SR-2(1): Establish SCRM Team

To meet the sr-2(1): establish scrm team requirement, you must formally stand up a cross-functional Supply Chain Risk Management (SCRM) team with defined membership, authority, and operating cadence, and assign it responsibility to lead and support your organization’s SCRM activities. Operationalize it by issuing a charter, naming accountable owners, embedding the team into procurement/architecture/security workflows, and retaining meeting and decision evidence.

Key takeaways:

• A named SCRM team with a charter and decision rights is the control; a “virtual” group with no authority usually fails audits.
• Tie SCRM team actions to real workflows (intake, sourcing, onboarding, change management, incident response) and retain evidence.
• Examiners look for traceability: who decided, when, based on what inputs, and what was done with the outcome.

SR-2(1) is a governance-and-operations requirement disguised as a documentation task. NIST expects you to establish a dedicated team that can actually run supply chain risk management across technology and service dependencies, including third parties, integrators, and product supply chains. If your current “vendor risk” program lives only in procurement questionnaires or security reviews, SR-2(1) forces a broader operating model: one group coordinates SCRM decisions across security engineering, acquisition, legal, privacy, resiliency, and mission/business owners.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat SR-2(1) like a control that needs: (1) explicit accountability, (2) defined scope, (3) an operating cadence, and (4) auditable outputs. That means a team charter, a roster with roles, a decision log, and repeatable touchpoints with sourcing and system lifecycle processes.

This page translates SR-2(1) into a practical runbook: who should be on the SCRM team, what they should do, how to embed them into daily work, what evidence to keep, and what auditors typically challenge.

Requirement: SR-2(1) Establish SCRM Team (operator view)

Plain-English interpretation: You must create a standing, cross-functional SCRM team (not a one-time working group) that owns and coordinates supply chain risk management decisions and activities. The team needs enough authority to set requirements, approve risk decisions, and drive remediation across internal stakeholders and third parties.

What “good” looks like in practice

• A documented charter that states purpose, scope, decision rights, and escalation paths.
• Named individuals (not just departments) with clear roles (chair, program owner, procurement rep, security architecture, legal/privacy, business owner).
• Recurring meetings with agendas tied to SCRM activities (intake reviews, exceptions, critical supplier monitoring, remediation tracking).
• Outputs that feed real processes: third-party onboarding gates, architecture review boards, change management, and incident response.

Who it applies to

Entities: Federal information systems and contractor systems handling federal data ¹.

Operational contexts where SR-2(1) is triggered

• Buying or renewing third-party products and services (SaaS, hosting, MSPs, data processors, consultants).
• Building systems that incorporate external components (open source dependencies, OEM hardware, firmware, managed services).
• Material supplier changes (new subprocessors, new hosting regions, acquisitions of key suppliers).
• Supply chain incidents (compromised upstream software, counterfeit hardware indicators, supplier breach affecting your environment).

Regulatory text

NIST’s enhancement states: “Establish a supply chain risk management team consisting of {{ insert: param, sr-02.01_odp.01 }} to lead and support the following SCRM activities: {{ insert: param, sr-02.01_odp.02 }}.” ¹

Operator translation of the text you have: The “{{ insert: param… }}” placeholders are OSCAL parameter references. Even without the expanded parameter values, the expectation is clear: define (1) the team composition and (2) the SCRM activities the team leads and supports, then implement and evidence that operating model. ²

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

Step 1: Write a one-page SCRM Team Charter

Minimum contents (keep it short, but specific):

• Purpose: Lead and support supply chain risk management across third parties and product/component supply chains.
• Scope: Which systems, business units, data types, and supplier categories are in scope.
• Decision rights: What the team can approve (security requirements, onboarding conditions, risk acceptances, exception expirations).
• Escalation: When issues go to the CISO, CIO, CRO/ERM, or an executive risk committee.
• Interfaces: Procurement, architecture review, SDLC, change management, incident response, business continuity.

Artifact: “SCRM Team Charter” (approved, versioned, dated).

Step 2: Name the SCRM Team and lock the roster

Create a roster that lists individual names and roles. Typical roles:

• SCRM program owner (often Security/GRC)
• Procurement/sourcing lead
• Security architecture/engineering
• IT operations / platform owner
• Legal (contracts) and privacy (as applicable)
• Product/system owner(s) for critical systems
• Business continuity / resiliency rep
• Optional: fraud, finance, physical security, export/compliance depending on your supply chain

Artifact: Roster with role descriptions and designated alternates.

Step 3: Define the SCRM activities the team “leads” vs “supports”

Make a simple RACI-style mapping so auditors can see boundaries.

Lead (accountable) examples

• Set third-party security requirements and minimum contracting clauses for in-scope suppliers.
• Maintain supplier criticality tiers and define what enhanced due diligence is required for each tier.
• Review high-risk onboarding and renewal decisions and approve compensating controls.
• Govern exception handling (who can accept risk, for how long, and what must be tracked).
• Track and drive remediation for supplier issues that affect your environment.

Support (consulted) examples

• Provide requirements and risk input to architecture reviews and system authorization activities.
• Support incident response for third-party originated events (supplier compromise, vulnerability disclosures).
• Support continuous monitoring for critical suppliers (operational and security signals).

Artifact: SCRM Activities Matrix (Lead/Support + RACI).

Step 4: Integrate the team into real workflows (so it operates by default)

Pick specific control points where the SCRM team is required:

• Third-party intake: SCRM review is required before procurement can finalize a purchase for defined risk tiers.
• Renewals: Renewals for critical suppliers require an SCRM re-review (not just a contract signature).
• Architecture/SDLC gates: Any system design that introduces a new external dependency triggers SCRM input.
• Change management: Supplier material changes require review (subprocessor changes, data location shifts).
• Exception process: All exceptions route to the SCRM team for recommendation and tracking.

Artifacts: Workflow screenshots, ticketing templates, procurement SOP excerpts, and approval records.

Step 5: Establish operating cadence and control health checks

Define how the SCRM team runs:

• Meeting cadence tied to sourcing volume and risk.
• Standing agenda items: new intakes, renewals, exceptions, critical supplier issues, remediation status.
• Action tracking: owners, due dates, closure criteria, evidence links.

Then implement periodic “control health checks” so you can show sustained operation over time (recommended in your guidance pack).

Artifacts: Meeting minutes, agenda templates, action logs, and health-check reports.

Step 6: Build your minimum evidence bundle (auditor-ready)

Auditors rarely accept “we have a team” without operational outputs. Create a checklist and store it in a known location.

Minimum evidence bundle to retain

• Approved SCRM Team Charter (current + prior versions)
• Current roster + role descriptions + alternates
• SCRM activities/RACI mapping
• Operating cadence definition (calendar invite series or SOP)
• Meeting agendas and minutes
• Decision log (onboarding approvals, exception decisions, escalations)
• Remediation tracker with validated closure notes
• Proof of workflow integration (procurement gates, intake tickets, renewal approvals)
• Training/enablement evidence for stakeholders who must engage the team (procurement, system owners)

Tip: If you use Daydream, create a requirement control card and attach the minimum evidence bundle to the control record so evidence stays consistent across audits.

Common exam/audit questions and hangups

Auditors and customer assessors tend to push on these:

1. “Who is on the SCRM team by name, and who is accountable?”
   Hangup: org charts show departments, not named owners. Fix with a roster and role assignments.

2. “What decisions does the team make, and where are they recorded?”
   Hangup: meetings happen but no decision log exists. Fix with a decision register tied to tickets.

3. “Show me how SCRM is triggered in procurement and system lifecycle.”
   Hangup: SCRM is optional or bypassed for renewals. Fix with defined gates and sampling evidence.

4. “How do you handle exceptions and risk acceptance?”
   Hangup: exceptions live in email. Fix with a standard exception form, approvals, and expiry tracking.

5. “How do you prove ongoing operation?”
   Hangup: a charter exists but no recent minutes or action tracking. Fix with cadence evidence and health checks.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Creating a “team” that is only a distribution list	No authority, no decisions, no outputs	Issue a charter with decision rights and an escalation path
Treating SCRM as procurement-only	Misses technical supply chain (components, dependencies)	Add engineering/architecture participation and SDLC triggers
No defined scope	Team reviews everything or nothing	Define in-scope supplier tiers and system categories
Minutes without actions	Auditors can’t see outcomes	Maintain an action log with closure evidence
Exceptions granted indefinitely	Risk acceptance becomes a loophole	Require expirations, compensating controls, and re-approval

Enforcement context and risk implications

No public enforcement cases were provided in your source pack, so this page does not cite specific actions or penalties.

Risk-wise, SR-2(1) is commonly tested indirectly: when a third-party incident happens or a critical supplier fails, reviewers assess whether you had a functioning governance body that could (a) identify critical dependencies, (b) make timely decisions, and (c) drive remediation. A missing or “paper-only” SCRM team often shows up as inconsistent supplier requirements, undocumented exceptions, and slow response to supplier-originated events.

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

You asked for speed, but the playbook rules prohibit unsourced implementation duration claims. Use this as Phase 1 / Phase 2 / Phase 3 sequencing, and compress or extend based on your environment.

Phase 1: Stand up governance (immediate)

• Draft and approve the SCRM Team Charter.
• Name the chair/program owner and publish the roster.
• Define team scope and the lead/support activity map.
• Create the evidence bundle checklist and storage location.

Phase 2: Wire into workflows (near-term)

• Add SCRM gates to third-party intake and renewal workflows.
• Implement a standard exception process with expirations and required approvals.
• Start the decision log and action tracker.
• Run initial control health check to confirm the process is operating.

Phase 3: Operational maturity (ongoing)

• Expand coverage to technical supply chain (SBOM/dependency risk inputs if available internally).
• Add continuous monitoring expectations for critical suppliers.
• Sample-test transactions (new suppliers, renewals, changes) and document results.
• Review metrics that show volume, exceptions, remediation aging, and recurring failure modes.

Frequently Asked Questions

Do we need a separate SCRM team if we already have a third-party risk management (TPRM) committee?

Not necessarily, but you must show that the existing body has explicit SCRM scope, membership, and decision rights. Update the charter/roster and map SCRM activities to the committee’s operating rhythm so it produces auditable SCRM outputs.

What is the minimum team composition auditors will accept?

NIST’s text uses parameter placeholders, so your implementation should be justified by your scope and risks ¹. In practice, auditors expect procurement/sourcing, security (GRC and architecture), and business/system ownership to be represented, with legal/privacy included when contracting and data processing are in scope.

Can the SCRM team be “virtual” across business units?

Yes, if it has a charter, named members, a cadence, and recorded decisions. A virtual team fails when there is no consistent meeting record, no decision log, and no evidence that procurement or engineering must route work through it.

What evidence is most persuasive in an audit?

A short charter, a named roster, meeting minutes, and a decision log tied to real third-party onboarding/renewal tickets. Auditors want traceability from intake to decision to remediation closure.

How do we show the team “leads and supports” SCRM activities without over-scoping it?

Use an activities matrix that distinguishes “lead” versus “support,” and add a RACI. Keep the team accountable for governance and high-risk decisions, while operational teams execute day-to-day tasks with clear triggers and escalation.

Where does Daydream fit if we already track vendors in spreadsheets or a GRC tool?

Daydream fits where teams typically break down: control cards, evidence bundling, and proving consistent operation across cycles. Use it to standardize the SR-2(1) control record, attach the minimum evidence bundle, and run recurring health checks with tracked remediation to closure.

Footnotes

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

2. NIST SP 800-53 Rev. 5 OSCAL JSON; NIST SP 800-53 Rev. 5