SR-6(1): Testing and Analysis

To meet the sr-6(1): testing and analysis requirement, you must define and perform testing and analysis on the supply chain elements, processes, and actors tied to your system or service, then keep repeatable evidence that the testing occurred and drove risk decisions. Operationalize it by scoping what gets tested, selecting methods, running tests on a schedule, and tracking results to remediation and acceptance. ¹

Key takeaways:

• SR-6(1) is about proving you tested and analyzed supply chain risk areas, not just documenting that suppliers exist. ¹
• Start with a clear scope: which third parties, components, and supply chain processes are “in scope” for testing and analysis. ¹
• The fastest exam-ready path is an owned procedure, a recurring test plan, and a tidy evidence set that links findings to remediation or risk acceptance. ²

SR-6(1) sits in the NIST SP 800-53 Supply Chain Risk Management (SR) family and expects you to go beyond questionnaires and contract clauses. You need an operational testing and analysis program that targets supply chain elements (for example, software components, services, integrators), processes (for example, build/release, change control, procurement), and actors (for example, third-party providers and their critical subcontractors) associated with your system or service. The control text is parameterized, which means your organization selects the specific testing/analysis methods and the specific supply chain targets, then implements them consistently. ¹

For a Compliance Officer, CCO, or GRC lead, the practical goal is assessment readiness: a documented method, a repeatable cadence, and evidence that testing results change decisions (remediation, supplier escalation, compensating controls, or risk acceptance). This page focuses on how to scope SR-6(1) correctly, assign ownership, design a lightweight but defensible test plan, and retain artifacts that auditors can trace from requirement to execution. Use this as a requirement-level playbook you can hand to control owners, security engineering, and third-party risk management (TPRM) teams without rewriting it into theory. ²

Regulatory text

Requirement (verbatim excerpt): “Employ {{ insert: param, sr-06.01_odp.01 }} of the following supply chain elements, processes, and actors associated with the system, system component, or system service: {{ insert: param, sr-06.01_odp.02 }}.” ¹

What the operator must do

Because SR-6(1) is parameterized, you must:

1. Define the testing and analysis approaches you will “employ” (the first parameter), and
2. List the specific supply chain elements, processes, and actors you will test/analyze (the second parameter), then
3. Execute and retain evidence that the testing and analysis happened and was acted on. ¹

Practical reading: your organization chooses the methods (for example, technical testing, analytic review, inspections, validation activities) and the supply chain scope (which third parties, which components, which processes), then proves the program runs.

Plain-English interpretation (what SR-6(1) is asking)

SR-6(1) expects a real-world check on supply chain risk for your system or service. That means you don’t stop at paper due diligence. You test and analyze the parts of your supply chain that could introduce compromise, integrity issues, counterfeit components, malicious updates, or hidden dependencies.

A simple way to frame it for operations: “We identified where supply chain risk can enter this system, we test those entry points using defined methods, and we keep evidence that findings were resolved or accepted.” ²

Who it applies to (entity and operational context)

SR-6(1) is commonly scoped to:

• Federal information systems implementing NIST SP 800-53 controls. ²
• Contractor systems handling federal data, where NIST SP 800-53 is flowed down contractually or adopted as the control baseline. ²

Operational contexts where auditors expect more than questionnaires:

• Cloud or managed services where the “system service” includes third-party run operations
• Software development and CI/CD pipelines with third-party libraries, build services, code signing, artifact repositories
• Hardware acquisition where authenticity and provenance matter
• Critical subcontractor chains (your third party relies on fourth parties for key functions)

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

Step 1: Name a control owner and define boundaries

• Control owner: usually TPRM lead (program) with Security Engineering (testing execution) and System Owner (scope decisions).
• Boundary statement: define which “system, component, or service” SR-6(1) covers (production only vs. prod + build environment; core platform vs. supporting tools). ²

Deliverable: a one-page SR-6(1) control implementation statement that says what’s in scope and who does what.

Step 2: Build your SR-6(1) scope register (elements, processes, actors)

Create a register with three columns and populate it from procurement, architecture, and SDLC documentation:

• Elements: external services, software components, appliances, build tools, signing keys/HSMs, artifact repositories.
• Processes: procurement onboarding, change management, patching, build/release, incident response with third parties, offboarding.
• Actors: third parties with privileged access, data processors, software publishers, integrators, and critical subcontractors you can identify. ¹

Keep scope tight by starting with “system-critical” items: components that can push code/config to production, handle sensitive data, or administer identity.

Step 3: Define the “testing and analysis” methods you will employ

Pick methods that match your environment and can be repeated. Examples that map cleanly to SR-6(1)’s intent:

• Technical testing of supplied software/components (for example, validating integrity of delivered artifacts, verifying signatures, scanning for known issues in third-party components you ship).
• Configuration and access validation for third-party integrations (for example, verifying least privilege, token scope, logging, and admin paths).
• Process analysis of supplier change practices that affect you (for example, reviewing how emergency patches are issued and how you get notified).
• Targeted assessments for high-risk third parties (deep dives triggered by events, architecture changes, or incidents).

Your goal is not to list every possible method. Your goal is to define methods you will actually run and evidence you can retain. ¹

Step 4: Set triggers and cadence (without overpromising)

Avoid brittle commitments you cannot meet. Define testing triggers that auditors recognize:

• New third party onboarding into in-scope system
• Major version upgrade or architecture change
• Privileged access granted or expanded
• Supplier security incident that could affect your environment
• Periodic review for critical suppliers/components

Write the cadence qualitatively in policy/procedure (“recurring,” “periodic,” “upon material change”) and put specifics in your internal test plan where you can adjust without rewriting policy.

Step 5: Execute tests, record results, and drive disposition

For each scoped item, record:

• What was tested/analyzed
• What method was used
• Date performed and by whom
• Findings (including “none”)
• Disposition: remediation ticket, compensating control, supplier escalation, or risk acceptance with approver

This is where many programs fail: they do the review but don’t produce traceable, decision-grade records.

Step 6: Tie SR-6(1) to your broader control stack

SR-6(1) should not live alone. Map it to:

• Your third-party lifecycle (onboarding, monitoring, offboarding)
• Secure SDLC controls (dependency management, build integrity)
• Incident management (supplier incidents and downstream actions)

A practical way to keep this tight is to map SR-6(1) to a single owned procedure and recurring evidence artifacts in your GRC system. Daydream can help by turning SR-6(1) into an assigned control with an evidence checklist and recurring collection workflow so execution does not depend on memory. ²

Required evidence and artifacts to retain

Auditors tend to accept SR-6(1) when evidence is consistent, dated, and traceable. Retain:

• SR-6(1) implementation statement (scope, methods, ownership) ²
• Supply chain scope register (elements/processes/actors) with version history
• Testing and analysis plan (methods, triggers, roles, recordkeeping)
• Completed test records (reports, outputs, screenshots where appropriate, analysis notes)
• Findings log with disposition and closure evidence (tickets, change records, supplier communications)
• Risk acceptances with approver, rationale, and expiry/reevaluation trigger
• Exception handling records (what didn’t get tested, why, and compensating measures)

Common exam/audit questions and hangups

Expect questions like:

• “Show me the list of supply chain elements/processes/actors you selected for SR-6(1) and why those are the right ones.” ¹
• “Which testing and analysis methods do you employ, and where is that defined?” ¹
• “Provide evidence for a sample of items that were tested, findings generated, and remediation tracked to closure.”
• “How do you trigger re-testing when a third party changes their service or has an incident?”
• “How do you know your testing coverage matches the system boundary?”

Hangup to anticipate: teams present a SOC 2 report or SIG questionnaire as “analysis.” That can be supporting input, but SR-6(1) expects you to define and employ testing/analysis of supply chain aspects associated with your system, not only collect attestations. ¹

Frequent implementation mistakes (and how to avoid them)

Mistake 1: No defined parameters (methods and scope)

SR-6(1) is parameterized; if you don’t specify your methods and scope, you can’t prove compliance. Fix: publish an internal SR-6(1) procedure that lists selected methods and the scoped elements/processes/actors. ¹

Mistake 2: “Testing” stays theoretical

A policy that says “we test suppliers” with no executed records fails quickly in audits. Fix: require dated test records and a findings log as mandatory artifacts for closure.

Mistake 3: Scope is either too broad or too vague

If you include every third party in the company, execution collapses. If you say “critical vendors” without definition, auditors push back. Fix: define objective scoping criteria tied to system impact (production change capability, sensitive data, privileged access).

Mistake 4: Findings don’t go anywhere

A spreadsheet of findings with no remediation owner creates repeat audit issues. Fix: enforce one of four dispositions for every finding: remediate, compensate, accept risk, or remove from scope (with rationale).

Enforcement context and risk implications

No public enforcement cases were provided in the supplied sources for SR-6(1). Your main risk is assessment failure or a control deficiency finding due to missing evidence that testing and analysis occurred and drove action. ²

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

Use a staged rollout that prioritizes assessment readiness and operational sustainability.

First 30 days (establish control design)

• Assign control owner(s) and RACI for SR-6(1).
• Draft SR-6(1) implementation statement: system boundary, chosen methods, recordkeeping.
• Build the initial scope register for the in-scope system/service.
• Define what counts as “done” for a test record and a finding disposition.

Next 60 days (operate on highest-risk scope)

• Run SR-6(1) testing/analysis on the highest-risk items in the register (those with production change paths, privileged access, or sensitive data handling).
• Stand up a findings workflow: ticketing integration, remediation SLAs (internal), and risk acceptance approvals.
• Conduct one tabletop walk-through with Security + TPRM + System Owner: pick one third party and trace evidence from scope → test → finding → closure.

By 90 days (make it repeatable and audit-ready)

• Expand to the remaining scoped items, or refine scope based on what you learned.
• Formalize triggers for re-testing (change events, incidents, renewals).
• Centralize evidence collection in your GRC system and schedule recurring requests. Daydream fits well here by keeping SR-6(1) ownership, evidence requests, and audit-ready exports in one place. ²

Frequently Asked Questions

Does SR-6(1) require penetration testing of third parties?

SR-6(1) requires that you employ defined testing and analysis methods on supply chain elements/processes/actors associated with your system. You choose the methods; they can include technical testing where appropriate, but the control does not prescribe a single technique. ¹

Can SOC 2 reports or ISO certificates satisfy SR-6(1)?

They can be inputs to your analysis, but SR-6(1) still expects you to define and employ your own testing/analysis approach tied to your system’s supply chain scope. Keep attestations as supporting evidence, not the only evidence. ¹

What’s the minimum evidence an auditor will accept?

A defined scope (elements/processes/actors), documented methods, and executed records that show tests occurred and results were dispositioned. If you cannot trace from scope to execution to remediation/acceptance, expect findings. ²

How do we scope “actors” without full visibility into fourth parties?

Start with the actors you directly engage and the ones with direct system impact (privileged access, production changes, sensitive data). Document assumptions and add fourth-party visibility requirements to contracts and renewal due diligence where feasible. ¹

Who should own SR-6(1): Security, Procurement, or TPRM?

Put program ownership in TPRM or GRC, and assign execution responsibilities to the teams that can actually test (Security Engineering, IAM, DevOps, System Owners). Auditors care that ownership is clear and evidence is consistent. ²

How do we keep SR-6(1) from becoming a paperwork exercise?

Make “testing and analysis” produce concrete outputs: a recorded result and a disposition tied to a ticket, compensating control, or signed risk acceptance. Automating evidence collection and reminders in a GRC workflow helps keep this operational over time. ²

Footnotes

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

2. NIST SP 800-53 Rev. 5