RC.RP-01: The recovery portion of the incident response plan is executed once initiated from the incident response process

For most organizations, “incident response” is where the attention goes: containment, eradication, forensics, and notifications. RC.RP-01 focuses on what happens next: recovery. The requirement is simple on paper but commonly weak in practice because teams treat recovery as ad hoc operational work rather than an executed part of the incident response lifecycle.

This page explains how a Compliance Officer, CCO, or GRC lead can make RC.RP-01 testable and repeatable. Your goal is to ensure that once incident response determines recovery must begin, the recovery plan is actually executed under control: the right people are engaged, the right steps happen in the right order, risk decisions are documented, and service restoration is tracked against defined targets.

The compliance outcome you want is defensible execution evidence. If an auditor, customer, regulator, or board asks “Show me how you recovered the business services after the incident, and prove it followed your plan,” you should be able to produce a clean recovery timeline with approvals, changes, and outcomes tied back to recovery procedures.

Target keyword: rc.rp-01: the recovery portion of the incident response plan is executed once initiated from the incident response process requirement

Regulatory text

Requirement (RC.RP-01): “The recovery portion of the incident response plan is executed once initiated from the incident response process.” ¹

What an operator must do:

• Treat recovery as a defined phase that is formally initiated from incident response, not as informal “ops cleanup.”
• Execute documented recovery procedures (runbooks/playbooks) once initiation criteria are met.
• Track and record recovery actions, approvals, and restoration outcomes so you can prove recovery occurred as designed. ²

Plain-English interpretation of the requirement

RC.RP-01 means: when incident response says “start recovery,” your organization actually runs the recovery plan. That includes:

• a clear trigger from the incident response process to the recovery process,
• assigned ownership (who is in charge of recovery decisions),
• controlled execution (runbooks, change control, communications),
• verification that restored services are stable and safe to return to normal operation,
• retained evidence.

Recovery is not the same as eradication. Eradication removes the threat from affected systems. Recovery restores business capabilities safely (services, data, dependencies) and confirms they can operate without reintroducing the incident conditions.

Who it applies to (entity and operational context)

Applies to: organizations operating a cybersecurity program that use NIST CSF 2.0 as a framework baseline. ²

Operationally, this requirement touches:

• Security / IR teams: decide when to initiate recovery, provide risk guidance, confirm eradication conditions as needed.
• IT operations / SRE / infrastructure: execute restoration, rebuilds, failover/failback, patching sequences, capacity validation.
• Application owners: validate application integrity and business functionality.
• BCP/DR program owners: align recovery actions with disaster recovery and business continuity plans where relevant.
• Change management: document emergency changes, approvals, and backout plans.
• Third parties: cloud providers, managed security providers, SaaS platforms, and critical suppliers involved in restoration steps.

Where it matters most:

• Ransomware and destructive malware events
• Identity compromise with broad access (forcing re-keying, token resets, privileged access rebuilds)
• Cloud control plane compromise
• Data integrity events (restoring from backups is not enough; integrity validation is required)

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

1) Define the “initiation” handoff from incident response to recovery

Create a documented gate that incident response uses to initiate recovery. Include:

• Trigger criteria: examples: containment achieved, restoration path selected (restore, rebuild, failover), leadership authorizes business restoration.
• Decision owner: Incident Commander or IR Lead initiates recovery; Recovery Lead accepts ownership.
• Inputs required: scope, impacted services, known-good restore points, affected identities, required security controls before return to service.
• Outputs: a recovery workstream ticket/record, assigned recovery roles, and a declared recovery objective for the incident.
  Map this explicitly in the IR plan so auditors can see the linkage. ²

2) Assign recovery roles and decision rights (RACI)

Minimum roles to define in writing:

• Recovery Lead (single-threaded owner): runs the recovery plan, coordinates IT/app teams, reports milestones.
• Incident Commander / IR Lead: retains authority for security risk decisions (for example, “safe to reconnect to network”).
• Service Owners: approve functional readiness and business acceptance.
• Change Manager (or emergency change authority): records emergency changes and approvals.
• Comms Lead: coordinates internal updates, customer messaging where applicable.

A lightweight RACI table is enough if it names the accountable person or function and how to reach them during an incident.

3) Maintain recovery runbooks tied to critical services

For each critical business service, document recovery procedures that operators can execute under pressure:

• restore sequence (dependencies first, then applications, then integrations),
• rebuild steps (gold images, IaC pipelines, configuration baselines),
• credential/key rotation steps if compromise is suspected,
• data restoration steps and integrity checks,
• validation checklist (technical health + business function),
• rollback/backout steps if recovery increases risk.

Avoid writing a novel. A short runbook that is executed beats a long one that is ignored.

4) Execute recovery through controlled work management

During recovery, require the team to log work in a system of record (IR platform, ITSM tickets, or incident channel logs) that captures:

• tasks assigned, start/stop times, dependencies,
• approvals for emergency changes,
• evidence of restoration (screen captures, command outputs, monitoring snapshots),
• validation results and acceptance sign-off.

From a GRC perspective, your key control is: recovery actions are planned, tracked, approved, and evidenced.

5) Verify “safe and stable” before returning to normal operations

Define minimum acceptance criteria to exit recovery, such as:

• monitoring signals stable,
• security controls re-enabled (EDR, logging, MFA, network segmentation),
• known compromised access revoked,
• data integrity validated for restored datasets where relevant,
• business owner confirms required workflows.

Tie these to a documented “return to operations” checkpoint controlled by the Recovery Lead with security concurrence when risk is involved.

6) Close recovery with documentation and lessons learned

After restoration:

• publish a recovery summary: what was restored, when, and how integrity was validated,
• record residual risks and compensating controls,
• update runbooks and escalation lists based on what failed in execution,
• ensure post-incident review outputs feed backlog and control improvements. ²

Required evidence and artifacts to retain

Auditors and customers rarely accept “we recovered” without artifacts. Retain:

• Incident record showing the moment recovery was initiated (timestamped decision and owner).
• Recovery plan/runbook versions in effect at time of incident (version control history).
• Work tickets / task logs for restoration actions, including owners and approvals.
• Emergency change records and backout plans (even if simplified).
• Restoration proof: backup restore logs, rebuild pipeline logs, infrastructure deployment records, screenshots, monitoring exports.
• Validation evidence: functional test results, integrity checks where applicable, service owner acceptance.
• Comms artifacts: internal situation reports, customer updates if sent, leadership briefings.
• Post-incident report with recovery timeline and corrective actions.

If you use Daydream to manage control evidence, map RC.RP-01 to a named control owner and set recurring evidence requests (for example, per recovery test, per incident, and per runbook review cycle) so the evidence trail stays current.

Common exam/audit questions and hangups

Expect these questions, and pre-answer them with documentation:

1. “Show me where incident response triggers recovery.” They want an explicit handoff in the IR plan and evidence it was used.
2. “Who is accountable for recovery?” A named Recovery Lead and decision rights prevent ambiguity.
3. “Did you follow your recovery plan?” Provide the runbook plus execution logs that match it, including deviations with rationale.
4. “How did you validate restoration?” Health checks alone are weak; add functional validation and security readiness checks.
5. “How do third parties fit into recovery?” Show contact paths, SLAs/OLAs where relevant, and how third-party actions are tracked.

Frequent implementation mistakes and how to avoid them

• Mistake: Recovery is “implicit.” Teams jump into restoration without a formal initiation record.
  Fix: require a timestamped recovery initiation step in the incident record and name the Recovery Lead.

• Mistake: Runbooks exist but aren’t executable. They are outdated, environment-specific, or missing dependencies.
  Fix: keep runbooks service-based, dependency-first, and test them during recovery exercises; update after incidents.

• Mistake: Change control is bypassed with no trace. Emergency changes happen in chat with no approval record.
  Fix: define an emergency change path with minimal required fields and capture approvals in the system of record.

• Mistake: “Restored” equals “secure.” Services come back online with logging disabled, old credentials, or reduced controls.
  Fix: define a security readiness checklist required for exit from recovery (logging, EDR, access controls).

• Mistake: Evidence is scattered. Screenshots in personal folders, timelines in chat, no central package.
  Fix: maintain an incident evidence folder/template; assign a scribe to compile recovery artifacts during the event.

Enforcement context and risk implications

NIST CSF is a framework, not a regulator, and the provided sources do not include enforcement actions tied to RC.RP-01. ²
Operationally, the risk is still real: if you cannot prove recovery execution, you face higher outcomes in customer security reviews, cyber insurance claim friction, and board scrutiny after an outage. The most common failure mode is governance: recovery happens, but the organization cannot demonstrate controlled execution, approvals, and validation.

Practical 30/60/90-day execution plan

First 30 days: Make recovery initiation and ownership unambiguous

• Update the IR plan to include a formal “Initiate Recovery” decision step and required inputs/outputs. ²
• Assign Recovery Lead role and backups; publish an on-call contact path.
• Create an evidence checklist template for recovery (what to capture, where to store it).
• Identify top critical services and confirm each has a recovery runbook owner.

By 60 days: Make recovery executable for critical services

• Draft or refresh runbooks for critical services with dependency order, validation steps, and rollback.
• Define an emergency change recording process that works during incidents.
• Run a tabletop focused on the recovery handoff: IR initiates recovery, Recovery Lead executes, service owners validate.
• Configure recurring evidence collection in your GRC workflow (Daydream or your existing tool) aligned to tests and incidents.

By 90 days: Prove it works and make it repeatable

• Conduct a recovery exercise that produces an audit-ready evidence package (initiation record, tickets, approvals, validation).
• Track corrective actions to closure: runbook gaps, missing permissions, dependency surprises, third-party coordination issues.
• Add recovery KPIs as internal management metrics (qualitative is fine): completeness of evidence package, timely role assignment, validation completion.
• Establish a cadence for runbook review and recovery training tied to service change cycles.

Frequently Asked Questions

What counts as “initiated from the incident response process” for RC.RP-01?

It means incident response makes a documented decision to begin restoration activities and hands off to a defined recovery workstream with an accountable owner. Capture the trigger, timestamp, and who authorized recovery in the incident record. ²

Do we need separate incident response and recovery plans?

You can keep them in one integrated plan, but the recovery portion must be clearly identifiable and executable. Auditors look for a clear handoff, roles, and runbooks that operators can follow. ²

How do we handle deviations from the recovery runbook during a real incident?

Deviations are acceptable if you document the rationale, the approver, and the alternative steps taken. Treat the deviation record as required evidence, then update the runbook after the incident.

Does RC.RP-01 require recovery testing?

RC.RP-01 focuses on execution once recovery is initiated. Testing is a practical way to prove the plan is executable and to generate evidence, but the requirement statement itself is about execution during initiation. ²

What evidence is strongest if an auditor asks “prove you executed recovery”?

Provide a complete recovery timeline: initiation decision, task/ticket trail, emergency change approvals, restore logs, validation results, and service owner acceptance. A single post-incident report without underlying records is usually weak.

How should we treat third parties in recovery (cloud/SaaS/MSP)?

Treat third-party actions as part of your recovery workstream: document who engaged them, what they did, and what evidence you received (status updates, case numbers, restoration confirmations). Make sure your runbooks include contact paths and decision points where third parties are dependencies.

Footnotes

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

2. NIST CSWP 29