SR-2: Supply Chain Risk Management Plan

To meet the sr-2: supply chain risk management plan requirement, you must create and maintain a written plan that defines how your organization identifies, assesses, treats, and monitors supply chain risks across the full system lifecycle for in-scope systems, components, and services ¹. Operationalize SR-2 by scoping covered assets, assigning ownership, embedding SCRM steps into procurement and engineering workflows, and retaining evidence that the plan is used.

Key takeaways:

• SR-2 is a plan requirement: auditors look for a lifecycle-based SCRM plan tied to specific in-scope systems/components/services ¹.
• “Supply chain” includes R&D through disposal; your plan must cover more than purchasing and onboarding ¹.
• Your fastest path to readiness is to map SR-2 to a control owner, procedures, and recurring evidence artifacts ¹.

SR-2 is one of those controls that fails in real programs for a simple reason: teams have activities (security reviews, third-party due diligence, SBOM requests, contract clauses), but they cannot show a single, coherent plan that ties those activities to lifecycle stages and specific systems. SR-2 fixes that gap. It requires a Supply Chain Risk Management (SCRM) Plan that governs how you manage supply chain risk for identified systems, system components, and system services from early design decisions through retirement and disposal ¹.

For a Compliance Officer, CCO, or GRC lead, the fastest way to operationalize SR-2 is to treat it like a “program wrapper” around existing procurement, engineering, security, and asset management workflows. You are documenting decisions, roles, triggers, and evidence. The plan should be specific enough that a new program manager could follow it and produce the same outcomes, and an assessor can trace requirements to artifacts without guessing.

This page gives requirement-level implementation guidance you can put into production quickly: scope, ownership, minimum plan contents, step-by-step rollout, evidence to retain, and audit friction points.

Regulatory text

NIST SP 800-53 Rev. 5 SR-2 states: “Develop a plan for managing supply chain risks associated with the research and development, design, manufacturing, acquisition, delivery, integration, operations and maintenance, and disposal of the following systems, system components or system services: {{ insert: param, sr-02_odp.01 }};” ¹.

What the operator must do:

1. Develop a written SCRM plan. “Develop” means it exists, is approved, and is actionable (not a slide deck without procedures).
2. Cover the full lifecycle listed in the requirement (R&D through disposal), not just procurement and onboarding ¹.
3. Apply it to defined scope: the specific systems/components/services your organization designates as in-scope in the plan placeholder (“the following…”) ¹.

Plain-English interpretation (what SR-2 is really asking)

SR-2 expects you to answer, in one controlled document:

• Which systems and services have supply chain exposure that matters to mission/business outcomes?
• What supply chain threats and failure modes do you care about (counterfeit components, malicious code, unsupported products, sub-tier dependency concentration, tampered shipments, opaque cloud supply chains)?
• Where in the lifecycle will you manage those risks (design reviews, supplier selection, delivery acceptance, patching and maintenance, end-of-life and disposal)?
• Who approves exceptions, and what evidence proves you followed the plan?

Assessors generally treat SR-2 as a “table stakes” control: if you cannot show the plan and evidence it drives actions, your downstream controls look ad hoc.

Who it applies to (entity and operational context)

SR-2 is used in environments aligned to NIST SP 800-53, including:

• Federal information systems subject to NIST-based security control baselines ².
• Contractor systems handling federal data, where 800-53 controls are flowed down contractually or used to meet federal program expectations ².

Operationally, SR-2 applies wherever you:

• Build or significantly configure systems (internal apps, infrastructure, CI/CD toolchains).
• Buy or subscribe to system components/services (SaaS, cloud, managed services, libraries).
• Depend on third parties for operations/maintenance (MSPs, data center providers, OEM support).
• Retire assets and handle sanitization/disposal.

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

Step 1: Define SR-2 scope in a way an auditor can test

Your plan must name the in-scope “systems, system components, or system services” ¹. Use a scope method that is defensible:

• Start with your system inventory (CMDB, SSP system list, or equivalent).
• Add critical components: identity provider, endpoint management, CI/CD, logging/SIEM, key management, core cloud accounts, and any regulated data processors.
• Include third-party-provided components that materially affect confidentiality, integrity, or availability (for example: managed database, CDN/WAF, payroll processor if it touches sensitive data).

Output: SR-2 scope register (system/service list) with owners.

Step 2: Assign ownership and governance

SR-2 fails when “everyone” owns it. Set clear roles:

• Plan owner (usually GRC, security assurance, or TPRM lead).
• Engineering/system owners for in-scope assets.
• Procurement / vendor management for third-party onboarding and contracting.
• Security architecture for design-stage controls and patterns.
• Legal for contractual requirements and breach notification language.

Define an approval path for:

• New supplier onboarding for in-scope systems.
• Exceptions (time-bound, risk-accepted, documented).
• End-of-life / forced migration risks.

Step 3: Write the SCRM plan with lifecycle “hooks”

Your plan should be short enough to be used, but complete enough to prove lifecycle coverage ¹. Use a format like:

A. Purpose and scope

• In-scope systems/components/services list (or link to the scope register).
• Definitions: third party, supplier, sub-tier supplier, component, service.

B. Supply chain risk identification (by lifecycle stage)

• R&D/design: approved architectures, prohibited components, secure-by-design requirements.
• Manufacturing/build: build pipeline integrity, artifact signing, controlled repositories.
• Acquisition: due diligence triggers, minimum security requirements, contract controls.
• Delivery/integration: acceptance testing, integrity verification, configuration hardening.
• Operations/maintenance: patch SLAs, supportability, vulnerability disclosure, monitoring.
• Disposal: sanitization, token/key revocation, contract termination checklist.

C. Risk assessment and treatment

• Risk criteria: what makes a supplier “higher risk” (data sensitivity, privileged access, criticality, concentration risk).
• Treatment options: mitigate, transfer (contract), avoid, accept with approvals.
• Required sign-offs.

D. Monitoring and change management

• Triggers: supplier ownership change,重大 outage, security incident, critical vuln, end-of-life notice.
• Review cadence for plan and supplier risk posture (set your own internal cadence; auditors care that it happens and is evidenced).

Step 4: Embed SR-2 into operational workflows (where evidence comes from)

Map plan requirements to workflow checkpoints:

• Intake: Third-party request form forces classification (data type, access level, criticality).
• Due diligence: security questionnaire or assessment path varies by risk tier.
• Contracting: minimum clauses (security controls, audit rights where feasible, incident notification, subprocessor transparency).
• Implementation: architecture review for integrations; secure configuration baselines.
• Ongoing: vendor performance reviews; security monitoring integration; vulnerability and patch tracking.
• Exit: offboarding checklist and data handling verification.

If you use Daydream for third-party risk management, this is where it naturally fits: SR-2 becomes a mapped requirement with a control owner, a documented procedure, and recurring evidence tasks so the plan does not drift from operations ¹.

Step 5: Prove operation with recurring evidence

SR-2 is frequently assessed as “paper vs. practice.” Build an evidence calendar aligned to your lifecycle hooks:

• New supplier onboarding packets (intake, tiering, approvals).
• Security review outputs for high-risk suppliers (findings, remediation, sign-offs).
• Change-trigger reviews (incident reviews, ownership change assessments).
• Disposal/offboarding records.

Required evidence and artifacts to retain

Keep artifacts that show both design (the plan exists) and operation (people followed it):

Core documents

• Approved Supply Chain Risk Management Plan (version-controlled).
• SR-2 scope register (in-scope systems/components/services) ¹.
• Roles and responsibilities (RACI) and exception process.

Operational records

• Third-party intake and risk tiering records for in-scope systems.
• Due diligence packages (questionnaires, SOC reports if collected, risk notes, approvals).
• Contract requirement checklists and executed security addenda where applicable.
• Integration/security architecture reviews for critical connections.
• Monitoring outputs (review notes, renewal risk reviews, incident-triggered reassessments).
• Offboarding/disposal checklists and confirmations.

Traceability

• A simple mapping table: SR-2 requirement element → procedure → evidence location → control owner ¹.

Common exam/audit questions and hangups

Auditors and assessors tend to drill into these areas:

• Scope clarity: “Show me the list of systems/services covered by SR-2 and why.”
• Lifecycle coverage: “Where do you address delivery acceptance and disposal, not just onboarding?” ¹
• Operational proof: “Pick one critical supplier. Walk me through onboarding, contracting, integration, monitoring, and offboarding readiness.”
• Exception handling: “How do you approve a high-risk supplier when the business insists?”
• Sub-tier visibility: “How do you track key subcontractors/subprocessors that affect your risk?”

Hangups you can preempt:

• Plan exists but no evidence it is used.
• Evidence exists but not connected to lifecycle stages or scoped systems.
• Multiple disconnected policies (procurement policy, SDLC policy, third-party policy) with no SR-2 wrapper tying them together.

Frequent implementation mistakes (and how to avoid them)

1. Writing a plan that reads like a policy and lacks procedures.
   Fix: add workflow triggers, required approvals, and where evidence lives.

2. Scoping SR-2 to “all vendors.”
   Fix: scope to systems/components/services, then map the relevant third parties to those assets ¹.

3. Ignoring “disposal.”
   Fix: add a concrete offboarding/disposal checklist: data return/destruction, access revocation, certificate/key rotation, asset sanitization.

4. No ownership for engineering-controlled parts of the supply chain.
   Fix: assign system owners responsibilities for design/integration and maintenance stages; procurement cannot carry those alone.

5. No change triggers.
   Fix: define events that force reassessment (incident, major vuln, M&A, end-of-life, material subcontractor change).

Enforcement context and risk implications

No public enforcement cases were provided in the available source catalog for this requirement. Treat SR-2 primarily as an assessment and assurance expectation under NIST SP 800-53: gaps typically surface as audit findings, authorization delays, customer assurance failures, or contractual noncompliance when federal requirements are flowed down ².

Practical 30/60/90-day execution plan

First 30 days (stand up the minimum viable SR-2 plan)

• Name SR-2 plan owner and approvers; document RACI.
• Produce the SR-2 scope register for in-scope systems/services ¹.
• Draft SCRM plan v1 with lifecycle hooks and an exception process.
• Build the SR-2 mapping table (requirement → procedure → evidence → owner) ¹.

Days 31–60 (embed into workflows and generate first evidence)

• Update third-party intake to capture risk tier inputs tied to in-scope systems.
• Add contract/security requirement checklist for in-scope procurements.
• Run a pilot on a small set of critical suppliers; collect onboarding-to-operations evidence.
• Establish a central repository for SR-2 artifacts (GRC tool or controlled document library).

Days 61–90 (operationalize monitoring and close audit gaps)

• Add change triggers and a monitoring cadence for high-risk suppliers.
• Test offboarding/disposal workflow on a low-risk supplier to validate checklists.
• Conduct an internal mini-assessment: pick one system and prove end-to-end lifecycle evidence.
• If using Daydream, convert the plan into scheduled evidence tasks and owner attestations so SR-2 stays “always ready” ¹.

Frequently Asked Questions

What counts as a “system component or system service” for SR-2?

Treat anything that materially affects your system’s confidentiality, integrity, or availability as a component/service, including cloud services, CI/CD platforms, identity services, and managed security tooling ¹.

Do I need a separate SR-2 plan per system?

Usually no. Write one enterprise SCRM plan, then attach a scope register that lists in-scope systems/services and any system-specific addenda for unusually sensitive environments ¹.

How do I prove SR-2 is operating, not just documented?

Keep traceable records from intake through monitoring: tiering decisions, approvals, due diligence outputs, contract checklists, and ongoing review notes mapped back to the plan’s lifecycle steps.

What’s the minimum content assessors expect in the SR-2 plan?

Clear scope, lifecycle coverage from design through disposal, defined roles/approvals, risk assessment approach, treatment options, monitoring triggers, and an exception process ¹.

We already have a third-party risk management policy. Is that enough?

Only if it explicitly covers the full lifecycle listed in SR-2 (including integration, operations/maintenance, and disposal) and it ties to the systems/components/services in scope with testable procedures ¹.

How should we handle open-source dependencies under SR-2?

Include open-source in the “component” category and manage it through your SDLC and build pipeline controls: approved sources, integrity checks, patching ownership, and monitoring triggers tied to critical vulnerabilities.

Footnotes

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

2. NIST SP 800-53 Rev. 5