03.06.01: Incident Handling

To meet the 03.06.01: incident handling requirement, you must establish and run an incident handling capability for systems that process, store, or transmit CUI, including defined procedures, assigned roles, and repeatable workflows that detect, analyze, contain, eradicate, and recover from incidents. Your fastest path to operationalize is to publish an incident handling procedure, stand up an intake-and-triage process, and collect evidence from real exercises and real tickets. ¹

Key takeaways:

• 03.06.01 expects an operating incident handling process, not a policy PDF. ¹
• Evidence is the control: tickets, timelines, comms, decisions, and after-action items prove performance. ¹
• Scope must align to CUI: map the process to the CUI environment boundary and its supporting services. ¹

03.06.01 sits in the Incident Response family of NIST SP 800-171 Rev. 3 and is routinely assessed as a “show me you can do it” control. Auditors and customers usually start with a simple question: “If you had a suspected compromise of CUI, what happens in the first hour, and who does what?” If your answer depends on a single person’s memory, or your evidence is limited to a policy that hasn’t been exercised, you will struggle to demonstrate compliance.

Operationalizing this requirement means building a workflow that works on ordinary days, not just during major events: an intake channel, triage criteria, severity levels, escalation rules, containment options that won’t destroy evidence, and a closed-loop review cycle. You also need to define scope correctly. For most federal contractors, the incident handling process must cover the systems in the CUI boundary and the supporting infrastructure and third parties that can affect it (for example, managed service providers, identity providers, or ticketing platforms used to administer CUI systems).

This page gives requirement-level guidance you can implement quickly: who owns what, what to write, what to configure, and what evidence to retain for an assessment against the 03.06.01: incident handling requirement. ¹

Regulatory text

Requirement: “NIST SP 800-171 Rev. 3 requirement 03.06.01 (Incident Handling).” ¹

Operator interpretation: You must have an incident handling capability that is defined, assigned, and executable for the environment handling CUI. “Capability” means more than a statement of intent. Assessors will expect documented procedures plus records that show the procedures are used in real incidents and/or exercises. ¹

What the operator must do (minimum):

• Define what constitutes an incident in your environment and how it enters your process (intake).
• Triage and classify events consistently (severity, category, CUI impact).
• Execute handling activities end-to-end: analysis, containment, eradication, and recovery.
• Preserve investigation evidence and record decisions.
• Close incidents with lessons learned and corrective actions that actually get tracked to completion. ¹

Plain-English requirement interpretation (what “good” looks like)

If something suspicious happens on a CUI system, you can:

1. notice it, 2) capture the right details fast, 3) make a severity call, 4) contain without making things worse, 5) restore securely, and 6) prove what you did afterward.

Assessors typically look for three things:

• Clarity: People know how to report, who is on point, and what “incident” means.
• Repeatability: The steps are consistent across incidents, not improvised.
• Proof: You can produce artifacts that show the process ran (tickets, timelines, approvals, comms). ¹

Who it applies to

In-scope entities

• Federal contractors and subcontractors that handle CUI in nonfederal systems.
• Any organization implementing NIST SP 800-171 Rev. 3 as a contractual requirement. ¹

In-scope operational context (what to include)

Scope the incident handling process to:

• The CUI environment boundary: endpoints, servers, identity, network, cloud resources, and applications that process/store/transmit CUI.
• Administrative and security tooling that can affect CUI: IAM/SSO, EDR, SIEM, vuln management, MDM, backup systems.
• Third parties with administrative access or material operational impact: MSPs, SOC providers, cloud providers, and critical SaaS used to run the CUI environment. Your process must define how incidents involving third parties are handled, escalated, and evidenced. ¹

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

Step 1: Define the incident handling “product” (documents + workflow)

Create three artifacts that work together:

1. Incident Handling Policy (1–2 pages): purpose, scope (CUI boundary), governance, and management intent.
2. Incident Handling Procedure / Playbook (operational): the actual steps responders follow.
3. Incident Classification Standard: severity levels, categories, and triggers for escalation.

Keep these aligned. A common audit failure is a policy that says one thing and a ticket workflow that does another. ¹

Step 2: Assign roles and escalation paths

At minimum, name:

• Incident Commander (IC): accountable for coordination and decisions.
• Technical Lead: drives investigation and containment.
• Comms Lead: internal updates, customer notifications if contractually required, third-party coordination.
• System Owners: approve impactful containment actions when needed (for example, isolating a production server).
• Legal/Contracts liaison: for contractual reporting and evidence preservation guidance.

Publish an on-call or contact method. If you rely on a third party SOC/MSP, make sure the contract states who declares an incident and who owns communications. ¹

Step 3: Stand up intake, triage, and tracking

Operationalize in your ticketing system (or IR platform):

• One intake channel (email alias, portal form, SOC queue) with required fields.
• Minimum intake fields: reporter, time detected, affected assets, suspected CUI involvement, indicators (IPs/domains/hashes), screenshots/log snippets, containment already taken.
• Triage checklist: confirm scope, preserve logs, assess privilege impact, decide severity, assign IC.

Make severity decisions auditable: store the criteria and the reason for classification in the ticket. ¹

Step 4: Build containment and evidence-preservation rules

Write practical guardrails responders follow by default:

• Containment menu: isolate host, disable account, block IOC, revoke sessions/tokens, restrict egress, remove public exposure.
• Evidence preservation: collect volatile data when relevant, retain logs, snapshot cloud resources, document commands run, preserve original files.

One common mistake is “containment-by-reimage” before capturing the facts. Your playbook should require an evidence checkpoint before destructive actions, with an approval step when CUI may be involved. ¹

Step 5: Define eradication and recovery with security acceptance criteria

Recovery is where teams accidentally reintroduce risk. Add acceptance checks:

• Patch applied or misconfiguration corrected.
• Credentials rotated where compromise is plausible.
• Persistence checks completed (EDR scans, scheduled tasks, startup items, cloud IAM review).
• Backups validated before restore, and restore actions logged.

Tie recovery to system owner sign-off for high-impact systems in the CUI boundary. ¹

Step 6: Close the loop with lessons learned and CAPA tracking

Require a short after-action record for incidents above a defined severity:

• What happened (facts only)
• Root cause or most likely cause
• Control gaps discovered
• Corrective actions, owners, and due dates
• Validation steps (how you know it’s fixed)

Track corrective actions in the same governance cadence you use for other security work (risk register, POA&M, or a remediation backlog). ¹

Step 7: Prove the control operates (tabletop + real ticket evidence)

Run at least one incident exercise that touches CUI boundary assumptions: identity compromise, endpoint malware, cloud storage exposure, third-party admin account compromise. Capture artifacts like you would for a real incident: timeline, decisions, communications, and follow-up tasks. ¹

If you use Daydream for third-party risk and evidence operations, treat your SOC/MSP and critical SaaS providers as incident-response dependencies: store their escalation contacts, contractual notification clauses, and prior incident attestations alongside your internal incident handling artifacts so audits don’t turn into a document scramble.

Required evidence and artifacts to retain (assessment-ready)

Use this checklist as your evidence binder for the 03.06.01: incident handling requirement:

Evidence	What it proves	Where to store
Incident Handling Policy + Procedure/Playbooks	Defined approach and scope	GRC repository with version control
Incident classification matrix	Consistent triage	Security wiki + controlled copy in GRC
Incident tickets/case records (sanitized if needed)	The process ran	Ticketing/IR system export + audit copies
Incident timelines	Investigation quality	Case notes or attached doc
Containment/eradication actions and approvals	Controlled response	Change records + ticket links
Log retention references (SIEM queries, exports)	Evidence preservation	SIEM case folder + retention settings snapshot
After-action review + CAPA items	Continuous improvement	Risk/POA&M tracker
Exercise report (tabletop or functional)	Preparedness	Exercise packet + attendance

Keep retention consistent with your contractual and internal requirements. What matters most in assessment is that you can produce complete records without rebuilding history from memory. ¹

Common exam/audit questions and hangups

Expect these prompts:

• “Show the written incident handling procedure for the CUI environment.” ¹
• “Walk me through your last incident: detection source, triage decision, containment, recovery, and closure.” ¹
• “Who can declare an incident, and how do you escalate after hours?” ¹
• “How do you handle incidents involving third parties with access to CUI systems?” ¹
• “Prove evidence preservation: what logs were pulled, and where are they stored?” ¹

Hangups that slow audits:

• No clear boundary for what counts as “CUI systems,” so the assessor can’t tell what the process covers.
• Tickets exist, but they lack decision rationale, timestamps, and approvals.
• The playbook exists, but responders don’t follow it because it’s not embedded in tools. ¹

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Policy-only compliance.
   Fix: Require at least one exercised case record and one real ticket sample with a complete timeline and closure tasks. ¹

2. Mistake: No severity definitions tied to CUI impact.
   Fix: Add a “CUI involved?” decision point in triage and an escalation rule when the answer is yes or unknown. ¹

3. Mistake: Containment destroys evidence.
   Fix: Put an evidence checkpoint before reimage/wipe, and train responders to snapshot/log-export first when feasible. ¹

4. Mistake: Third-party incidents are handled informally.
   Fix: Maintain third-party escalation contacts, notification requirements, and access paths as part of your incident handling runbook; test it in a tabletop. ¹

5. Mistake: Lessons learned are “nice to have.”
   Fix: Tie after-action items to a remediation tracker with owners and completion evidence (config changes, patches, control updates). ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite specific actions or penalties.

Operational risk still shows up quickly: weak incident handling increases the chance that a security event becomes a CUI exposure, extends outage time, and creates contractual reporting problems. The compliance risk is straightforward: if you cannot produce incident records and evidence of an operating process, you will likely fail an assessment of the 03.06.01: incident handling requirement. ¹

Practical 30/60/90-day execution plan

First 30 days (stabilize)

• Confirm the CUI boundary and list the systems and third parties that support it. ¹
• Publish incident handling policy + procedure and assign roles (IC, technical lead, comms, legal/contracts). ¹
• Configure the intake and ticket fields; create an “IR” case type with required fields and templated checklists. ¹

Days 31–60 (operate)

• Run a tabletop exercise against a realistic CUI scenario; produce the full exercise packet and CAPA list. ¹
• Validate evidence preservation steps: SIEM queries, endpoint isolation steps, cloud snapshot steps, log access permissions. ¹
• Align third-party escalation: confirm contacts, paths, and notification obligations; store them in your third-party risk records (Daydream can hold this alongside due diligence artifacts). ¹

Days 61–90 (prove and tune)

• Audit your last incidents (or exercises) against the playbook: missing timestamps, missing approvals, weak closure notes. Fix the templates. ¹
• Implement a lightweight metrics review for governance: case aging, CAPA closure, recurring incident types. Keep it qualitative if you can’t support precise benchmarks. ¹
• Package an assessor-ready evidence set: current documents, one exercise, one to two case samples, and the remediation tracker. ¹

Frequently Asked Questions

Does 03.06.01 require a dedicated incident response team?

It requires an incident handling capability with defined roles and procedures; that can be a small team with named responsibilities. What matters is that incidents are handled consistently and you can produce evidence that the process runs. ¹

Can we outsource incident handling to a third party SOC or MSP?

Yes, but you still own compliance and must define joint responsibilities, escalation, and communications. Keep contracts, escalation contacts, and example joint case records as evidence. ¹

What evidence is most persuasive to an assessor for this requirement?

Complete incident records: intake details, triage rationale, actions taken, approvals, timeline, and closure with corrective actions. A tabletop exercise packet can help, but real tickets are harder to dispute. ¹

How do we handle “suspected” CUI involvement during triage?

Treat “unknown” as a decision state with a required next step, such as scoping affected systems to the CUI boundary and preserving logs before destructive containment. Document the decision and what evidence changed the classification. ¹

Our ticketing system has limited fields; how do we make this audit-ready?

Add a required template in the description (or a linked form) that captures minimum fields, timeline, actions, and approvals. Consistency matters more than tool choice, as long as records are complete and retrievable. ¹

How should a CCO/GRC lead oversee incident handling without running the technical response?

Own governance: approve the policy and scope, confirm roles are staffed, require exercise evidence, and track corrective actions to closure. Review a small sample of incident records for completeness and alignment to the documented playbook. ¹

Footnotes

1. NIST SP 800-171 Rev. 3