RC.CO-03: Recovery activities and progress in restoring operational capabilities are communicated to designated internal and external stakeholders

The rc.co-03: recovery activities and progress in restoring operational capabilities are communicated to designated internal and external stakeholders requirement is a recovery communications control, not a generic “send updates” expectation. It forces you to answer hard questions before an incident: who needs to know, what they need to know, when they need to know it, and how you prove you did it. In audits, teams fail this requirement less from weak recovery work and more from weak communications design: no stakeholder map, no pre-approved templates, unclear approval authority, and no retained evidence beyond chat logs.

RC.CO-03 sits in the “Recover” function of NIST CSF 2.0 and complements incident response communications. The focus is the recovery period: actions to restore systems and business services, progress against restoration milestones, and communications that support governance, customer commitments, third-party dependencies, and legal or contractual duties. You should treat this as an operational capability with named owners, triggers, and tooling, then test it during tabletop exercises so you do not invent the process mid-outage. ¹

Regulatory text

Requirement (RC.CO-03): “Recovery activities and progress in restoring operational capabilities are communicated to designated internal and external stakeholders.” ²

What the operator must do

You must (1) designate stakeholder groups in advance, (2) define what recovery updates contain (activities and progress toward restoration), and (3) execute communications during recovery using defined channels and owners. The “designated” qualifier is the point: auditors will look for pre-definition (plans, lists, procedures), not informal “we told people” narratives.

Plain-English interpretation

During service restoration, you must provide timely, role-appropriate status updates to the people who run the business and the people impacted by the outage. “Recovery activities” means what you are doing (workstreams, mitigations, restorations, failovers). “Progress” means where services stand against restoration goals (which services are up, what remains degraded, current ETA ranges if you provide them, and what is blocking recovery). “Internal and external stakeholders” includes executives, business owners, IT ops, customer support, legal, and also customers, regulators (if applicable), critical third parties, and others defined by contract or business need.

Who it applies to

Entities: Any organization operating a cybersecurity program and using NIST CSF 2.0 as a framework reference or requirement baseline. ¹

Operational context where RC.CO-03 becomes exam-relevant:

• Material business services supported by IT, SaaS, or operational technology.
• Dependency chains with critical third parties (cloud, MSPs, payment processors, telecom, data providers).
• Customer-facing platforms where support and communications teams need consistent messaging.
• Regulated or contractual environments where outage notifications and restoration status must be coordinated (even when RC.CO-03 itself is not a regulation, it often maps to contractual and sector expectations).

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

1) Assign ownership and decision rights

• Name a Recovery Communications Owner (often BCM, IT Service Continuity, or IR communications lead) accountable for executing the recovery comms procedure.
• Define approvers for external communications (typically Legal/Privacy plus executive incident commander).
• Define who can declare restoration milestones (usually IT Ops/SRE lead) to prevent premature “all clear” statements.

Operational tip: If approvals slow down updates, pre-approve templates and “safe language” blocks.

2) Build a stakeholder designation register (internal + external)

Create and maintain a register that includes:

• Stakeholder group (e.g., Exec leadership, Business service owners, IT Ops, Customer Support, HR, Legal)
• External groups (e.g., affected customers, key accounts, critical third parties, cyber insurer, sector coordinators if applicable)
• Primary and backup contacts
• Communication channels (email distro, status page, phone bridge, ticketing notifications)
• Required content level (executive summary vs technical detail)
• Frequency triggers (event-based; avoid rigid clocks if you cannot support them)

Minimum expectation: The list exists before the incident and is reviewed on a scheduled cadence aligned to your governance model.

3) Define message triggers tied to recovery milestones

Write explicit triggers so you are not debating “should we send an update?” mid-recovery:

• Recovery initiated (incident moved from containment to restoration work)
• Failover executed / rollback initiated
• Partial restoration of a business service
• Restoration blocked (dependency issue, third-party outage, data integrity checks)
• Full restoration achieved (and what “restored” means, such as service availability vs backlog processing)
• Post-recovery monitoring period start and end (if you track that)

4) Standardize the content of recovery updates

Use a template with consistent fields:

• What happened (brief, non-speculative)
• What services are impacted and current status (up/degraded/down)
• Recovery actions underway (high-level and technical appendix as needed)
• Dependencies and blockers (including third-party constraints where appropriate)
• Customer/workaround guidance (what users should do now)
• Next update trigger (time-based only if you can commit)
• Who to contact (support channels; internal escalation paths)

Governance note: Include a classification tag (internal-only vs external-safe) to prevent oversharing sensitive details.

5) Establish channels and a single source of truth

Pick the authoritative channel per audience:

• Internal: incident bridge notes, internal status page, ITSM major incident record
• External: public status page, customer email, account management outreach scripts

Avoid conflicting sources. If you allow multiple channels, define which one is “binding” for status claims.

6) Exercise the process and prove it works

Test RC.CO-03 during:

• Tabletop exercises (validate triggers, approvals, templates)
• Recovery tests (DR/BCP exercises where you simulate restoration milestones and send comms)

Capture lessons learned and update the stakeholder register and templates.

7) Map the requirement to policy, procedure, control owner, and recurring evidence

Put RC.CO-03 into your control library with:

• Control statement
• Owner and backups
• Evidence sources and retention locations
• Test method (walkthrough + sample incident validation)

This mapping is a common way teams keep RC.CO-03 audit-ready without rebuilding artifacts for every assessment. ²

Required evidence and artifacts to retain

Auditors and internal assurance teams will look for objective proof that communications are defined and executed. Retain:

Design-time artifacts (pre-incident)

• Recovery Communications Procedure (or section in IR/BCP/DR plan)
• Stakeholder designation register (internal and external) with owners and channels
• Message templates (internal update, exec brief, customer update, third-party notice)
• Approval matrix (RACI) for external statements
• Communications channel inventory (status page ownership, distro lists, bridge procedures)
• Training or onboarding records for on-call/incident commanders (if you maintain them)

Run-time artifacts (during an actual recovery)

• Major incident record with restoration milestones and timestamps
• Copies of messages sent (emails, status page change logs, ticket updates, customer notices)
• Distribution proof (distro list, account team outreach log, portal announcement record)
• Decision log for what was communicated and why (especially if you withheld details for legal/security reasons)

Post-incident artifacts

• After-action report showing communications effectiveness and gaps
• Updated register/templates based on lessons learned

Retention practicality: Store comms evidence in the same system of record you use for incidents (ITSM) and link to the status page change log.

Common exam/audit questions and hangups

• “Who are your designated stakeholders?” Expect a request for the register and proof it is maintained.
• “Show us the last recovery event and the communications trail.” Teams often have chat logs but no curated evidence pack.
• “How do you prevent inconsistent messaging across support, status page, and exec updates?” Auditors want a single source of truth and an approval path.
• “How do you handle third-party-caused outages?” You still must communicate your recovery progress, even if root cause is external.
• “What triggers an external update?” “We do it as needed” is a weak answer unless “as needed” is operationalized with triggers.

Frequent implementation mistakes (and how to avoid them)

1. No pre-designation of external stakeholders.
   Fix: Build the external list from contracts, customer tiers, critical third parties, and service ownership.

2. Blending incident response comms with recovery comms and missing the recovery window.
   Fix: Add a clear handoff point from containment to restoration, with recovery-specific templates.

3. Overpromising restoration timelines.
   Fix: Use milestone-based language and ETA ranges only when your ops team has confidence and approval.

4. Evidence trapped in ephemeral tools.
   Fix: Require copying key updates into the incident record and exporting status page logs after closure.

5. Unclear authority for “all services restored.”
   Fix: Define what “restored” means (availability, performance, data integrity, backlog) and who certifies it.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for RC.CO-03. Treat RC.CO-03 as an audit and assurance expectation tied to operational resilience: weak recovery communications increases customer harm, contractual disputes, executive decision errors, and post-incident defensibility gaps. The control reduces the risk of inconsistent statements across internal teams and external audiences, which can create legal and reputational exposure even when technical recovery is effective. ¹

Practical 30/60/90-day execution plan

First 30 days (stand up the minimum viable control)

• Assign the Recovery Communications Owner and external comms approver(s).
• Draft the Recovery Communications Procedure with triggers and channel assignments.
• Create the stakeholder designation register for internal groups and top external groups (customers by tier, critical third parties, insurer).
• Publish two templates: internal recovery update and external status update.
• Decide your system of record for evidence (ITSM record plus status page log exports).

Days 31–60 (make it operational and testable)

• Integrate the procedure into major incident management runbooks.
• Implement a single source of truth pattern (status page or internal incident dashboard) and document it.
• Run a tabletop that includes a “recovery phase” segment and sends mock updates to each stakeholder group.
• Add an evidence checklist to incident closure criteria (messages, timestamps, distribution proof).

Days 61–90 (harden, measure, and prepare for audit)

• Expand the external stakeholder list based on contract review and third-party dependency mapping.
• Add backup owners and escalation paths for comms approvals.
• Conduct a recovery exercise (DR test or simulated restore) and produce an evidence pack as if for an audit.
• Map RC.CO-03 in your control library to policy, procedure, owner, and recurring evidence collection so audit prep becomes a pull, not a scramble. Daydream can help maintain the control mapping and automate evidence requests and reminders across incident tooling and documentation stores.

Frequently Asked Questions

Do we need to communicate to external stakeholders for every recovery event?

RC.CO-03 requires communications to designated internal and external stakeholders, so scope depends on how you designated external audiences and triggers. Define severity thresholds and customer impact criteria in your procedure so the decision is consistent.

Can a status page alone satisfy RC.CO-03?

A status page can satisfy part of the requirement for certain external audiences, but you still need designated stakeholder lists, internal updates, and retained evidence. Auditors also expect proof that the right people were notified, not just that a page was updated.

What counts as “progress in restoring operational capabilities”?

Progress is measurable movement toward restoration milestones for business services, not just technical activity. Use service status (up/degraded/down), restoration steps completed, blockers, and next milestone criteria.

How do we handle third-party outages where we lack details?

Communicate what you know and what you are doing: your mitigations, expected next update trigger, and customer guidance. Avoid speculating about the third party; record what information you received and when in the incident record.

Who should approve external recovery updates?

Define approvals based on your risk profile, but most organizations require Legal/Privacy review for sensitive incidents and an executive or incident commander sign-off for high-impact outages. Pre-approved templates reduce approval friction.

What evidence do auditors ask for most often?

The stakeholder designation register, the recovery communications procedure, and a completed incident example with copies of messages and timestamps. If you cannot produce those quickly, RC.CO-03 will look informal even if your teams communicated in practice.

Footnotes

1. NIST CSWP 29

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