03.06.04: Incident Response Training

To meet the 03.06.04: incident response training requirement, you must run role-appropriate incident response (IR) training for personnel who have IR responsibilities, on a defined cadence, and keep proof that training occurred and was effective. Operationalize it by defining IR roles, building a short training curriculum tied to your IR plan, and retaining attendance, content, and follow-up actions. ¹

Key takeaways:

• Training must be role-based for people who perform incident response work, not generic security awareness. ¹
• Auditors look for repeatable execution plus evidence: curriculum, rosters, completion records, and updates after lessons learned. ¹
• The fastest path is to map the requirement to policy, assign ownership, schedule recurring sessions, and automate evidence collection. ¹

03.06.04 sits in the incident response family of NIST SP 800-171 Rev. 3 and is straightforward to state but easy to fail in practice: you need incident response training that is planned, repeatable, and provable. Many programs have an incident response plan and even run occasional tabletop exercises, yet still struggle to show that the right people were trained on their specific responsibilities and that training outcomes changed behavior or improved readiness.

For a Compliance Officer, CCO, or GRC lead, the operational goal is simple: make incident response training a managed control with clear scope, role mapping, a defined cadence, and evidence that stands up during a customer assessment, prime contractor review, or an internal audit. This page gives you a requirement-level playbook: who must be trained, what “good” training content looks like, which artifacts to retain, and the exam questions that typically expose gaps.

You do not need a large IR department to comply. You need clarity: who responds, what they must do, how they learn it, and how you prove it later. ¹

Regulatory text

Requirement: “NIST SP 800-171 Rev. 3 requirement 03.06.04 (Incident Response Training).” ¹

Operator interpretation (what you must do):

• Provide training for personnel who have incident response roles or responsibilities. Training must prepare them to execute your organization’s incident handling process, not a generic “cybersecurity 101” module. ¹
• Make training part of your managed control system: defined scope, assigned ownership, a recurring schedule, and retained records. ¹

Plain-English interpretation of the requirement

If someone is expected to help detect, triage, contain, eradicate, recover, communicate, or preserve evidence during an incident, they must be trained to do that job the way your IR plan says it gets done. Then you must be able to prove it with artifacts that show what training occurred, who took it, and how you keep it current. ¹

This requirement is about readiness. Your incident response plan can be well-written and still fail operationally if responders do not know:

• escalation paths and decision rights,
• what must be documented,
• how to protect Controlled Unclassified Information (CUI) during response,
• how to coordinate with IT, security operations, Legal, HR, and Communications.

Who it applies to

Entity scope

• Federal contractors and other organizations operating nonfederal systems that handle CUI where NIST SP 800-171 Rev. 3 is contractually required. ¹

Operational scope (who needs training) Focus on people with incident response duties, including:

• Security/IT responders (SOC, IT ops, endpoint, network, cloud admins)
• Incident commander or on-call manager
• Help desk or service desk (often first detection and ticket routing)
• Legal/compliance points of contact (notification, chain-of-custody expectations)
• HR (insider events, employee communications)
• Communications/customer success leads (external messaging coordination)
• System owners for CUI environments
• Key third parties with contracted IR duties (MSSP, DFIR retainer), where you must confirm their role alignment and your internal staff’s coordination steps

A practical scoping test: if the IR plan names the role, or the role is on an on-call roster, that role needs IR training mapped to its responsibilities.

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

1) Assign ownership and define the control boundary

• Name an IR Training Owner (often IR lead, Security GRC, or IT Security manager) with responsibility for curriculum, scheduling, and evidence.
• Define the system boundary where CUI is processed, stored, or transmitted, and confirm that your IR process and training apply to those systems and support teams. ¹

2) Map roles to responsibilities (this is where audits are won)

Create a role-to-training matrix. Minimum columns:

• Role title (e.g., “Help Desk Analyst,” “Cloud Administrator,” “IR Commander”)
• IR responsibilities (triage, containment steps, evidence handling)
• Required training modules
• Frequency trigger (recurring cadence; plus ad hoc triggers like major process change)
• Evidence produced (LMS record, roster, quiz score, attestation)

This matrix becomes your control “spine.” It also prevents a common failure mode: training only the security team while leaving IT and service desk unprepared.

3) Build a curriculum tied directly to your IR plan

Your training should reference your organization’s real procedures and tools. Use short modules that match roles:

Core module (for all IR-involved roles)

• How to recognize and declare an incident vs. event
• How to report/escalate (channels, after-hours process)
• Documentation requirements (ticketing, timeline, decision log)
• CUI handling during response: least exposure, secure sharing, approved repositories ¹

Technical responder module (IT/SecOps)

• Initial triage steps (endpoint isolation, account disablement, log preservation)
• Forensics hygiene: what not to do (avoid wiping evidence), how to collect artifacts
• Tooling basics (EDR actions, SIEM queries, firewall blocks)

Leadership/IC module

• Severity classification, decision rights, and containment tradeoffs
• Stakeholder coordination (Legal/Compliance/Program management)
• Third-party engagement (MSSP/DFIR), including when to call and what to provide

Legal/Compliance/HR/Comms module

• Internal notification sequence
• Data handling constraints and approval steps for external communications
• Recordkeeping expectations during response (who approves what, where it’s stored)

Training does not have to be long. It must be specific enough that a trained person can follow your playbooks under stress.

4) Run training on a defined cadence and after material changes

• Schedule recurring sessions and new-hire onboarding for IR roles.
• Trigger retraining when you change IR tooling, escalation contacts, severity model, or the IR plan materially.
• Include a mechanism for “lessons learned” to feed back into training content after incidents or exercises.

Your internal standard can define timing; the compliance objective is that training is repeatable and current. ¹

5) Validate effectiveness (lightweight is fine, but document it)

Pick one or more:

• short knowledge checks (quiz),
• scenario walkthroughs for each role,
• tabletop exercises with attendance and action items,
• supervisor sign-off that the person can execute assigned steps.

Effectiveness evidence matters because auditors often see “attendance-only” programs that do not translate into operational readiness.

6) Retain evidence in an audit-ready package

Store artifacts in a single control folder, tagged to the requirement. Daydream can help by mapping 03.06.04 to your policy/control statements and setting up recurring evidence requests so training records, rosters, and updates are collected on schedule and ready for assessments. ¹

Required evidence and artifacts to retain

Keep artifacts that answer: who, what, when, and what changed because of it.

Minimum evidence set

• Incident Response Training policy/standard (scope, roles, cadence, owner)
• Role-to-training matrix (the mapping document)
• Training content (slides, runbooks, recordings, or LMS module export)
• Attendance/completion records (LMS exports or signed rosters)
• Knowledge checks or attestations (quiz results, sign-offs)
• Exception records (who missed training, remediation plan)
• Change log showing training updates after IR plan changes or lessons learned

Nice-to-have (often decisive in audits)

• Tabletop/exercise after-action report with action items
• Updated runbooks reflecting improvements
• On-call roster showing trained coverage for key roles

Common exam/audit questions and hangups

Auditors and customer assessors tend to probe these points:

1. “Who has incident response responsibilities?”
   Hangup: your IR plan says “IT will respond,” but you cannot name roles or individuals.

2. “Show me the training content and how it maps to responsibilities.”
   Hangup: only generic security awareness content is available.

3. “Prove it’s recurring and current.”
   Hangup: one-off training exists but no schedule, no triggers for retraining after changes.

4. “How do you know the training works?”
   Hangup: no quizzes, no exercises, no supervisor verification, no post-exercise improvements.

5. “Do third parties participate?”
   Hangup: you outsource monitoring/IR steps but have no documented coordination training for internal staff.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Treating IR training as general security awareness	03.06.04 is role-based IR readiness, not broad awareness. 1	Create IR modules tied to your IR plan and runbooks.
No role mapping	You cannot prove the right people were trained.	Maintain a role-to-training matrix and keep it updated with org changes.
Training exists, evidence does not	Assessments are evidence-driven.	Centralize records; export LMS reports; store rosters and content snapshots.
“We did a tabletop” but no follow-up	Exercises without corrective actions do not show operational improvement.	Write an after-action report; track action items; update training/runbooks.
Ignoring IT/service desk	First responders often sit outside the security team.	Include service desk, system owners, and on-call managers in scope.

Enforcement context and risk implications

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

Risk-wise, weak incident response training increases the chance that an event becomes a reportable incident, expands scope, or results in loss of CUI due to mishandled containment and evidence. From a compliance lens, the most common failure is not “no training happened,” but “training happened and you cannot prove it in a way that maps to 03.06.04.” ¹

Practical execution plan (30/60/90-day)

You asked for speed. Use phased execution without calendar guarantees.

First 30 days (get to “auditable minimum”)

• Name the IR training owner and approver.
• Inventory IR roles and build the role-to-training matrix.
• Gather existing materials: IR plan, runbooks, past tabletop notes, LMS content.
• Publish a short IR training standard and an evidence checklist for 03.06.04. ¹

Next 60 days (run training and close coverage gaps)

• Deliver the core module to all IR-in-scope roles.
• Deliver technical and leadership modules to responders and incident commanders.
• Stand up lightweight effectiveness checks (quiz or sign-off).
• Centralize evidence storage and standardize naming (date, module, audience, trainer).

Next 90 days (make it repeatable)

• Add retraining triggers tied to IR plan/tooling changes.
• Run a tabletop exercise; publish an after-action report; track action items to closure.
• Operationalize recurring evidence collection in Daydream: scheduled requests for LMS exports, updated role mapping, and content revision history. ¹

Frequently Asked Questions

Does general security awareness training satisfy 03.06.04?

Usually no. 03.06.04 expects training for personnel with incident response responsibilities, tied to your incident handling process and roles. ¹

Who counts as having “incident response responsibilities”?

Anyone expected to detect, report, triage, contain, preserve evidence, coordinate communications, or approve response actions in CUI environments. If a role is in your IR plan, on-call roster, or runbooks, treat it as in scope. ¹

What evidence do auditors ask for first?

A role-to-training mapping plus completion records (LMS exports or rosters) and the actual training content. After that, they often ask how you keep training current and how you measure effectiveness. ¹

We outsource monitoring to a third party. Do we still need internal IR training?

Yes, because internal teams still make decisions, coordinate access, handle CUI, and manage communications. Train internal roles on how to engage the third party and execute your parts of the process. ¹

Can tabletop exercises count as incident response training?

They can support training if you document objectives, attendance, scenario, outcomes, and follow-up actions. Most teams still pair tabletops with short role-based modules for consistent coverage. ¹

How do we operationalize this without building a new program from scratch?

Start with your IR plan, extract roles and steps into a matrix, then build short modules that teach those steps. Use Daydream to map 03.06.04 to the control owner, set recurring evidence tasks, and keep an audit-ready record set. ¹

Footnotes

1. NIST SP 800-171 Rev. 3