CP-2(5): Continue Mission and Business Functions

“cp-2(5): continue mission and business functions requirement” sits inside Contingency Planning and is easy to misread as a generic disaster recovery expectation. It is narrower and more demanding: you must plan for continuity of identified mission and business functions with minimal or no loss of operational continuity, and you must be able to sustain that continuity until primary processing and/or storage sites are fully restored ¹. That “until fully restored” phrase is where many programs get stuck, because teams often stop at “we can fail over” and do not document how they will operate in a degraded state for an extended period.

This page gives requirement-level implementation guidance you can execute quickly as a Compliance Officer, CCO, or GRC lead. The goal is simple: walk into an assessment with a continuity plan that names what must continue, explains exactly how it continues, shows who does what, and proves you have rehearsed the hard parts. You will also see where third parties commonly break continuity assumptions (cloud dependencies, managed services, call centers, data providers) and how to convert those into testable, auditable commitments.

Regulatory text

Control requirement (excerpt): “Plan for the continuance of [organization-defined] mission and business functions with minimal or no loss of operational continuity and sustains that continuity until full system restoration at primary processing and/or storage sites.” ¹

What the operator must do:
You need a written, approved contingency planning approach that explicitly (1) identifies the mission and business functions that must continue, (2) defines how you keep them operating through a disruption with minimal/no interruption, and (3) explains how you keep them operating for the entire period before the primary site is fully restored ¹. Assessors will look for more than a DR diagram; they will look for function-by-function decisions, resource requirements, and evidence you can execute the plan.

Plain-English interpretation (what CP-2(5) really expects)

CP-2(5) is a continuity-of-functions requirement, not a backup requirement.

• “Mission and business functions”: the outcomes your organization must deliver (e.g., claims intake, benefits determination, 24/7 SOC monitoring, manufacturing release, payment processing), not a list of servers.
• “Minimal or no loss of operational continuity”: you set an expectation that the function continues with little interruption. If “no loss” is unrealistic, you must define what “minimal” means in your environment (for example: a short service pause, reduced throughput, restricted feature set) and document it as part of your continuity approach.
• “Sustains that continuity until full system restoration”: your plan must cover the whole disruption window, including a prolonged degraded mode. A one-time failover is not enough; you need staffing, security, data handling, and operational runbooks that work day after day until the primary site returns ¹.

Who it applies to

Entity scope

• Federal information systems.
• Contractor systems handling federal data ¹.

Operational context Apply CP-2(5) wherever a disruption could prevent your organization from delivering a defined mission/business function. Typical triggers:

• Primary data center outage, region-level cloud outage, storage corruption.
• Loss of a critical third party service (identity provider, payment processor, EDI gateway, managed SOC, call center).
• Facility loss (fire/flood), workforce unavailability, telecom loss.

System scope decision If you have multiple systems, CP-2(5) is easiest to operationalize by anchoring on functions and then mapping systems to those functions. Systems supporting non-critical functions can have lighter continuity strategies, but you must be explicit.

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

Step 1: Name the functions that must continue

Create a short list of “must-run” mission/business functions. Keep it operational, not abstract.

Minimum fields to capture

• Function name and owner (business).
• Peak periods and operational constraints (hours, volume, dependencies).
• “Continuity expectation” statement (what “minimal” means for this function).
• Upstream/downstream dependencies (systems, data stores, identity, networks, third parties).

Tip for fast execution: If you already have a BIA, start there. If you do not, run a workshop with business owners and capture the above fields in a simple table.

Step 2: Map each function to the continuity approach that works during disruption

For each function, document the practical method you will use to keep it running. Examples:

• Active-active or warm standby environment.
• Manual processing with later reconciliation.
• Reduced feature set (“read-only mode,” limited transaction types).
• Alternate facility or distributed workforce plan.
• Pre-positioned equipment, privileged access method, and break-glass credentials.

Your write-up should answer: “If the primary processing and/or storage site is down, what do we do in the first hour, first day, and on day N?”

Step 3: Prove you can sustain operations until restoration

This is the CP-2(5) differentiator. Add a “sustainment” section per function:

Sustainment checklist

• Staffing model for extended operations (coverage, on-call, backfill).
• Security controls during degraded mode (logging, monitoring, access approvals).
• Data integrity approach (how you prevent split-brain, duplicate records, or lost writes).
• Capacity assumptions (what breaks first under degraded capacity).
• Supply chain and third-party constraints (rate limits, contractual continuity, support hours).
• Decision rights: who declares continuity mode, who authorizes return-to-primary.

If a third party is essential to continuity, write the dependency as a requirement: “Function X requires third party Y to support continuity mode,” then tie it to contract terms, SLAs, and testing.

Step 4: Convert the plan into runbooks people can follow

Assessors will accept a contingency plan that references runbooks, but they will not accept “tribal knowledge.”

Create runbooks for:

• Failover/fallback steps (including approvals).
• Data restoration steps and validation checks.
• Communications plan (internal/external, status page, customer comms).
• Manual workarounds (forms, queues, reconciliation process).
• Return-to-primary steps (and how you avoid data loss during cutback).

Step 5: Exercise the continuity strategy and track fixes

Run an exercise that demonstrates you can execute the continuity approach and sustain it. Capture:

• Scenario, participants, timestamps, decisions made.
• Gaps found (access issues, missing scripts, third-party bottlenecks).
• Remediation tickets and closure evidence.

NIST expects planning that is assessable. The cleanest way is to tie exercise outcomes directly back to CP-2(5) requirement language ¹.

Step 6: Assign ownership and evidence cadence

Operationalize CP-2(5) with clear RACI:

• Control owner (GRC) responsible for plan governance and evidence.
• Technical owners (Infra/AppSec/SRE) responsible for runbooks and test execution.
• Business owners responsible for function prioritization and acceptance of degraded-mode behavior.

If you use Daydream to manage third-party and control evidence, treat CP-2(5) like a living requirement: map it to owners, procedures, and recurring artifacts so evidence is continuously ready instead of assembled during the audit scramble ¹.

Required evidence and artifacts to retain

Keep these artifacts in an assessor-ready folder ¹:

1. Contingency/continuity plan section addressing CP-2(5) with named mission/business functions and sustainment language ¹.
2. Function-to-dependency mapping table (systems, data stores, third parties, key staff roles).
3. Continuity architecture diagrams (primary, alternate, data flows, trust boundaries).
4. Runbooks (failover, operate-in-continuity-mode, return-to-primary).
5. Exercise records: tabletop or technical test plan, attendance, results, after-action report.
6. Remediation tracking: tickets, change records, approvals, closure validation.
7. Third-party continuity evidence (where relevant): contractual clauses, support commitments, joint test notes, incident comms procedures.

Common exam/audit questions and hangups

Auditors and assessors commonly ask:

• “Which mission/business functions does this system support, and which must continue?”
• “Show me where the plan states how you sustain operations until the primary site is restored.” ¹
• “Who can declare continuity mode, and what are the criteria?”
• “What changes in security monitoring and access approvals during continuity operations?”
• “When was the last exercise, what broke, and what did you change?”
• “Which third parties are required for continuity mode, and have you validated their role?”

Hangups that slow assessments:

• You list “critical systems” but cannot tie them to business functions.
• You can fail over, but you cannot explain day-to-day sustained operations (staffing, reconciliations, capacity, security logging).
• The plan exists, but runbooks are outdated or owned by a team that reorganized.

Frequent implementation mistakes (and how to avoid them)

1. Mistaking backups for continuity. Backups support recovery; CP-2(5) is about continued function delivery. Write continuity-mode operations explicitly.
2. Ignoring “return-to-primary.” Teams document failover but not safe restoration. Add step-by-step cutback with data validation gates.
3. No defined degraded mode. If you cannot guarantee full service, define which transactions are allowed, what queues, and what manual steps exist. Get business sign-off.
4. Third parties treated as “out of scope.” If a third party is a dependency, it is in scope for continuity planning. Capture assumptions, support channels, and test coordination.
5. Evidence gaps. A good plan without exercise records reads as aspirational. Schedule exercises and keep after-action artifacts ready.

Enforcement context and risk implications

No public enforcement cases were provided for this requirement in the source catalog. Practically, CP-2(5) failures show up as service delivery failures during incidents: inability to process core transactions, loss of service integrity, and prolonged outage due to untested cutback steps. For federal systems and contractors handling federal data, those outcomes drive negative assessment results and can affect authorization decisions because CP-2(5) is explicit about sustaining continuity through restoration ¹.

Practical 30/60/90-day execution plan

Days 0–30: Establish scope, functions, and ownership

• Confirm in-scope systems and data types (federal system or contractor handling federal data).
• Identify mission/business functions that must continue; assign business owners.
• Build the function-to-dependency map, including third parties.
• Draft CP-2(5) plan language that states sustainment “until full restoration” ¹.
• Assign RACI and create a single evidence folder structure.

Days 31–60: Build runbooks and continuity-mode operations

• Write runbooks for failover, continuity operations, and return-to-primary.
• Define degraded-mode rules per function and get business approval.
• Document security changes during continuity mode (monitoring, access, logging).
• Validate third-party participation requirements and update contracts/SOWs where needed.

Days 61–90: Exercise, remediate, and make it repeatable

• Run a tabletop plus a technical exercise (as appropriate to the system).
• Produce an after-action report with remediation tickets and owners.
• Update the plan/runbooks based on lessons learned; capture the change history.
• Set a recurring review/exercise cadence and automate evidence collection where possible (for example, tracking artifacts in Daydream tied to control owners and recurring evidence tasks).

Frequently Asked Questions

Does CP-2(5) require “zero downtime”?

The text allows “minimal or no loss of operational continuity,” so you must define what “minimal” means for your mission/business functions and document how you meet it ¹.

How is CP-2(5) different from disaster recovery?

Disaster recovery focuses on restoring IT services; CP-2(5) focuses on keeping mission/business functions operating through the disruption and sustaining operations until the primary site is fully restored ¹.

We are SaaS on a major cloud provider. Is that enough?

No. You still need a plan that names the functions, explains your continuity mode, and addresses cloud dependency failure modes and sustainment through restoration, including third-party support constraints ¹.

What evidence is most persuasive to an assessor?

A plan that lists the functions and sustainment approach, plus dated exercise results and an after-action remediation trail that shows you closed gaps.

How do we handle third parties that refuse to participate in tests?

Document the dependency, record the request and the third party’s response, and design compensating steps (alternative workflows, alternate providers, manual procedures). Tie the gap to contract renewal requirements.

Where should this live: BCP, IR, or DR documentation?

Put CP-2(5) content where operators will follow it during an outage, then cross-reference related documents. Assessors care that the CP-2(5) requirement is explicitly satisfied and testable ¹.

Footnotes

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