SR-5: Acquisition Strategies, Tools, and Methods

To meet the sr-5: acquisition strategies, tools, and methods requirement, you must bake supply chain risk controls into how you buy and contract for products and services, then prove it with repeatable procurement steps and retained evidence. Operationally, that means defining approved acquisition strategies and contract clauses, applying them consistently by risk tier, and tracking exceptions. 1

Key takeaways:

  • SR-5 is a procurement control: it turns supply chain risk management into contract and sourcing requirements, not post-signature cleanup. 2
  • You need a documented “toolkit” (strategies, clauses, evaluation methods) plus a workflow that forces buyers to use it. 1
  • Evidence wins exams: show the clause set, the sourcing decision record, and the exception trail for representative buys. 2

SR-5 sits in NIST SP 800-53’s Supply Chain Risk Management (SR) family and targets a common operational gap: teams assess third-party risk, but the purchase still goes through without enforceable contractual obligations or a consistent sourcing method. SR-5 closes that gap by requiring you to employ acquisition strategies, contract tools, and procurement methods to protect against, identify, and mitigate supply chain risks. 1

For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing SR-5 is to treat it as a procurement gating control with three outputs: (1) a defined set of acquisition approaches by risk level (for example, competitive sourcing vs. sole source with compensating controls), (2) standard contract clauses and templates that impose measurable security and supply chain obligations, and (3) a documented evaluation and approval workflow that captures decisions and exceptions. Your goal is consistency: the organization should be able to show that higher-risk buys get stronger controls, and that deviations are approved and tracked.

This page gives requirement-level guidance you can hand to Procurement, Legal, Security, and vendor owners and get implemented without a long theory phase.

Regulatory text

NIST SR-5 (excerpt): “Employ the following acquisition strategies, contract tools, and procurement methods to protect against, identify, and mitigate supply chain risks: {{ insert: param, sr-05_odp }}.” 1

Operator interpretation: NIST is directing you to define and apply a set of sourcing/contracting mechanisms that actively manage supply chain risk. Even though the OSCAL excerpt references an organization-defined parameter (the “sr-05_odp” insert), an assessor will still expect two things:

  1. you have named strategies/tools/methods selected by your organization; and
  2. you can show those mechanisms are used in real acquisitions (contracts, POs, renewals, and material changes), with evidence. 2

Plain-English interpretation (what SR-5 really demands)

SR-5 requires you to control supply chain risk at the point of purchase. That means Procurement and Legal cannot treat security as an “attachment” that may or may not be included. Instead, the organization defines a standard set of acquisition controls (templates, clauses, evaluation steps, sourcing constraints) and applies them based on the risk of the product/service and how it will be deployed.

Think of SR-5 as answering four exam questions with artifacts:

  • What supply chain risk protections do you require in contracts?
  • When do you require them?
  • Who approves exceptions?
  • Where is the proof that the process runs the same way each time? 2

Who it applies to (entity and operational context)

SR-5 is commonly applied in:

  • Federal information systems and the organizations that operate them. 2
  • Contractor systems handling federal data, where 800-53 controls are flowed down by contract, ATO expectations, or customer security requirements. 1

Operationally, SR-5 touches:

  • Procurement / Strategic Sourcing (RFPs, bid evaluation, supplier onboarding)
  • Legal / Contracts (MSAs, DPAs, security addenda, flow-downs)
  • Security / Privacy (third-party risk assessments, technical requirements)
  • Engineering / IT (product selection, architecture reviews)
  • Business owners (budget holders, third-party relationship owners)

If your organization buys SaaS, hardware, managed services, software components, or uses subcontractors, SR-5 applies to those acquisition motions.

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

1) Assign ownership and define scope

  • Name a control owner (often GRC + Procurement) and confirm which acquisition paths are in scope: new purchases, renewals, statement-of-work changes, and high-risk click-throughs where feasible.
  • Define what “acquisition” means internally (PO, MSA, order form, marketplace purchase).
    Deliverable: SR-5 control statement mapped to process owners and systems of record. 1

2) Define your organization’s SR-5 “toolkit” (the ODP content)

Because SR-5 references organization-defined parameters, you must specify what you will “employ.” Create a controlled document (or GRC control procedure) listing your required strategies/tools/methods, such as:

  • Acquisition strategies: approved sourcing paths by risk tier (e.g., competitive bid for high criticality; restricted supplier lists; preferred suppliers; sole-source justification with compensating controls).
  • Contract tools: required clause library (security requirements, incident notice, subcontractor flow-downs, right to audit, data handling, geographic restrictions, termination/transition assistance).
  • Procurement methods: mandatory steps (risk screening, technical evaluation, third-party due diligence, approval gates, exception workflow).
    Deliverable: SR-5 procedure with an embedded checklist that Procurement must complete. 2

3) Build risk-tiered triggers (so buyers don’t guess)

Create simple triggers that decide which SR-5 toolkit elements apply. Common trigger inputs:

  • Data type handled (federal data, sensitive customer data, regulated data)
  • Connectivity (network access, privileged access, code execution)
  • Criticality (mission/business critical service)
  • Subcontracting/manufacturing complexity (multi-tier supply chain)

Practical control design: Put these triggers into intake forms (Procurement intake, third-party onboarding questionnaire, purchase request). The output should be a required clause set and required review steps.

4) Standardize templates and clause sets

Work with Legal to publish:

  • Pre-approved MSA/SOW templates for common buy types (SaaS, services, hardware)
  • A security addendum with selectable modules (baseline vs. elevated)
  • Flow-down language for subcontractors where applicable

Operational rule: If the third party refuses a required clause, the request must route to an exception approver (Security + Legal + business owner) with compensating controls documented.

5) Embed SR-5 in the procurement workflow (gating)

A policy alone does not satisfy SR-5 in practice. Add workflow enforcement:

  • Procurement cannot issue a PO or execute an agreement until required reviews are completed.
  • TPRM/security review cannot be bypassed without an approved exception.
  • Renewal workflows re-check tiering and re-apply clause sets when scope changes.

Systems of record: ERP/procurement suite, contract lifecycle management (CLM), and your third-party risk workflow tool should show the gate decisions.

6) Create an exception process with teeth

Define:

  • What qualifies as an exception (time-critical purchase, sole source, clause deviations)
  • Who can approve
  • Required compensating controls (extra monitoring, reduced access, shorter contract term, escrow/backup arrangements, segmentation)
  • How exceptions expire and get revisited

This is where many teams fail audits: exceptions exist, but there’s no consistent approval record or follow-up.

7) Test with “representative acquisitions”

Before an assessment, pick a sample of purchases across risk tiers and verify you can produce:

  • the intake and risk tier outcome,
  • the applied clause set,
  • approvals,
  • and any exception decisions.

If you can’t reconstruct the acquisition story end-to-end, SR-5 will be hard to defend.

Where Daydream fits (practical, not theoretical)

If your biggest SR-5 risk is “missing implementation evidence,” Daydream’s pragmatic value is in mapping SR-5 to a control owner, a written implementation procedure, and a recurring evidence list that matches your procurement workflow so you can answer auditor requests fast. 1

Required evidence and artifacts to retain

Keep artifacts that prove both design (your toolkit exists) and operating effectiveness (it’s used).

Design evidence (static/controlled):

  • SR-5 control procedure and acquisition toolkit (strategies, clause library, procurement methods) 1
  • Standard contract templates and security addendum versions
  • Risk-tiering criteria and decision logic
  • RACI showing Procurement/Legal/Security responsibilities

Operational evidence 1:

  • Completed purchase intake with tiering outcome
  • Due diligence outputs tied to the acquisition (security review record, questionnaires, risk acceptance)
  • Executed contract/order form plus security addendum and any negotiated redlines
  • Exception requests, approvals, compensating controls, and expiry/review evidence
  • Renewal check records (if the scope/data/access changed)

Common exam/audit questions and hangups

Assessors tend to push on consistency and traceability:

  1. “Show me your SR-5 strategies/tools/methods.”
    Hangup: You reference SR-5 in a policy, but can’t point to the concrete checklist, clause set, or sourcing method library. 2

  2. “How do you decide which contracts get which clauses?”
    Hangup: Tiering exists but is subjective, or it lives in someone’s head.

  3. “Give me three examples of high-risk acquisitions and prove the gates were followed.”
    Hangup: Records are scattered across email, CLM, and ticketing, with no consistent audit trail.

  4. “How do you handle exceptions and sole source?”
    Hangup: Exceptions are common, approvals are informal, and compensating controls aren’t documented.

Frequent implementation mistakes and how to avoid them

  • Mistake: Treating SR-5 as a TPRM questionnaire exercise.
    Fix: Tie the risk outcome to contract requirements and procurement gates, not just a score.

  • Mistake: One clause set for everything.
    Fix: Maintain baseline and elevated modules so Procurement can move fast while still scaling controls for high-risk buys.

  • Mistake: No linkage between sourcing decision and supply chain risk.
    Fix: Require a short sourcing decision record for higher-risk purchases (why this third party, what alternatives were considered, what risks were accepted).

  • Mistake: Exceptions don’t expire.
    Fix: Put an expiry date and a re-approval trigger in the exception workflow, and tie it to renewal events.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for SR-5, so this page does not cite enforcement outcomes. Practically, SR-5 failures show up as audit findings because they are easy to test: contracts either contain required controls and approvals, or they do not. 2

Practical 30/60/90-day execution plan

First 30 days (stand up the minimum viable SR-5)

  • Assign SR-5 ownership (GRC + Procurement + Legal).
  • Draft the SR-5 acquisition toolkit (the organization-defined list of strategies/tools/methods). 1
  • Publish a baseline security addendum and a simple intake/tiering form.
  • Identify where evidence will live (CLM, ticketing, GRC) and define naming conventions.

Days 31–60 (embed into workflow)

  • Add procurement gates: no PO/contract without the completed intake and required approvals.
  • Train sourcing managers, contract managers, and third-party owners on “what changes by tier.”
  • Create the exception workflow and an exception register.
  • Pilot on a small set of new purchases and one renewal cycle; fix friction points.

Days 61–90 (prove operating effectiveness)

  • Run a sample-based internal check: select representative acquisitions and compile an “audit packet” for each.
  • Add recurring reporting: open exceptions, upcoming renewals with elevated tier, contracts missing addenda.
  • Update templates and playbooks based on negotiation patterns (what third parties push back on, and what compensating controls you accept).
  • If you use Daydream, finalize the SR-5 control mapping, evidence checklist, and recurring collection schedule so you can respond to assessor requests without scrambling. 1

Frequently Asked Questions

Do we have to use specific acquisition tools listed by NIST for SR-5?

The provided SR-5 text references an organization-defined parameter, so you must define which strategies, contract tools, and procurement methods your organization will employ and then apply them consistently. Your assessor will look for your defined toolkit and evidence it is used. 1

Does SR-5 apply to renewals or only new purchases?

Treat renewals and material changes as in scope because the control is about “acquisition” methods and contract tools. A clean approach is to re-run tiering and re-apply required clauses when scope, data, or access changes.

What’s the minimum evidence set to pass an audit for SR-5?

Keep (1) your SR-5 procedure/toolkit, (2) your standard templates/clause sets, and (3) a sample of executed acquisitions showing tiering, approvals, the executed contract language, and documented exceptions if any. 2

How do we handle click-through SaaS where we can’t negotiate terms?

Route those requests through an exception path with compensating controls (reduced access, no sensitive data, segmentation, alternate tooling) and document the approval. Track them in an exception register and revisit at renewal.

Who should approve SR-5 exceptions?

Use a small approval group that can accept legal, security, and business risk: Legal for contract deviations, Security/TPRM for control gaps, and the business owner for risk acceptance. Document the decision and the compensating controls.

How do we operationalize SR-5 if Procurement and Legal are understaffed?

Standardize as much as possible: tiering triggers, clause modules, and a single intake workflow that produces an audit trail. Automate evidence capture in your CLM/ticketing tool so staff time goes to negotiation and risk decisions, not hunting for records.

Footnotes

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

  2. NIST SP 800-53 Rev. 5

Frequently Asked Questions

Do we have to use specific acquisition tools listed by NIST for SR-5?

The provided SR-5 text references an organization-defined parameter, so you must define which strategies, contract tools, and procurement methods your organization will employ and then apply them consistently. Your assessor will look for your defined toolkit and evidence it is used. (Source: NIST SP 800-53 Rev. 5 OSCAL JSON)

Does SR-5 apply to renewals or only new purchases?

Treat renewals and material changes as in scope because the control is about “acquisition” methods and contract tools. A clean approach is to re-run tiering and re-apply required clauses when scope, data, or access changes.

What’s the minimum evidence set to pass an audit for SR-5?

Keep (1) your SR-5 procedure/toolkit, (2) your standard templates/clause sets, and (3) a sample of executed acquisitions showing tiering, approvals, the executed contract language, and documented exceptions if any. (Source: NIST SP 800-53 Rev. 5)

How do we handle click-through SaaS where we can’t negotiate terms?

Route those requests through an exception path with compensating controls (reduced access, no sensitive data, segmentation, alternate tooling) and document the approval. Track them in an exception register and revisit at renewal.

Who should approve SR-5 exceptions?

Use a small approval group that can accept legal, security, and business risk: Legal for contract deviations, Security/TPRM for control gaps, and the business owner for risk acceptance. Document the decision and the compensating controls.

How do we operationalize SR-5 if Procurement and Legal are understaffed?

Standardize as much as possible: tiering triggers, clause modules, and a single intake workflow that produces an audit trail. Automate evidence capture in your CLM/ticketing tool so staff time goes to negotiation and risk decisions, not hunting for records.

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Map requirement text to controls, owners, evidence, and review workflows inside Daydream.

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