CA-8(2): Red Team Exercises

CA-8(2): Red Team Exercises is a requirement-level expectation for organizations using NIST SP 800-53 Rev. 5 to validate that security controls hold up against realistic adversary behavior, not only checklist testing. A vulnerability scan or a basic penetration test usually won’t satisfy what assessors expect from a “red team exercise” because the intent is to simulate compromise attempts end-to-end, under controlled conditions, using pre-approved rules of engagement.

For a Compliance Officer, CCO, or GRC lead, the fastest way to make CA-8(2) audit-ready is to translate it into an operating cadence: a documented red team exercise plan, an approved rules-of-engagement package, evidence of execution (including what was attempted), and a remediation workflow that closes the loop. You also need to settle ownership boundaries between security, IT operations, incident response, legal, privacy, and any affected third parties (including cloud and managed service providers), because red team activity creates real operational risk if mis-scoped.

If you want this to run smoothly every cycle, map CA-8(2) to a control owner, a repeatable procedure, and a standard evidence set that you can produce on demand. ¹

Requirement: CA-8(2): red team exercises requirement (plain-English)

CA-8(2) expects you to employ red team exercises that simulate attempts by adversaries to compromise organizational systems, and to do so in accordance with applicable rules of engagement. ¹

In practice, that means:

• You run planned “thinking attacker” exercises that try to reach meaningful objectives (e.g., unauthorized access to sensitive data, privilege escalation, persistence, lateral movement).
• You pre-approve how the red team will operate so activity is legal, safe, and controlled (rules of engagement).
• You treat results as a driver for remediation, not a one-time validation event.

Operator translation: “We can show what attack paths were attempted, what worked, what controls failed or detected it, and what we changed afterward.”

Regulatory text

Excerpt: “Employ the following red-team exercises to simulate attempts by adversaries to compromise organizational systems in accordance with applicable rules of engagement: {{ insert: param, ca-08.02_odp }}.” ¹

What you must do with this text (operationally):

1. Define “the following red-team exercises” for your program using your organization’s CA-8(2) parameterization (the org-defined parameter referenced by the control). Your assessor will expect to see what exercise types you selected and why they are appropriate for your environment. ¹
2. Run those exercises against in-scope systems.
3. Use written rules of engagement that cover authorization, safety controls, escalation paths, and stop conditions. ¹

Who it applies to (entity + operational context)

This requirement commonly applies where NIST SP 800-53 is the governing control set, including:

• Federal information systems and programs using NIST SP 800-53 Rev. 5. ²
• Contractor systems handling federal data where a contract, SSP, or ATO boundary references NIST SP 800-53 controls. ²

Operationally, CA-8(2) becomes relevant when:

• You have crown-jewel systems (identity, key management, privileged access, customer data platforms).
• You rely on third parties that can form attack paths (managed endpoints, CI/CD tooling, SOC providers, cloud admins).
• You need evidence that “security works” under adversarial pressure, not only via self-attestation.

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

1) Assign ownership and governance (make it auditable)

• Name a control owner (often Head of Security Assurance, Security Engineering, or GRC with Security as operator).
• Define RACI across Security, IT Ops, IR, Legal, Privacy, and business owners.
• Map CA-8(2) to a written procedure and recurring evidence artifacts so execution is repeatable and assessable. ¹

Practical tip: Put the exercise program under the same governance as incident response and change management so “findings to fixes” has a clear path.

2) Define scope and the CA-8(2) parameter (what exercises you will run)

CA-8(2) includes an org-defined parameter placeholder. Your job is to set it in your control implementation statement and then execute against it. ¹

Minimum scoping decisions you must document:

• In-scope systems, environments, and identity stores
• In-scope user types (employees, admins, contractors)
• In-scope third parties and shared services (or explicit exclusions with rationale)
• Test objectives (examples: demonstrate MFA bypass resistance, validate segmentation, measure detection/response)

3) Write rules of engagement (RoE) that operations will approve

Your RoE package should be short, specific, and signed/approved.

Include:

• Written authorization (who approved, date, systems)
• Allowed techniques and explicit prohibitions (e.g., no data exfiltration beyond synthetic tokens)
• Hours of operation and change-freeze alignment
• Safety controls (rate limits, avoid destructive payloads, no production DoS unless explicitly approved)
• Communications plan (who gets notified, when; “white cell” contacts)
• Stop conditions (service impact, unexpected data exposure, legal hold triggers)

This is the artifact most teams regret skipping. Without RoE, the activity looks like unauthorized hacking, even if it was “for security.”

4) Execute the red team exercise (treat it like a real operation)

Execution should produce evidence that:

• The team attempted realistic attack paths.
• Defensive controls were tested implicitly (prevent/detect/respond).
• The exercise stayed within RoE.

Execution components to capture:

• Plan of attack (high level)
• Test logs (operator notes, timestamps, targets)
• Evidence of compromise attempts (screenshots, command output, SIEM events)
• Detection and response observations (who saw what, when, and what they did)

5) Report findings in a way that drives remediation

A red team report that only lists vulnerabilities is usually not enough. Your reporting should translate attack narrative into fixable control gaps.

Required reporting sections (practical):

• Executive summary tied to business impact
• Attack chain narrative (initial access → privilege → objective)
• Root causes mapped to control failures (e.g., weak privileged access workflow, inadequate logging)
• Recommended remediations with owners and due dates
• Retest criteria (what “fixed” means)

6) Track remediation to closure and retest

For audit readiness, the strongest evidence is a closed-loop workflow:

• Ticketed findings with severity, owner, and target date
• Change records showing the fix
• Retest evidence (or compensating control decision with risk acceptance)

If you use Daydream, this is where it fits naturally: store the CA-8(2) control narrative, attach the RoE and final report, and link each finding to remediation evidence so you can answer assessor questions quickly without rebuilding a binder.

Required evidence and artifacts to retain (audit-ready checklist)

Keep a standard evidence package per exercise cycle:

1. Control implementation statement for CA-8(2), including your org-defined exercise parameter. ¹
2. Red team exercise plan (scope, objectives, schedule, roles).
3. Rules of engagement with approvals/sign-offs. ¹
4. Execution evidence (logs, screenshots, activity notes, tooling output, relevant SIEM/EDR alerts).
5. Final report with findings and recommendations.
6. Remediation tracker (tickets, risk acceptances, change records).
7. Retest evidence (proof that key findings were revalidated).
8. Lessons learned notes, especially if incident response processes were exercised.

Retention tip: Store artifacts in a controlled repository with access restrictions; red team outputs often contain sensitive details about weaknesses.

Common exam/audit questions and hangups

Assessors commonly probe these points:

• “What red team exercises did you define for CA-8(2), and why?” Expectation: you can point to the parameterization and a risk-based rationale. ¹
• “Show me the rules of engagement.” Expectation: written constraints and approvals. ¹
• “Prove the exercise happened.” Expectation: timestamps, scope, evidence, and reporting.
• “What changed as a result?” Expectation: tickets closed, controls improved, retest performed.
• “Was production impacted?” Expectation: RoE stop conditions, comms, and approvals.

Hangup to anticipate: If your “red team” is actually a vulnerability scan plus a pentest letter, call it what it is and plan a true scenario-driven exercise to close the gap.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails in audits	Avoid it by
No documented RoE	Activity can’t be shown as authorized and controlled	Require RoE approval before any testing. 1
Findings not tracked to closure	Looks like theater; risk remains	Create tickets for every material issue; require closure evidence.
Scope excludes identity/admin paths without rationale	Misses the most likely compromise routes	Include identity, privileged access, and logging pipelines or document exclusions.
Third parties ignored	Real attackers use supply-chain paths	Include third-party access points in scope or document constraints and compensating tests.
Reports are too technical for operators	Fixes stall	Add root cause and “how to remediate” steps per finding.

Enforcement context and risk implications

No public enforcement cases were provided in the supplied source catalog for this requirement, so you should treat CA-8(2) primarily as an assurance and risk-reduction requirement within NIST-based assessments, ATO processes, and customer security reviews. ¹

Risk implications if you under-implement:

• Undetected attack paths persist across identity, cloud control planes, and third-party integrations.
• You fail “operating effectiveness” expectations because you can’t show realistic adversary simulation under controlled rules of engagement. ¹

Practical execution plan (30/60/90)

You asked for speed; here is an operator plan that works even if you start from zero.

First 30 days (stand up the control so it’s defensible)

• Assign control owner and approve a CA-8(2) procedure and evidence list. ¹
• Define the org-specific CA-8(2) exercise parameter (what exercises you will run) and record it in the control narrative. ¹
• Draft rules of engagement template; get Legal/IR/IT Ops pre-review.
• Identify in-scope systems and third parties; document exclusions with rationale.

By 60 days (execute one scoped exercise end-to-end)

• Obtain written approvals and finalize RoE for the first exercise. ¹
• Run a limited-scope red team exercise with clear objectives (identity to workload, user to admin, or workstation to sensitive system).
• Produce the final report and open remediation tickets with owners.

By 90 days (close the loop and make it repeatable)

• Complete remediation for high-impact findings (or document risk acceptance with compensating controls).
• Retest the top findings and attach evidence.
• Publish a recurring cadence (e.g., per major release, per new environment, or on a regular schedule defined by your risk posture) and pre-stage the next RoE and scope.

Operational win: Once you have one full cycle with clean evidence, the next cycle is mainly repeat, refine, and expand scope.

Frequently Asked Questions

Does CA-8(2) require an external red team, or can we do it internally?

The control text does not mandate internal vs. external; it mandates that you employ red team exercises under applicable rules of engagement. ¹ If you run it internally, document independence safeguards and approvals.

Is a penetration test enough to satisfy ca-8(2): red team exercises requirement?

A typical pentest can contribute evidence, but CA-8(2) expects adversary simulation with defined red team exercises and rules of engagement. ¹ If you only have a pentest letter, add scenario-based objectives and RoE-backed execution evidence.

What should “rules of engagement” include for audit purposes?

Include scope, authorization, allowed/prohibited actions, communications, safety constraints, and stop conditions. The requirement explicitly ties red team exercises to applicable rules of engagement. ¹

How do we handle third-party systems (cloud, MSPs, SaaS) in red team scope?

Treat third-party connectivity as an attack path into your environment, then decide whether to test it directly (with written permission) or through compensating simulations. Document the decision and keep approvals in the RoE package.

What evidence is most persuasive to an assessor?

A signed RoE, proof of execution (logs/notes), a final report, and remediation tickets closed with retest evidence usually answer the “did you do it and did it matter?” questions. ¹

How should we document the “following red-team exercises” placeholder in the control text?

Treat it as an org-defined parameter: define the exercise types you will run, the scope boundaries, and the cadence triggers in your control implementation statement, then execute accordingly. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5