SI-6(3): Report Verification Results

SI-6(3) is a small control enhancement with outsized audit impact because it tests whether your verification work reaches decision-makers. Many programs verify security and privacy functions (for example, log review, alerting, access controls, privacy monitoring) but fail to prove that results were routed to the right stakeholders with enough context to act. Assessors commonly interpret that gap as a breakdown in governance, not a tooling problem.

This requirement is also intentionally flexible: NIST leaves the recipient list open as an organization-defined parameter. That flexibility becomes your job as an operator. You must choose recipients that fit your environment (system owner, ISSO, privacy officer, SOC leadership, CISO/CCO governance bodies), document the choice, and then execute reporting consistently.

This page focuses on fast operationalization: how to define “verification,” what to report, who should receive it, and what evidence will satisfy an assessor. It also covers typical audit hangups and the documentation pattern that keeps SI-6(3) from becoming a last-minute scramble during an ATO, annual assessment, or customer due diligence.

What SI-6(3) requires (plain English)

SI-6(3) requires you to report the results of verification of security and privacy functions to a defined audience. The core test is simple: when your team checks that security and privacy functions are working as intended, do the results get communicated to the right people, in a form that supports action and oversight?

“Verification” in this context usually includes activities like:

• Validating security tooling and controls are operating (alerts firing, logs collected, access controls enforced)
• Checking privacy mechanisms (data handling controls, monitoring, minimization checks) where applicable to the system
• Reviewing outcomes, exceptions, and corrective actions from those checks

The operational goal: close the loop between “we verified something” and “the organization knows what happened and can fix issues.”

Regulatory text

Requirement: “Report the results of security and privacy function verification to {{ insert: param, si-06.03_odp }}.” (NIST SP 800-53 Rev. 5 OSCAL JSON)

Operator interpretation: You must (1) define who the recipients are (the organization-defined parameter), (2) generate verification results in a consistent format, and (3) demonstrate those results were reported to the defined recipients.

Where teams get stuck is treating the parameter as a placeholder. Don’t. Your recipients must be explicitly named (by role or group) in a controlled document, and you must show repeatable reporting.

Who it applies to

Entities

• Federal information systems implementing NIST SP 800-53 controls (NIST SP 800-53 Rev. 5)
• Contractor systems handling federal data where 800-53 is contractually required or inherited through an authorization boundary (NIST SP 800-53 Rev. 5)

Operational contexts where SI-6(3) shows up

• ATO / continuous monitoring programs (system-level governance)
• SOC operations where verification checks occur but reporting is informal
• Privacy programs embedded in system monitoring (especially where privacy controls are in scope)
• Third-party hosted environments where verification evidence is split between your team and a cloud/service provider

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

Step 1: Define the reporting recipients (the ODP)

Create a short, explicit recipient definition. Use roles/groups, not names, so it survives staffing changes. Examples:

• System Owner (SO)
• ISSO / ISSE
• SOC Manager or Incident Response Lead
• Privacy Officer (if privacy functions are in scope)
• CISO/CCO risk committee or security governance forum (if that’s your operating model)

Document the choice in your SSP/control narrative and cross-reference your governance charters where relevant.

Audit objective: recipients are defined, appropriate, and stable.

Step 2: Define what counts as “verification” in your program

Make a list of verification activities that you already perform (or should perform) and tie them to owners and sources. Typical inputs:

• Daily/weekly/monthly control health checks (EDR status, log forwarding, backup restore tests)
• SIEM detection verification or alert testing
• Privileged access monitoring checks
• DLP or data discovery checks (if used)
• Privacy monitoring checks (if implemented) tied to privacy requirements

Keep the list small enough to run reliably. If you claim too much, you inherit an evidence burden you won’t sustain.

Audit objective: verification is defined and repeatable, not ad hoc.

Step 3: Standardize the “verification results” format

Create a template that converts raw checks into decision-ready reporting. Minimum fields that work well in practice:

• Verification activity name + scope (system/environment)
• Date/time performed and period covered
• Result status (pass / fail / partial / not performed) with rationale
• Exceptions found (what failed, where, and why it matters)
• Risk statement (impact if unresolved)
• Corrective action (owner, target date, tracking ticket)
• Dependencies (third party responsibility, inherited control notes)

Use the same structure across security and privacy function verification where applicable.

Audit objective: results are actionable, not just raw logs or screenshots.

Step 4: Establish the reporting mechanism and cadence

Pick a mechanism that creates durable evidence:

• Ticketing workflow that routes a “verification results” ticket to defined recipients
• Scheduled email distribution to a controlled mailing list
• GRC workflow task with assignment and acknowledgment
• Standing governance meeting agenda item with minutes and attachments

Cadence can be aligned to your continuous monitoring schedule. NIST does not dictate a frequency in the control text, but your program must be consistent and defensible (NIST SP 800-53 Rev. 5).

Audit objective: reporting happens routinely and predictably.

Step 5: Prove delivery and follow-up

This is where SI-6(3) often fails. You need evidence that results were actually reported and reviewed:

• Delivery: sent email, ticket assignment, or GRC task completion
• Review/triage: comments, approvals, meeting minutes, or acknowledgment
• Action: linked remediation tickets, accepted risk records, or change requests

If findings repeat, show trend visibility and escalation.

Audit objective: oversight exists; issues don’t disappear into inboxes.

Step 6: Map SI-6(3) to a control owner, procedure, and recurring evidence

Assign one accountable owner (not a shared mailbox). Then write a short SOP: inputs, steps, outputs, storage location, and exception handling. This aligns with the practical control guidance to map SI-6(3) to an owner, procedure, and evidence artifacts (NIST SP 800-53 Rev. 5 OSCAL JSON).

If you use Daydream, this is where it fits naturally: store the control narrative, assign ownership, schedule evidence collection, and keep a clean audit trail of recurring artifacts tied to each reporting cycle.

Required evidence and artifacts to retain

Use an evidence bundle approach so each verification cycle produces a consistent packet:

Artifacts (keep examples for multiple cycles):

• Control narrative/SSP excerpt defining recipients (ODP) and reporting method (NIST SP 800-53 Rev. 5 OSCAL JSON)
• Verification schedule or continuous monitoring plan excerpt showing verification activities
• Completed verification reports (template outputs) for sampled periods
• Proof of reporting:
  • Ticket records showing assignment to recipients and timestamps, or
  • Email distribution logs to defined groups, or
  • GRC task completion/attestation records
• Meeting minutes or governance notes showing review and decisions
• Remediation evidence: linked tickets, change records, risk acceptances

Retention note: match your organization’s records retention requirements; SI-6(3) does not specify a retention period (NIST SP 800-53 Rev. 5).

Common exam/audit questions and hangups

Assessors tend to focus on these points:

• “Who exactly receives the results?” If you can’t name the roles/groups, you fail the parameterization test.
• “Show me evidence for multiple periods.” One perfect report is not enough; they want operational consistency.
• “How do you know recipients reviewed it?” Delivery alone often gets challenged; show acknowledgment, minutes, or downstream actions.
• “What about privacy function verification?” If privacy controls are in scope, they will ask how privacy verification is included, not handled informally.
• “How do you handle third-party/inherited controls?” You still must report the verification results you receive or perform, and document dependencies.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Leaving the recipient list vague (“security team”).
   Fix: define specific roles or governed distribution lists; document them in the control narrative.

2. Mistake: Reporting raw tool exports.
   Fix: wrap tool outputs in an operator summary that states result, exceptions, impact, and next steps.

3. Mistake: No proof of delivery.
   Fix: route reports through systems that log delivery and acknowledgment (ticketing/GRC), not informal chat threads.

4. Mistake: No linkage to corrective action.
   Fix: require every “fail/partial” result to reference a remediation ticket or risk acceptance.

5. Mistake: Privacy omitted because “security owns SI controls.”
   Fix: confirm whether privacy functions are in scope for the system boundary; add the privacy recipient and relevant checks where applicable.

Risk implications (practical)

SI-6(3) failures usually signal governance drift: verification exists, but leadership oversight and accountability are weak. The real risk is operational: recurring control failures persist because they are not escalated, tracked, or owned. During authorization or customer assessments, that pattern can also damage credibility because it suggests your continuous monitoring loop is incomplete (NIST SP 800-53 Rev. 5).

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

First 30 days (Immediate stabilization)

• Name the SI-6(3) control owner and backup.
• Define recipients (ODP) by role/group and publish in the SSP/control narrative.
• Inventory current verification activities and pick the set you will report consistently.
• Create the reporting template and decide your evidence system of record (ticketing or GRC).

By 60 days (Operational reporting live)

• Run at least one full reporting cycle end-to-end: verification, report creation, delivery, acknowledgment, and action tracking.
• Train SOC/control owners on the template and the minimum reporting quality bar.
• Start a central register of verification reports with immutable timestamps.

By 90 days (Assessment-ready)

• Demonstrate repeatable reporting across multiple cycles with consistent recipients.
• Add quality checks: review for completeness, stale findings, and missing corrective actions.
• Run an internal “auditor drill”: sample a report, trace it to delivery evidence, then to remediation closure.

Frequently Asked Questions

What counts as “security and privacy function verification” for SI-6(3)?

Any repeatable activity where you confirm security or privacy functions are operating as intended can qualify. Document your specific verification set and keep it consistent so you can produce comparable results over time (NIST SP 800-53 Rev. 5).

Do I have to report to executives?

NIST requires reporting to an organization-defined recipient set, not a specific level (NIST SP 800-53 Rev. 5 OSCAL JSON). Choose recipients who can accept risk, fund remediation, or direct operational changes, and document the rationale.

Is an email enough to satisfy “report the results”?

Email can work if it goes to a controlled distribution list and you retain proof of sending plus evidence of review or follow-up. Many teams prefer ticketing or GRC tasks because they produce cleaner delivery and acknowledgment evidence.

How do I handle verification results provided by a cloud service provider or other third party?

Treat third-party verification outputs as inputs to your reporting. Store the third party’s report, summarize system impact, and report it to your defined recipients along with any gaps, shared responsibility notes, and required actions.

What evidence do auditors usually sample for SI-6(3)?

They typically sample multiple reporting cycles and trace each from verification activity to report output to delivery evidence and corrective action tracking. Prepare a packaged evidence trail per cycle so sampling is fast.

How can Daydream help operationalize SI-6(3) without adding process overhead?

Use Daydream to assign the SI-6(3) owner, store the recipient definition, schedule recurring evidence requests, and keep the reporting artifacts and delivery proofs tied to each cycle in one audit-ready record.