CP-4: Contingency Plan Testing

CP-4 requires you to test your system contingency plan on a defined cadence and with defined test types, then use test results to prove the plan works and your team can execute it under stress. Operationalize it by setting a test schedule, running realistic exercises, documenting outcomes, and tracking corrective actions to closure. ¹

Key takeaways:

• CP-4 is an operational control: evidence comes from executed tests, not a written plan alone. ¹
• Your test program must measure both plan effectiveness and readiness to execute, with documented results and fixes. ¹
• Assign ownership, define test types and scope, and retain artifacts that an assessor can replay end-to-end. ¹

The cp-4: contingency plan testing requirement is where contingency planning stops being a policy exercise and becomes an operational capability. CP-4 expects you to run tests against your contingency plan for a defined system scope, using defined test methods, to confirm two things: the plan is effective, and the organization is ready to execute it. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path to “audit-ready” is to treat CP-4 like a recurring control with (1) a schedule, (2) named test scenarios, (3) clear success criteria tied to recovery objectives, (4) a standard results package, and (5) a corrective action workflow. The testing itself usually lives with IT, Security, SRE/Operations, and Business Continuity. Your job is to make it governable: define expectations, set minimum evidence, and make sure failures drive improvement rather than getting buried in meeting notes.

This page focuses on execution: who does what, how to run tests without boiling the ocean, and what artifacts to retain so an examiner can trace your contingency plan from documented procedures to observed performance. ²

Regulatory text

NIST SP 800-53 CP-4 excerpt: “Test the contingency plan for the system {{ insert: param, cp-04_odp.01 }} using the following tests to determine the effectiveness of the plan and the readiness to execute the plan: {{ insert: param, cp-4_prm_2 }}.” ¹

Operator interpretation of the excerpt (what you must do):

• “Test the contingency plan” means execute planned exercises against the documented contingency procedures, not just review them in a meeting. ¹
• “for the system” means scope is system-specific. Enterprise-wide tabletop exercises can help, but they do not automatically satisfy CP-4 for a particular system unless you can show the system’s plan and dependencies were actually tested. ¹
• “using the following tests … to determine effectiveness and readiness” means you must predefine test types/scenarios and evaluate outcomes. Evidence should show what was tested, who participated, what happened, and what changed afterward. ¹

Plain-English interpretation (what CP-4 is really asking)

Run repeatable contingency plan tests that simulate realistic disruption, then prove you can execute recovery procedures within your stated expectations. CP-4 is satisfied when you can demonstrate a closed loop: plan → test → results → corrective actions → updated plan and runbooks. ¹

Assessors usually look for two dimensions:

1. Plan effectiveness: Are the documented steps complete and accurate for the current architecture and third-party dependencies? ¹
2. Execution readiness: Do people, access, tooling, backups/replicas, and communications actually work during a test? ¹

Who it applies to (entity and operational context)

CP-4 commonly applies where NIST SP 800-53 is the governing baseline, including:

• Federal information systems and the programs that operate them. ¹
• Contractor systems handling federal data, including environments supporting federal contracts and regulated program boundaries. ¹

Operationally, you should treat CP-4 as in-scope for any system where outage, data loss, or disruption triggers mission impact, contractual commitments, or security obligations. The requirement is easiest to defend when “system” is defined consistently with your authorization boundary / system security plan approach under NIST SP 800-53. ²

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

1) Define scope: “the system” and its recovery dependencies

Create a CP-4 test scope sheet for each in-scope system:

• System boundary (apps, data stores, identity, network segments)
• Upstream/downstream dependencies (including third parties such as cloud hosting, managed services, DNS/CDN, communications platforms)
• Recovery assumptions (who declares an incident, who can approve failover, where credentials are stored) ¹

Practical tip: If you can’t list the third parties that must cooperate during recovery, your tests won’t reflect real execution readiness.

2) Establish a test strategy and calendar (what “following tests” means in your program)

Document the test types you will run for the system. Keep it simple and repeatable:

• Tabletop exercise: walk through roles, decision points, communications, and escalation.
• Technical recovery test: restore from backup, fail over a component, rebuild from code, rotate credentials, validate monitoring/alerts.
• Comms test: validate call trees, paging, and stakeholder notifications.
• Dependency test: confirm critical third-party contact paths and access methods work under disruption (for example, emergency support channels). ¹

Your written strategy should map test type → objective → evidence expected → who participates. The goal is to demonstrate both effectiveness and readiness, as stated in CP-4. ¹

3) Define pass/fail criteria tied to your contingency plan claims

Before you test, write down what success looks like:

• What services must be restored first
• What data integrity checks must pass
• What minimum functionality counts as “recovered”
• What documentation/runbooks must be followed and updated based on findings ¹

Avoid vague criteria like “successful test.” Make it measurable using your own stated objectives (even if you don’t publish numeric RTO/RPO values in evidence packages).

4) Run the test with controlled realism

Execute the exercise with:

• Named facilitator and scribe
• Attendance captured (including on-call, security, infra, app owners, and business reps where relevant)
• Time-stamped event log (what happened, when, who decided)
• Proof points (screenshots, logs, ticket numbers, restore job IDs, change records) ¹

What auditors like: a clear line from contingency plan step “X” to observed action “X executed,” plus an explanation of deviations.

5) Produce a standardized after-action report (AAR)

Your AAR should be consistent across systems:

• Scenario(s) tested and scope
• What worked / what failed
• Root cause summary for failures
• Corrective actions with owners and due dates
• Required updates to contingency plan, runbooks, contact lists, or architecture diagrams ¹

6) Track corrective actions to closure and refresh the plan

CP-4 testing is weak if findings never get fixed. Create a remediation workflow:

• Log findings as tickets with severity and owner
• Validate fixes (retest when needed)
• Update the contingency plan and supporting procedures
• Obtain approvals and publish updated documents ¹

Daydream fit (earned mention): Many teams fail CP-4 on evidence hygiene, not on engineering. Daydream can help you map CP-4 to an owner, a repeatable procedure, and a recurring evidence checklist so every test yields an assessor-ready packet. ¹

Required evidence and artifacts to retain

Keep artifacts in a system-level CP-4 evidence folder with consistent naming. Minimum set:

• Contingency plan for the system (current version and approval record). ¹
• Test plan (scope, scenario, participants, success criteria, date). ¹
• Execution artifacts (facilitator notes, event timeline, screenshots/log snippets, restore job outputs, change tickets). ¹
• After-action report with findings and corrective actions. ¹
• Remediation evidence (closed tickets, updated runbooks/diagrams, retest results if applicable). ¹
• Training/role evidence where execution depends on specific roles (on-call roster, escalation lists used during test). ¹

Common exam/audit questions and hangups

Expect these questions, and pre-answer them in your evidence package:

• “Show me the last contingency plan test for this system and the results.” ¹
• “Which test types do you run, and why do they demonstrate readiness to execute?” ¹
• “What changed after the test? Show me the corrective actions closed.” ¹
• “How did you include third-party dependencies (cloud, managed services, telecom) in the test assumptions?” ¹
• “Is this test specific to this system’s contingency plan, or was it an enterprise tabletop?” ¹

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails CP-4	Fix
Treating a policy review as a “test”	CP-4 requires tests that determine effectiveness and readiness. 1	Run at least one execution-oriented exercise and produce an AAR.
No documented success criteria	You can’t show “effectiveness” without pre-set expectations. 1	Add pass/fail criteria to the test plan.
Tests ignore access and identity realities	Recovery often fails due to missing privileges, expired break-glass accounts, or unclear approvals.	Include access validation steps and evidence.
Findings aren’t tracked to closure	Assessors read this as low control maturity and weak readiness. 1	Tie each finding to a ticket and show closure evidence.
Evidence is scattered across chat, wikis, and tickets	You can’t prove execution cleanly under audit pressure.	Standardize a CP-4 evidence packet per test.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not list enforcement examples. Practically, CP-4 gaps increase operational and contractual risk because you may not be able to demonstrate recoverability under disruption, which can also affect security outcomes if incident response depends on recovery actions. ²

A practical 30/60/90-day execution plan

First 30 days (stand up the control so it can run)

• Assign a CP-4 control owner per system (IT Ops/SRE typically executes; GRC governs). ¹
• Build a system inventory list that identifies which systems require CP-4 testing and where their contingency plans live. ²
• Publish a one-page CP-4 test template: scope, scenario, participants, success criteria, evidence checklist, AAR format. ¹

Days 31–60 (run the first test and produce audit-ready artifacts)

• Select the highest-impact system and run one tabletop plus one technical recovery activity aligned to the plan. ¹
• Generate the AAR the same week, while details are fresh. ¹
• Open remediation tickets for every finding and assign owners. ¹

Days 61–90 (close the loop and scale)

• Close high-priority corrective actions, update the contingency plan/runbooks, and capture approvals. ¹
• Repeat the test process for the next systems on your priority list using the same evidence packet structure. ¹
• Operationalize recurring evidence collection in Daydream (or your GRC system) so each test automatically produces the artifacts auditors request. ¹

Frequently Asked Questions

Do tabletop exercises count for CP-4?

They can, if they are structured tests tied to the system contingency plan and you document outcomes that demonstrate effectiveness and readiness. Pairing a tabletop with at least one executed technical recovery step usually creates stronger CP-4 evidence. ¹

How do I scope CP-4 when we have shared platforms across many applications?

Define the “system” boundary consistently with your NIST SP 800-53 system documentation, then test contingency procedures for the shared components and document which dependent services were included in the scenario. Keep a dependency list in the test plan. ²

What evidence is most persuasive to an auditor?

A complete packet: pre-brief/test plan, participant list, time-stamped execution notes, technical proof (logs/screenshots/tickets), and an after-action report with corrective actions closed. That shows testing occurred and drove improvement. ¹

How should we handle third-party dependencies in contingency plan tests?

Document the third party dependency and the operational assumption (support channel, failover responsibility, contact path), then test what you control (access, escalation, configuration, backups) and retain evidence that the dependency was addressed in the scenario. ¹

If a test fails, does that mean we’re noncompliant?

A failed test is not automatically a control failure if you document the failure, open corrective actions, update the contingency plan or procedures as needed, and track remediation to closure. The control breaks when you don’t test, don’t document, or don’t fix known gaps. ¹

Who should own CP-4: GRC or Engineering?

Engineering/Operations should own execution because they run recovery. GRC should own governance: defining test expectations, verifying evidence quality, and confirming corrective actions close on time. Split roles clearly in your control narrative. ²

Footnotes

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

2. NIST SP 800-53 Rev. 5