SR-1: Policy and Procedures

SR-1 sits at the front of the NIST SP 800-53 Supply Chain Risk Management (SR) family. If you cannot show a clear SR policy and procedures, most downstream SR controls become hard to defend because assessors treat SR-1 as the governance “hook” that makes the rest enforceable and repeatable. SR-1 is also one of the easiest controls to “think you have” but fail in an assessment: teams often have fragments (a procurement SOP, a security policy, a vendor questionnaire) without a single, approved SR policy and a procedure that tells operators what to do, when to do it, and where to record evidence.

This page is written for a Compliance Officer, CCO, or GRC lead who needs to implement SR-1 quickly in real environments: federal information systems and contractor systems handling federal data. You’ll get a plain-English interpretation, an implementation checklist, the artifacts to retain, and the exam questions that commonly stall teams. Where helpful, it also calls out how to structure SR-1 so it supports third-party risk management and vendor due diligence programs without turning into a paper exercise.

Regulatory text

NIST’s SR-1 control begins with: “Develop, document, and disseminate to {{ insert: param, sr-1_prm_1 }}:” ¹. The excerpt indicates a required action pattern that repeats across NIST: you must (1) develop policy and procedures, (2) document them, and (3) disseminate them to defined audiences (the parameter is where your organization specifies recipients).

What the operator must do with this text

• Develop: Decide what your SR program requires (scope, roles, minimum expectations).
• Document: Publish a controlled policy and procedure set with identifiers, versioning, approvals, and effective dates.
• Disseminate: Identify recipients (by role/team), distribute through a controlled channel, and keep proof of distribution and awareness.

Reference: NIST SP 800-53 Rev. 5 ².

Plain-English interpretation (what SR-1 really requires)

SR-1 requires you to write down how your organization manages supply chain risk for systems and services, and to write down the repeatable steps teams follow to execute that policy. Then you must get those documents into the hands of the people who must follow them (security, procurement, legal, engineering, IT operations, program managers, and business owners as applicable) and be able to prove it.

In practice, SR-1 becomes your “source of truth” for:

• How you categorize third parties and supply chain relationships in scope
• Minimum due diligence expectations before onboarding
• Contract and flowdown requirements (security requirements passed to third parties)
• Ongoing monitoring triggers and reassessment expectations
• Exception handling, risk acceptance, and governance

Who it applies to (entity and operational context)

SR-1 is commonly applied where NIST SP 800-53 is the governing control baseline, including:

• Federal information systems ²
• Contractor systems handling federal data ²

Operationally, SR-1 touches multiple functions:

• Security/GRC: owns the control design, assessment readiness, and risk governance
• Procurement/Vendor Management: operationalizes third-party onboarding, renewals, and contracting workflows
• Legal/Contracts: implements security requirements, flowdowns, and breach notice terms
• IT/Engineering: manages technical intake for SaaS, software dependencies, and integrations
• Program owners: accept residual risk and ensure business adoption

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

Use this sequence to get to “auditable” quickly.

1) Assign ownership and define SR-1 scope

1. Name a control owner (role + person) and a backup owner.
2. Define scope boundaries:
   • Systems in scope (federal system boundary, enclaves, or corporate systems supporting federal data)
   • Supply chain relationships in scope (SaaS, cloud, MSPs, OEMs, software libraries, contractors, data processors)
3. Set a policy authority chain: who approves (CISO, CIO, risk committee) and who enforces (procurement, security operations).

Deliverable: SR-1 Control Statement (one page) that says “SR-1 is satisfied by Policy X and Procedure Y” plus owner and scope.

2) Draft the SR policy (what must be true)

Your SR policy should read like enforceable requirements, not guidance. Include:

• Purpose and scope (what systems/relationships it covers)
• Roles and responsibilities (security, procurement, legal, system owners)
• Minimum supply chain risk activities (pre-engagement, contracting, ongoing monitoring, offboarding)
• Risk acceptance and exception handling (who can approve, required documentation)
• Required recordkeeping (what artifacts must exist for each third party)

Keep the policy stable. Put operational detail in procedures.

3) Write procedures (how it’s done, step-by-step)

Create procedures that match how work actually flows. At minimum, write procedures for:

• Third-party intake and tiering (how you classify criticality and data sensitivity)
• Due diligence (security questionnaire, SOC reports, pen test summaries, SBOM where applicable, financial viability checks if required)
• Contracting and flowdowns (security addendum, incident notification, subcontractor controls)
• Ongoing monitoring (what events trigger review: renewals, scope changes, incidents, material control failures)
• Offboarding (data return/destruction, access removal, continuity planning)

Procedure format that passes audits:

• Trigger → Inputs → Steps → Decision points → Outputs/evidence → SLAs (optional) → Exception path → Record location.

4) Define “dissemination” as a controlled activity

You need a clear answer to: “Who received this, and how do you know?”

• Identify required recipients by role (not individual names only): procurement team, vendor management, security reviewers, system owners, contract managers.
• Distribute through controlled channels: GRC tool policy module, intranet with access logs, document management system with read/attest workflows.
• Track acknowledgments where feasible (policy attestation, training completion, ticketing workflow acknowledgments).

5) Map SR-1 to recurring evidence artifacts (assessment readiness)

This is the fastest way to operationalize SR-1 and avoid “we have a policy” failures. Build a simple mapping:

SR-1 element	Owner	Where documented	Evidence you keep
SR policy exists and is approved	GRC/InfoSec	Policy repository	Approved policy PDF, approval record, version history
Procedures exist and match operations	Procurement + Security	SOP repository / GRC	Procedure docs, workflow diagrams, RACI
Dissemination completed	GRC	LMS / intranet / GRC	Distribution list, attestations, training records, access logs
Periodic review and updates	Control owner	Policy governance schedule	Review meeting notes, change log, re-approval records

Recommended approach: explicitly map SR-1 to the control owner, implementation procedure, and recurring evidence artifacts ¹.

Where Daydream fits naturally If you struggle to keep SR-1 “alive” (current documents, owners, review cycles, evidence), Daydream can act as the system of record for control ownership, procedure linkage, and evidence collection so SR-1 doesn’t degrade into outdated PDFs and missing screenshots.

Required evidence and artifacts to retain

Keep artifacts that prove design (policy/procedure exists and is approved) and operation (people follow it).

Minimum evidence set:

• SR policy document: version, effective date, approvals
• SR procedures: intake/tiering, due diligence, contracting/flowdowns, monitoring, offboarding
• RACI or responsibility matrix tied to SR activities
• Dissemination records:
  • distribution list (roles/teams)
  • policy attestations or training completion reports
  • publication record (doc system link + access controls)
• Review/maintenance artifacts:
  • policy/procedure review schedule
  • change log and re-approval records
• Crosswalk: SR-1 mapped to internal control library, owners, and evidence cadence

Tip from practice: store evidence where it can be exported quickly (single folder per control with subfolders for policy, procedure, dissemination, reviews).

Common exam/audit questions and hangups

Expect these questions from assessors aligned to NIST SP 800-53:

1. Show me the SR policy and procedures. Are they current, approved, and in scope?
2. Who are the recipients? How did you determine the dissemination audience ({{ sr-1_prm_1 }})?
3. How do you know teams follow the procedure? Show tickets, approvals, completed due diligence packages, or workflow logs.
4. How often do you review and update SR policy/procedures? Show review artifacts and change history.
5. How do exceptions work? Show an exception request, risk acceptance, compensating controls, and approval authority.

Common hangup: the policy exists, but procedures are vague (“perform risk assessment”) without steps, decision criteria, or evidence outputs.

Frequent implementation mistakes and how to avoid them

• Mistake: Treating SR-1 as a “security-only” policy.
  Fix: co-author with procurement and legal. SR governance fails when contracting and intake workflows aren’t aligned.
• Mistake: Dissemination is assumed, not evidenced.
  Fix: define recipients and keep distribution proof (attestation, LMS completion, or document access logs).
• Mistake: Procedures don’t match reality.
  Fix: run a tabletop using a real third-party onboarding. Update procedures to match actual steps and tools.
• Mistake: No ownership or review cadence.
  Fix: assign a named owner and put SR-1 into your policy governance calendar with tracked reviews.
• Mistake: Evidence is scattered.
  Fix: create a control evidence register. Make “where evidence lives” part of the procedure outputs.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for SR-1, so this page does not cite enforcement outcomes.

Risk-wise, SR-1 gaps tend to show up as:

• inconsistent third-party onboarding decisions
• missing contractual security requirements and flowdowns
• inability to prove governance during assessments
• delayed remediation because no one owns updates

Assessors typically treat missing SR-1 artifacts as a program-level weakness because it undermines confidence that supply chain controls are managed systematically ².

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

Use this as an execution sequence. Adjust scope to your environment.

First 30 days (Immediate)

• Assign SR-1 owner and approvers; document RACI.
• Inventory existing artifacts (procurement SOPs, vendor risk docs, security policy sections).
• Draft SR policy outline and identify {{ sr-1_prm_1 }} dissemination recipients by role.
• Stand up a single evidence location and naming convention for SR-1.

Days 31–60 (Near-term)

• Publish SR policy v1 and get formal approval.
• Write procedures for intake/tiering, due diligence, contracting/flowdowns, and monitoring.
• Align procedures to your actual tools (ticketing, GRC, contract repository).
• Launch dissemination: publish documents and collect attestations or training acknowledgments.

Days 61–90 (Operationalize and test)

• Run a pilot on live third-party onboarding and one renewal. Capture evidence.
• Fix gaps found in the pilot (decision criteria, incomplete outputs, missing contract clauses).
• Implement a recurring SR-1 review workflow (calendar + task owner + evidence of completion).
• Build an assessor-ready SR-1 packet: policy, procedures, dissemination proof, review log, and sample onboarding evidence.

Frequently Asked Questions

What counts as “disseminate” for the sr-1: policy and procedures requirement?

Dissemination means getting the policy and procedures to the roles that must follow them and keeping proof. Acceptable proof is usually a controlled publication record plus attestations, training completion, or access logs tied to defined recipients.

Can I satisfy SR-1 with a procurement policy and a security policy instead of an SR policy?

Sometimes you can, but it’s risky if the documents don’t clearly cover supply chain risk management end-to-end and don’t map cleanly to SR responsibilities. A dedicated SR policy with cross-functional procedures is easier to assess and maintain ².

Who should own SR-1: security, procurement, or GRC?

GRC or security commonly owns the control, but procurement and legal must be accountable for key procedure steps (contracting, onboarding gates). The best ownership model is a single control owner with a documented RACI across functions.

How do I prove the procedures are actually followed?

Keep operational evidence: third-party intake tickets, risk tiering decisions, completed due diligence packages, contract security addenda, and monitoring outputs. Tie each artifact back to the procedure step that required it.

What’s the minimum set of procedures I should write first?

Start with intake/tiering, due diligence, and contracting/flowdowns because those create the most immediate control points. Add monitoring and offboarding next so you can show lifecycle governance.

How does Daydream help with SR-1 without turning this into “tool compliance”?

Use Daydream as the registry for SR-1 ownership, document links, dissemination tasks, and evidence requests. Your policy and procedures remain the authority; Daydream keeps them current and makes assessment packaging predictable.

Footnotes

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

2. NIST SP 800-53 Rev. 5