SI-2(3): Time to Remediate Flaws and Benchmarks for Corrective Actions

To meet the si-2(3): time to remediate flaws and benchmarks for corrective actions requirement, you must measure how long it takes to remediate each identified flaw and manage that work against defined remediation benchmarks (targets) that drive timely corrective action. Operationalize it by standardizing timestamps, severity-based targets, exception handling, and recurring reporting tied to accountable owners. ¹

Key takeaways:

• You need a measurable clock: “identified” and “remediated” must be defined consistently, then tracked for every flaw.
• Benchmarks must be explicit (by severity/system tier), enforced through workflow, and supported by exceptions with documented risk acceptance.
• Evidence is mostly operational exhaust: scanner outputs, ticket data, SLA reports, and management review artifacts.

SI-2(3) is an operations control disguised as a measurement control. Auditors and assessors will not be satisfied by a patch policy alone; they will look for proof that your organization can quantify remediation performance and manage it against agreed benchmarks. The excerpt is short, but the expectation is concrete: you identify flaws, you remediate them, and you can show elapsed time between those two events with repeatable logic. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat SI-2(3) as a closed-loop workflow requirement: define what starts the clock, define what stops it, set remediation benchmarks by risk, and produce reporting that supports prioritization and corrective action when benchmarks are missed. This page gives you requirement-level implementation guidance you can hand to vulnerability management, infrastructure, application teams, and ITSM owners without rewriting it into theory.

If you already run vulnerability scanning and ticketing, you are halfway there. The gap is usually measurement integrity (bad timestamps, inconsistent closure criteria) and governance (no enforceable targets, weak exception approvals, and no management review cadence).

Regulatory text

Requirement excerpt: “Measure the time between flaw identification and flaw remediation; and” ¹

What the operator must do:
You must implement a repeatable method to (1) record when a flaw is identified, (2) record when that same flaw is remediated, and (3) compute elapsed time in a way you can report and manage. The “and” indicates this is part of a broader enhancement concept (“benchmarks for corrective actions”), so measurement alone is insufficient; you need benchmarks that trigger prioritization, escalation, and corrective action when remediation runs long. ¹

Plain-English interpretation of the requirement

• Measure remediation time means you can answer: “How long did this vulnerability/misconfiguration/patch gap exist after we knew about it?”
• Benchmarks for corrective actions means you set targets (by severity and context) and use them to drive action: assignment, due dates, escalation, exception review, and management oversight.

This is not a “one-time report.” Assessors expect an operating practice: ongoing measurement, trend visibility, and evidence that benchmarks influence what gets fixed first.

Who it applies to (entity and operational context)

SI-2(3) commonly applies where NIST SP 800-53 is the governing framework, including:

• Federal information systems and programs assessed against NIST SP 800-53. ²
• Contractor systems handling federal data, including environments that support federal missions or process federal information. ²

Operationally, it applies wherever you manage flaws:

• Infrastructure and endpoint patching
• Cloud configuration and container/image scanning
• Application security findings (SAST/DAST, dependency and SBOM-related findings)
• Network device and appliance vulnerabilities
• Third-party hosted systems in your authorization boundary (or inherited controls you must monitor)

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

Step 1: Define flaw scope and normalize categories

Create a short “flaw taxonomy” that your tooling can support:

• Vulnerabilities (CVE findings)
• Configuration weaknesses (CIS/benchmarks, cloud misconfigs)
• Missing patches / outdated packages
• Security defects from SDLC tooling (if in-scope for your SSP/control boundary)

Write down what is in-scope for SI-2(3) measurement and what is tracked elsewhere, then stick to it.

Step 2: Define the clock start and stop (measurement integrity)

Document precise definitions and enforce them in workflow:

Clock start (“identified”)—choose one and standardize

• Scanner detection timestamp (first observed)
• Triage timestamp (validated and accepted as real)
• Ticket creation timestamp (if you can prove it is not delayed)

Clock stop (“remediated”)—must be verifiable

• Patch applied and confirmed by a rescan
• Misconfiguration corrected and verified by policy-as-code or rescan
• Compensating control applied (only if your benchmark policy treats this as remediation, and you can prove effectiveness)
• Risk accepted (do not count as “remediated” unless your governance explicitly defines and reports accepted risk separately)

Most programs fail here. If closure is based on “ticket marked done” without technical validation, your measurement becomes audit-fragile.

Step 3: Set remediation benchmarks (targets) that drive behavior

Define benchmarks by:

• Severity/criticality of flaw (e.g., scanner severity or exploitability signals)
• System tier (internet-facing, regulated data, mission critical)
• Asset class (workstations vs servers vs containers)
• Change constraints (maintenance windows, vendor dependencies)

Benchmarks must be written as enforceable internal requirements: “must remediate within X for category Y,” with a defined exception process. SI-2(3) does not dictate the numbers; you set them based on risk tolerance and operational reality. ¹

Step 4: Implement workflow controls in the systems people already use

Operationalize in your ITSM / ticketing and vulnerability management tooling:

• Auto-create tickets from findings (or batch ingestion) with consistent identifiers.
• Add required fields: severity, asset owner, system tier, identification timestamp, due date derived from benchmark, and validation method.
• Enforce SLAs: due dates, escalations, and exception approvals.
• Require verification evidence before closure (rescan ID, screenshot, config state record, package version, etc.).

Step 5: Build reporting that supports corrective action

Minimum reporting set for SI-2(3):

• Time to remediate (TTR) distribution by severity and system tier
• Benchmark compliance: on-time vs overdue counts and trends
• Aging backlog: oldest open items by severity/system
• Exception register: open risk acceptances and compensating controls, with expiry dates and approvers

Use the report to run a monthly (or more frequent) remediation review with engineering owners. Capture decisions and action items.

Step 6: Run governance: ownership, escalation, and exception handling

Assign clear ownership:

• Vulnerability Management owner: measurement method, reporting, tooling integrity
• System owners: remediation execution
• Change management: scheduling and risk of changes
• GRC/Compliance: benchmark policy, exception governance, evidence readiness

Define escalations:

• Overdue criticals escalate to system owner leadership
• Chronic benchmark misses trigger root-cause analysis and corrective action plans (staffing, patch process fixes, automation, or architectural changes)

Step 7: Extend to third parties where you inherit risk

Where third parties operate systems in your boundary (hosted platforms, managed services), require:

• Their remediation benchmarks or your required benchmarks
• Periodic TTR reporting
• Evidence upon request (attestation is weaker than operational evidence)

Daydream note: Daydream is a practical place to map SI-2(3) to a control owner, a written procedure, and a recurring evidence checklist so measurement/report artifacts are consistently collected across teams and audit cycles.

Required evidence and artifacts to retain

Keep artifacts that prove both measurement and management against benchmarks:

Control design (static)

• Remediation benchmark standard (policy/standard) with categories and required timeframes
• Defined “identified” and “remediated” timestamps and validation rules
• Exception/risk acceptance procedure, including expiry and approval authority
• RACI for flaw remediation and reporting

Control operation (dynamic)

• Vulnerability/misconfiguration scan outputs and schedules
• Ticket records with timestamps (created/assigned/due/closed) and linkage to findings
• Rescan/verification evidence showing remediation completion
• Benchmark compliance reports and dashboards (exported snapshots)
• Meeting minutes/action logs from remediation review forums
• Exception register with approvals and periodic review evidence

Common exam/audit questions and hangups

Expect these:

• “Show how you calculate time between identification and remediation for a sample of findings.” ¹
• “What benchmarks exist, who approved them, and how do they differ for high-value systems?”
• “How do you prevent teams from closing tickets without technical verification?”
• “How are exceptions granted, and how do you ensure they expire or get re-validated?”
• “Demonstrate trending and corrective actions taken when benchmarks are missed.”

Hangups that trigger findings:

• Multiple “truth sources” (scanner vs ticketing) with mismatched timestamps
• No consistent identifier linking a finding to a remediation record
• Benchmarks exist but are not enforced (no due dates, no escalation, no review cadence)

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Measuring from ticket creation when ticket creation is delayed	Understates exposure window	Use first observed or validated timestamp; enforce prompt ticket creation
Counting “risk accepted” as “remediated”	Masks backlog and weakens governance	Track accepted items separately; report acceptance duration and expiry
Closing without verification	Converts control into an honor system	Require rescan/validation artifact before closure
One benchmark for everything	Ignores system criticality and change constraints	Tier benchmarks by severity and system tier; document rationale
Reporting exists but no action	Violates “benchmarks for corrective actions” intent	Add escalation, recurring review, and CAPA triggers

Enforcement context and risk implications

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

Risk-wise, weak TTR measurement and unenforced benchmarks commonly show up as:

• Larger vulnerability exposure windows
• Inability to prove “timely remediation” during assessments and incident post-mortems
• Uncontrolled exceptions that become permanent risk

From a program perspective, SI-2(3) is also a credibility control: if you cannot measure TTR reliably, every “we patch quickly” claim becomes hard to defend.

Practical 30/60/90-day execution plan

First 30 days (baseline and definitions)

• Assign control owner and approve scope (what counts as a flaw for SI-2(3)).
• Define “identified” and “remediated” timestamps and verification rules.
• Inventory data sources (scanner tools, CSPM, SAST/DAST, ITSM) and confirm you can extract timestamps.
• Produce a baseline report from existing data, label gaps explicitly (missing linkage, missing verification).

Next 60 days (benchmarks and workflow enforcement)

• Publish remediation benchmarks by severity/system tier and embed due-date logic into tickets.
• Implement required ticket fields and closure requirements (verification evidence).
• Stand up an exceptions workflow with approvers and expiry tracking.
• Start recurring remediation review meetings with owners; capture actions and escalations.

By 90 days (operational cadence and audit-ready evidence)

• Stabilize automated reporting for TTR, benchmark compliance, and aging backlog.
• Run at least one management review cycle that results in documented corrective actions.
• Perform an internal sample test: pick findings and trace identification → ticket → remediation → verification → reporting.
• Package evidence artifacts into an assessor-ready folder structure (by month/quarter and by system tier).

Frequently Asked Questions

What counts as a “flaw” for SI-2(3)?

Treat flaws as security-relevant weaknesses your program can remediate and verify, such as vulnerabilities and misconfigurations. Write the scope down and align it to the systems in your assessment boundary. ¹

Do we need to use scanner “first seen” time, or can we use ticket creation time?

You can choose a consistent start point, but you must defend it and apply it uniformly. If ticket creation lags detection, ticket time can understate exposure; many teams standardize on first observed or validated timestamps.

How do we handle remediation that requires a vendor patch or planned maintenance window?

Track it against the same benchmark, then route delays through an exception process with documented approvals and compensating controls. Keep evidence of the dependency (vendor advisory, change calendar entry) and the approval decision.

Can compensating controls stop the clock?

Only if your governance explicitly defines compensating controls as an acceptable remediation state and you can verify the control’s operation. Otherwise, keep the item open (or in an exception state) until permanent remediation is verified.

What evidence do assessors ask for most often?

They usually sample findings and ask you to show timestamps, due dates, closure verification, and benchmark reporting for the same items. Prepare traceability from the original finding through remediation validation and management review.

How should third parties fit into SI-2(3)?

If a third party operates in-scope systems, require contractual benchmarks or reporting that lets you measure their remediation time. If you cannot get raw evidence, document what you receive (reports/attestations) and how you validate them.

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5