discover vulnerabilities across defined asset classes, not just run an occasional scan (NIST CSWP 29).
• “Validated” requires triage, de-duplication, and confirmation of exploitability or applicability before you treat a finding as real work.
• “Recorded” means a durable system of record with ownership, timestamps, evidence, and linkage to the affected asset and remediation workflow.

ID.RA-01 sits in the Identify function’s Risk Assessment category and is one of the fastest ways auditors and security assessors gauge whether your risk program is real or aspirational. If you cannot prove you reliably find and track vulnerabilities, every downstream control becomes harder to defend: patching, compensating controls, incident response readiness, third-party assurance, and even board reporting.

Operationalizing this requirement is less about buying a scanner and more about making vulnerability data trustworthy and governable. Trustworthy means: coverage is defined, findings are validated, exceptions are controlled, and you can show what changed since last time. Governable means: every vulnerability has an owner, a status, a due date or disposition, and evidence that actions taken match policy.

This page gives requirement-level implementation guidance you can hand to a control owner. It focuses on what a CCO, GRC lead, or security risk owner needs to define: scope, process, records, evidence, and audit handling. The goal is simple: if an examiner asks, “Show me your last cycle of vulnerability identification, validation, and recording,” you can produce a clean, end-to-end trail.

Regulatory text

Requirement excerpt: “Vulnerabilities in assets are identified, validated, and recorded” (NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes).

What the operator must do:
You must run a vulnerability management process that covers your in-scope assets, confirms findings are real and relevant (not noise), and logs them in a system of record that supports remediation tracking and risk decisions. Evidence has to show the process operates repeatedly, not as a one-time exercise (NIST CSWP 29).

Plain-English interpretation (what “identified, validated, recorded” means)

Use this three-part translation to keep teams aligned:

• Identified: You have defined sources and methods to detect vulnerabilities across asset types (endpoints, servers, network devices, cloud resources, applications, container images, and key third-party-provided components where you have visibility). Identification includes authenticated scanning where feasible, but also vendor advisories, SBOM inputs where available, penetration test findings, bug bounty reports, configuration assessments, and cloud-native posture findings.
• Validated: You confirm applicability and relevance. That includes: de-duplicating multiple detections of the same issue; checking the affected version/build; confirming reachability/exposure; verifying whether compensating controls materially reduce risk; and classifying false positives. Validation is where you prevent “scanner output” from becoming “risk truth.”
• Recorded: You keep a durable, queryable record of each validated vulnerability, linked to the asset and owner, with timestamps, severity/context, current status, and final disposition (remediated, accepted risk, mitigated via compensating control, or false positive). Recording also means you can reconstruct what you knew and when.

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 that must demonstrate baseline security hygiene to customers, insurers, partners, or auditors (NIST CSWP 29).

Operationally, it applies wherever you have assets and change:

• Enterprise IT: laptops, servers, network gear, identity infrastructure.
• Cloud and SaaS administration: IaaS/PaaS resources, misconfigurations with vulnerability impact, exposed services.
• Product/application teams: libraries, build pipelines, container images, application vulnerabilities from testing.
• OT/IoT (if in scope): specialized scanning constraints; heavier reliance on compensating controls and vendor advisories.
• Third party context: You may not be able to scan third-party-managed systems directly. Your duty becomes defining assurance inputs (attestations, vuln reporting SLAs, advisory monitoring) and recording third-party-reported vulnerabilities that affect your environment or products.

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

1) Define scope and ownership (control design)

1. Set asset scope: align to your asset inventory and data classification. Start with “assets that can materially impact confidentiality, integrity, or availability.”
2. Assign a control owner: typically Security Operations/Vulnerability Management, with GRC as oversight.
3. Define “system of record”: ticketing platform, vulnerability management platform, or GRC tool that can store evidence and workflow.
4. Define severity scheme: scanner severity plus business context (internet exposure, asset criticality, exploit availability, compensating controls).

Deliverable: Vulnerability Management Standard (or procedure) mapped to ID.RA-01, with RACI.

2) Identify vulnerabilities (collection)

Build a defined set of “input channels,” then prove they run:

• Technical discovery: authenticated scans for servers/endpoints, cloud posture/vuln tools, container/image scanning, SAST/DAST where adopted.
• Human-led discovery: penetration tests, red team, code reviews, incident learnings.
• Supplier and ecosystem discovery: vendor security advisories, CERT notifications, and third-party notifications.

Operator tip: Document coverage by asset class. Auditors ask “what’s covered and what isn’t” before they ask “how often.”

3) Validate findings (triage and confirmation)

Validation should be an explicit workflow state with clear criteria:

• De-duplicate: same CVE across many hosts should roll up for tracking while retaining affected-asset linkage.
• Confirm applicability: verify package/version, OS build, configuration state, cloud control plane settings.
• Confirm exposure: reachable from the internet, reachable from untrusted networks, or only internal; privilege required; mitigations present.
• Classify disposition: valid vulnerability, false positive, or informational. For valid items, set remediation path; for false positives, require justification and approver.

Deliverable: Triage runbook with examples of false positive handling and compensating control validation.

4) Record vulnerabilities (system of record fields)

Minimum fields you should require for each validated vulnerability record:

• Asset identifier and owner (team/service owner)
• Vulnerability identifier (CVE or tool ID), title, description
• Source (scanner/tool/advisory/test)
• Detection date/time; validation date/time; validator identity
• Severity and business context (asset criticality, exposure)
• Required action (patch, config change, mitigation)
• Target due date (policy-driven) and actual closure date
• Status (open/in progress/mitigated/accepted/false positive/closed)
• Evidence links (scan output, screenshots, advisory link, change record)
• Approval fields for risk acceptance/exception

5) Drive remediation and governance (operate the control)

ID.RA-01 ends at recording, but in practice you need governance hooks or the control won’t be credible:

• Aging and backlog review: recurring review with accountable engineering leaders.
• Exceptions process: time-bound risk acceptance with compensating controls and sign-off.
• Metrics that auditors recognize: open criticals by business unit, validation turnaround time, closure by SLA tier (don’t add numbers unless you can defend them internally).
• Change linkage: patch/change tickets tied to vulnerability IDs for traceability.

6) Map to policy, procedure, owner, and recurring evidence

The most audit-efficient pattern is explicit mapping of ID.RA-01 to a control statement, an owner, and a monthly/quarterly evidence pull (NIST CSWP 29; NIST CSF 1.1 to 2.0 Core Transition Changes).
If you use Daydream, configure the control once, assign ownership, and schedule recurring evidence requests so vulnerability identification/validation/recording stays continuously audit-ready.

Required evidence and artifacts to retain

Keep artifacts that prove design and operation:

Design evidence

• Vulnerability Management Policy/Standard mapped to ID.RA-01 (NIST CSWP 29)
• Scope statement (asset classes included/excluded) with rationale
• RACI (who scans, who validates, who approves exceptions)
• Data retention guidance for vuln records and scan outputs

Operating evidence

• Scan schedules/configuration exports (show authenticated coverage where applicable)
• Sample scan reports from each major asset class and tool/source
• Triage/validation logs: false positive dispositions with justification
• System-of-record exports: vulnerability list with required fields populated
• Exception/risk acceptance records with approvals and expiry dates
• Meeting notes or dashboards from recurring backlog review

Common exam/audit questions and hangups

Auditors tend to press on these points:

• Coverage: “Show me which assets are scanned and how you know the inventory is complete.”
• Validation rigor: “How do you prevent false positives from inflating risk reporting?”
• Timeliness: “How quickly do you validate new findings and route them to owners?”
• Traceability: “Pick one high-risk vulnerability and show detection → validation → ticket → remediation → closure evidence.”
• Exceptions: “Who can accept risk, and how do you ensure acceptances expire or get reviewed?”

Frequent implementation mistakes (and how to avoid them)

1. No authoritative asset linkage. Findings exist, but you cannot tie them to a real owner.
   Fix: require CMDB/cloud inventory identifiers in vuln records; reject records without ownership.

2. Scanner output treated as final truth. Teams stop trusting the program due to false positives.
   Fix: enforce a validation state and require justification for “false positive” with approver.

3. Vulnerability data spread across tools with no system of record. You cannot answer basic audit questions.
   Fix: pick one tracking layer (ticketing/GRC/vuln platform) and synchronize all sources into it.

4. Third-party exposure ignored. You track internal vulnerabilities but miss supplier advisories that affect your product stack.
   Fix: add an “advisory monitoring” channel and record supplier-reported issues that impact your environment.

5. Evidence not retained. You can describe the process, but you cannot prove it operated last quarter.
   Fix: schedule recurring evidence exports and store them with timestamps and access controls.

Enforcement context and risk implications

No public enforcement cases were provided in the approved source catalog for this requirement, so this page does not cite specific actions. Practically, failure to meet ID.RA-01 creates predictable outcomes: untracked exposures, inconsistent patching, weak incident root cause analysis, and poor defensibility when customers or auditors ask what you knew about known vulnerabilities and when (NIST CSWP 29).

Practical 30/60/90-day execution plan

First 30 days (stand up the control)

• Name the ID.RA-01 control owner and approve scope (asset classes, environments).
• Choose the system of record and define required fields.
• Inventory vulnerability “input channels” you already have (scanners, cloud tools, pen tests, advisories).
• Publish a short triage/validation runbook and start tracking false positives explicitly.

Days 31–60 (make it auditable)

• Prove coverage: produce a report that reconciles in-scope assets to scan coverage and identifies gaps.
• Implement validation SLAs internally (time to triage, time to assign owner) and enforce workflow states.
• Stand up an exceptions process with named approvers, expiry dates, and required compensating controls evidence.
• Start recurring evidence collection: monthly exports of vuln records and sample validation artifacts.

Days 61–90 (make it sustainable)

• Add governance: recurring backlog review with engineering leadership and a documented agenda.
• Tune noise: refine scan configs and validation rules based on false positive patterns.
• Integrate third-party advisory monitoring into the same recording workflow.
• Run an audit simulation: select several vulnerabilities and walk the full traceability chain end-to-end, then fix gaps.

Frequently Asked Questions

Do we have to scan every asset to meet ID.RA-01?

You need defined coverage across in-scope assets and a defensible method to identify vulnerabilities for each asset class (NIST CSWP 29). Where scanning is not feasible (some OT or third-party-managed systems), document alternative identification inputs and record the resulting findings the same way.

What counts as “validated”?

Validation means confirming the finding is applicable to the asset and materially represents a vulnerability, not just tool output. In practice this includes de-duplication, version confirmation, exposure checks, and documented false positive handling.

Can our ticketing system be the “record,” or do we need a vulnerability platform?

A ticketing system can work if it supports required fields, evidence links, reporting, and immutable history. Auditors care about traceability and completeness more than tool brand.

How do we handle vulnerability findings from penetration tests or bug reports?

Treat them as first-class inputs: validate them, record them in the same system of record, assign an owner, and track disposition to closure. Keep the original report as evidence and link it to the record.

What do we do about vulnerabilities in third-party software or SaaS platforms?

Record vulnerabilities that affect your risk, even if remediation is owned by a third party. Track vendor notification dates, your validation of impact, your mitigation steps, and any contractual escalation or risk acceptance.

What evidence is most persuasive in an audit?

End-to-end traceability samples: scan/advisory → validation notes → tracked record with owner → remediation change/ticket → closure proof. Pair that with a documented scope and recurring reports that show the process operates over time (NIST CSWP 29).