CP-2(8): Identify Critical Assets

CP-2(8): identify critical assets requirement is a contingency planning enhancement, but operators should treat it as a foundational inventory decision that drives downstream priorities: what gets restored first, what needs redundancy, what requires tighter backup objectives, and what must be tested more rigorously. The requirement language is short; the operational impact is large. If you mislabel assets as “critical” (too many or too few), your contingency plan becomes either unexecutable (everything is priority one) or unsafe (the real bottlenecks are missed).

A strong implementation produces one clear output: a defensible list of critical system assets that directly support the mission/business functions your system exists to deliver, along with enough metadata to act during disruption. That list must be governed (owned, approved, reviewed) and connected to how your environment changes (new services, third-party dependencies, architecture shifts).

This page gives requirement-level implementation guidance you can execute quickly: who should own it, how to set criteria, how to run the mapping, what evidence to retain, and what auditors typically ask for. It also includes a practical execution plan and common pitfalls that cause findings.

Regulatory text

Requirement (verbatim): “Identify critical system assets supporting {{ insert: param, cp-02.08_odp }} mission and business functions.” ¹

What the operator must do:
You must (1) determine which assets in-scope for the system are “critical,” (2) show how each critical asset supports the system’s mission/business functions, and (3) keep that determination current so contingency planning decisions (recovery sequencing, backup coverage, alternate processing, testing scope) can rely on it. ¹

Plain-English interpretation

Identify the small set of assets that, if lost or degraded, would stop the system from delivering its most important functions within required timeframes. Then document those assets, their owners, and their dependencies so your contingency plan can prioritize recovery and your teams can execute under pressure.

“Assets” here is broader than servers. In practice it includes:

• Core applications and services (including managed services)
• Data stores and critical datasets
• Identity and access components (IdP, PAM, key management)
• Network and security infrastructure that the system cannot operate without
• Third-party-provided components that are essential to operation (SaaS, cloud managed services, payment processors, DNS/CDN) when they are part of system delivery

Who it applies to

Entity scope: Federal information systems and contractor systems that handle federal data and align their control baseline to NIST SP 800-53 Rev. 5. ²

Operational context (where this shows up):

• You maintain a System Security Plan (SSP) and contingency planning documentation
• You have production services with defined mission/business functions (even if internal)
• You depend on shared services (cloud, identity, networking) and third parties that can become single points of failure

Typical owners:
This is usually owned by the System Owner or BCP/DR program owner with execution support from Enterprise Architecture, SRE/Infrastructure, Security Engineering, and Application Owners. Compliance (CCO/GRC) should set the standard, define evidence, and run the control health check, not manually classify every asset.

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

Step 1: Create a control “run card” (so it runs the same way every time)

Document, in one page, the operating details:

• Objective: identify critical assets supporting mission/business functions
• Owner: accountable role and backup
• Inputs: architecture diagrams, CMDB/inventory, service catalog, data flow diagrams, third-party register, prior BIA/criticality analysis
• Triggers: production go-live, major architecture change, new third party, material incident/postmortem, annual review
• Outputs: critical asset register + approval record + mapping to functions
• Exceptions: criteria for excluding dev/test assets or shared services outside scope, with rationale

This aligns to the practical expectation that teams can show ownership, cadence, and evidence for operation. ¹

Step 2: Define and approve “critical asset” criteria

Write criteria that your environment can apply consistently. Keep it measurable and tied to mission/business functions. Common criteria buckets:

• Functional impact: asset supports a top-tier mission/business function
• Dependency concentration: asset is a single point of failure or high fan-in dependency
• Recoverability constraints: hard to rebuild, long lead time, specialized configuration/keys
• Data criticality: contains/controls data required to operate or to meet obligations
• Security/control plane: compromise or loss prevents safe operation (identity, keys, logging pipeline)

Produce an approval record (system owner + security + continuity lead). Auditors look for governance, not just a spreadsheet.

Step 3: Build an initial asset universe (don’t start by arguing what’s “critical”)

Aggregate from:

• CMDB/service inventory (or cloud resource inventory)
• Kubernetes clusters/namespaces, cloud accounts/subscriptions/projects
• CI/CD and artifact repositories if required to restore production
• Identity providers, secrets management, KMS/HSM, certificate authorities
• Data platforms (object storage, databases, queues, caches)
• Third-party services embedded in delivery (SaaS, managed databases, DNS/CDN)

If inventory quality is weak, document the gap and the source-of-truth you are using now, plus the plan to improve.

Step 4: Map assets to mission/business functions (the core CP-2(8) output)

Create a simple mapping table. Example columns:

• Mission/business function (from your system purpose statement)
• Supporting service/component
• Underlying assets (platforms, data stores, identity, network dependencies)
• Criticality rationale (why it qualifies under your criteria)
• Primary owner and backup owner
• Key third-party dependencies (if any)
• Upstream/downstream dependencies (what must be restored first)

This mapping is what makes the list defensible under audit. It directly answers “supporting mission and business functions.” ¹

Step 5: Produce the “Critical Asset Register” (your auditable artifact)

Minimum fields that make it operational during an incident:

• Asset name + unique identifier
• Asset type (app/service, database, identity, network/security control plane, third-party service)
• Environment/scope (prod only, specific region/account)
• Owner and on-call group
• Dependency list (including third party)
• Recovery priority tier (e.g., Tier 0/1/2) with brief rationale
• Links to runbooks, backups, IaC repos, diagrams
• Last reviewed date + approver

Keep it short enough that incident responders will read it.

Step 6: Tie updates to change management (so it stays current)

Define “update required” events:

• New production service or major feature launch
• New cloud account/project/subscription
• Migration to a new identity/KMS/logging stack
• Adoption of a new third party that becomes a critical dependency
• Post-incident lessons learned that reveal hidden critical dependencies

Operationally: add a checkbox/task in change tickets and architecture review templates: “Does this change affect the critical asset register and mapping?”

Step 7: Run a recurring control health check and remediate gaps

Perform periodic checks that verify:

• The register exists, is approved, and is accessible during an outage
• Owners are current
• Dependencies reflect current architecture
• Recovery tiers still match mission/business function priorities

Track findings to closure with due dates and evidence of fix. This directly addresses the common risk factor where teams cannot show ownership, cadence, or evidence. ¹

Required evidence and artifacts to retain

Keep an evidence bundle that an auditor can re-perform from:

• Critical asset criteria document + approval record
• Critical asset register (exported snapshot + repository location)
• Asset-to-function mapping (table or diagram)
• Dependency documentation (architecture diagrams, data flow diagrams, third-party dependency list)
• Change management tie-in (template, ticket samples showing updates)
• Control health check records (review notes, issues, remediation closure evidence)

Store evidence in a named, access-controlled location with version history.

Common exam/audit questions and hangups

Expect these:

• “Define ‘critical.’ Who approved the definition?”
• “Show me how each critical asset supports a stated mission/business function.”
• “Prove completeness: how do you know you didn’t miss a key dependency like identity, DNS, or key management?”
• “What triggers updates? Show tickets or architecture reviews.”
• “How do you prevent everything from being labeled critical?”
• “How does this list drive contingency plan priorities (restore order, alternate processing, backup scope)?”

Hangup to anticipate: auditors often treat “critical assets” as including control-plane services (identity, keys, logging). If you exclude them, document why and where they are handled.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
“Critical assets” equals “all production assets”	Recovery priorities become meaningless	Use tiering and a strict definition; cap Tier 0 to true bottlenecks
No mapping to mission/business functions	Doesn’t satisfy CP-2(8)’s stated basis	Maintain a mapping table that ties each asset to a function 1
Ignoring third-party dependencies	Real outage risk lives in dependencies	Include critical third parties as assets or explicitly list them as dependencies
Register exists but isn’t maintained	Becomes stale; audit fails on operating effectiveness	Add change triggers and run periodic health checks 1
Ownership missing or unclear	No one updates it; incident response suffers	Assign named roles, on-call group, and escalation path

Enforcement context and risk implications

No public enforcement cases were provided in the supplied source catalog for this requirement, so you should treat this primarily as an auditability and resilience risk control rather than a control with a specific enforcement trail in this dataset.

Risk implications you can explain to executives without hype:

• Misidentified critical assets lead to failed or delayed recovery because teams restore the wrong components first.
• Hidden single points of failure (often identity, DNS, key management, or a third party) cause cascading outages.
• Poor evidence and unclear ownership frequently create audit findings even when engineering teams “know” what’s critical.

A practical 30/60/90-day execution plan

First 30 days (baseline and governance)

• Assign an accountable owner and publish a one-page control run card (objective, triggers, outputs, evidence location).
• Draft “critical asset” criteria and get formal approval.
• Build the initial asset universe from current inventories and architecture docs.
• Deliver a first-pass critical asset register for the top mission/business functions.

Days 31–60 (mapping and dependency hardening)

• Complete the asset-to-function mapping for all in-scope mission/business functions.
• Add dependency metadata: identity, keys, logging, DNS/CDN, and third-party services.
• Establish recovery tiers and confirm alignment with contingency plan assumptions.
• Add a change-management trigger step to update the register.

Days 61–90 (operationalize and prove it runs)

• Run a control health check and log gaps (missing owners, missing dependencies, stale entries).
• Remediate the highest-risk gaps and capture closure evidence.
• Tabletop a disruption scenario using the register to validate recovery sequencing.
• Lock the evidence bundle structure so audits are repeatable.

Where Daydream fits naturally: If you manage many systems or many third parties, Daydream can standardize the control run card, evidence bundle requirements, and recurring health checks so CP-2(8) doesn’t degrade into a one-time spreadsheet exercise. ¹

Frequently Asked Questions

Does “critical assets” mean only hardware and servers?

No. Treat “asset” as any component required to deliver mission/business functions, including data stores, identity/key management, and critical third-party services when they are part of the delivery chain. Your mapping should make that defensible. ¹

How do we avoid labeling everything as critical?

Start with strict criteria and require a short rationale for each critical designation. Use tiering so only true bottlenecks and control-plane dependencies land in the top tier.

What if we don’t have a mature CMDB?

Use the best available source of truth (cloud inventory exports, service catalog, architecture diagrams) and document the limitation. Auditors usually accept an interim inventory if the process is repeatable and governed.

Are third-party services “assets” under CP-2(8)?

The text requires identifying critical system assets that support mission/business functions, and in practice critical third-party dependencies often meet that bar. If you keep them as “dependencies” rather than “assets,” make the dependency explicit in the register and recovery sequencing.

Who should approve the critical asset list?

At minimum, the System Owner should approve, with review from security and continuity/DR stakeholders. The approval record is part of what makes the list auditable.

How often should we review the critical asset register?

Tie updates to change events, then add a recurring health check cadence your organization can sustain. The key is being able to show it is maintained and owned over time. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5