CP-4(3): Automated Testing

The cp-4(3): automated testing requirement sits inside NIST’s Contingency Planning family and focuses on one practical point: your contingency plan cannot be “paper compliant.” You need automated mechanisms that exercise recovery capabilities and generate consistent, reviewable output. ¹

For a CCO, GRC lead, or compliance officer, the fastest path to operationalizing CP-4(3) is to treat it as a control about engineered testability. That means you design your contingency plan so it can be executed and verified with automation, not just discussed in tabletop exercises. Automation also makes testing easier to repeat across systems, environments, and changes, which matters when auditors ask how you know recovery actually works for today’s configuration.

This page translates CP-4(3) into an implementation checklist you can assign to IT operations, SRE, infrastructure, and application owners. It also tells you exactly what evidence to retain so an assessor can retrace what was tested, when it was tested, what failed, and how you fixed it.

Regulatory text

Text (excerpt): “Test the contingency plan using {{ insert: param, cp-04.03_odp }}.” ¹

Operator interpretation: NIST is requiring you to conduct contingency plan testing with automated mechanisms (the parameter placeholder refers to organization-defined automated mechanisms). In practice, you must:

1. specify what automated testing tools/approaches you will use,
2. execute tests that meaningfully exercise recovery procedures, and
3. produce and retain objective, system-generated outputs that demonstrate results. ¹

Plain-English interpretation (what CP-4(3) really demands)

CP-4(3) expects your recovery testing to be repeatable and verifiable because automation runs the same way each time and leaves an audit trail. A good mental model:

• Manual: A person reads a runbook and claims the steps would work.
• Automated (CP-4(3) direction): A scheduled job, pipeline, or orchestrator executes recovery steps (or key parts of them) and produces logs, metrics, and pass/fail outcomes you can review.

Automation does not have to cover every contingency step. It must cover enough of the plan to materially test your ability to recover, and it must be defined, executed, and evidenced.

Who it applies to (entity and operational context)

CP-4(3) commonly applies where NIST SP 800-53 is the governing framework, including:

• Federal information systems and the teams operating them ¹
• Contractor systems handling federal data (including cloud and SaaS providers supporting federal workloads) ¹

Operationally, this control lands on:

• Infrastructure/SRE teams running backup, restore, failover, IaC, and DR orchestration
• Application owners for app-level recovery validation
• Security/GRC teams responsible for control design, evidence, and assessment readiness

If you rely on third parties (cloud platforms, managed backup providers, managed databases), CP-4(3) still applies to your system boundary. You may satisfy pieces through third-party tooling and reports, but you remain accountable for proving tests occurred and issues were corrected.

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

Step 1: Name the control owner and define automated mechanisms

Write down, in one place, the automated mechanisms you will use to test the contingency plan. Examples you can tailor:

• Backup verification jobs (automated restore tests)
• DR/failover orchestration workflows
• CI/CD pipelines that deploy to a recovery environment and run health checks
• Scheduled runbooks (automation platform) that execute recovery steps and validate outcomes

Deliverable: CP-4(3) implementation procedure that includes tooling, scope, and where evidence is stored.

Step 2: Define test scope that maps to the contingency plan

Create a coverage map from the contingency plan to testable components. Keep it pragmatic:

• Data protection: backup completion + restore integrity checks
• Compute/platform recovery: instance/service recreation from IaC
• Application recovery: service startup + synthetic transactions
• Identity and access for recovery: break-glass readiness checks (where appropriate)
• Communications: automated paging/notification checks (where feasible)

Deliverable: Contingency Test Matrix (plan section → automated test → expected result → evidence location).

Step 3: Implement “automated pass/fail” criteria

Assessors struggle with vague outcomes like “restore performed.” Define success criteria that are machine-verifiable:

• Restore job completes without errors
• Hash or consistency check passes for restored data (where applicable)
• Service health endpoint returns expected status
• Synthetic user journey succeeds
• RTO/RPO targets are validated if you have them defined internally (avoid claiming numeric targets unless you can support them)

Deliverable: Automated test acceptance criteria documented in the procedure or test matrix.

Step 4: Schedule and execute automated tests

Run tests on an organizational cadence appropriate to system criticality and change rate. The key is consistency and traceability:

• Scheduled jobs with immutable logs
• Change-controlled test definitions (versioned scripts/pipelines)
• Separation of duties where required (operator runs, control owner reviews)

Deliverable: Test run history (job scheduler history, pipeline runs, DR tool reports).

Step 5: Log, review, and create corrective actions

A CP-4(3) program fails audits when teams run tests but do not manage failures. Your workflow should be:

• Capture failures in tickets
• Assign owners and due dates
• Track remediation through closure
• Re-test after remediation

Deliverable: After-action review (AAR) summary tied to tickets and retest evidence.

Step 6: Make it assessor-ready (control narrative + evidence mapping)

Write a control narrative that answers:

• What is tested automatically?
• How often does it run?
• What tools run it?
• Where are logs and reports stored?
• Who reviews results?
• How are issues tracked to closure?

If you use Daydream, map CP-4(3) to a single control owner, attach the procedure, and set recurring evidence requests for test reports, run logs, and remediation tickets so evidence stays current and complete.

Required evidence and artifacts to retain

Keep artifacts that prove design, operation, and results:

Design evidence

• Contingency plan section(s) that describe testing approach ²
• CP-4(3) procedure: automated mechanisms, scope, roles ¹
• Test Matrix (plan mapping)

Operational evidence (system-generated where possible)

• Job/pipeline definitions (version-controlled scripts, IaC, workflow definitions)
• Execution logs and timestamps (scheduler history, pipeline run records)
• Automated test reports (pass/fail outputs, health check results)
• Screenshots only as a last resort; prefer exports/log files

Governance evidence

• Review signoff (change record, ticket comment, meeting notes with approver)
• Corrective action tickets (opened, triaged, closed)
• Retest proof after fixes

Common exam/audit questions and hangups

Auditors and 3PAOs usually push on these points:

1. “What is automated vs manual?”
   Be explicit. List which steps run automatically and which remain manual, and justify why.

2. “Show me the last test and its raw outputs.”
   Have direct links to logs/reports, not a slide deck summary.

3. “How do you know the test reflects production?”
   Explain environment parity, configuration management, and how you keep test definitions current.

4. “What happens when tests fail?”
   Show the ticket trail and the retest.

5. “Who reviews results?”
   Name reviewers and demonstrate periodic review.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Treating tabletop exercises as CP-4(3)	CP-4(3) is about automated mechanisms, not discussion-only testing 1	Keep tabletop under broader CP-4, but add automated execution and machine outputs for CP-4(3).
Only testing backups, ignoring app recovery	Backups alone do not prove service restoration	Add automated service bring-up + synthetic checks.
Logs exist but are hard to retrieve	Evidence retrieval becomes the audit failure	Centralize evidence locations and document them in the control narrative.
Tests run, failures are ignored	Unremediated findings show ineffective control operation	Enforce ticketing, SLAs (internally defined), and retest requirements.
No mapping to contingency plan	You cannot prove you tested “the plan”	Maintain the Test Matrix and update it with plan revisions.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for CP-4(3). From an operational risk perspective, weak automated contingency testing increases the likelihood that recovery steps fail during real incidents, and it increases audit risk because you cannot produce objective evidence of test execution and outcomes. ¹

A practical 30/60/90-day execution plan

First 30 days (establish control and evidence)

• Assign a CP-4(3) control owner and backups.
• Inventory current contingency testing activities and identify which ones are automated.
• Draft the CP-4(3) procedure: tools, scope, evidence locations, review workflow.
• Stand up an evidence folder structure (or GRC evidence collection workflow) and define naming conventions.

Days 31–60 (implement automation and produce first evidence set)

• Build or refine automated restore tests for core data stores.
• Add automated service recovery validation (health checks, synthetic transactions) for critical applications.
• Run at least one end-to-end automated test in a controlled window.
• Create tickets for all failures and document corrective actions with owners.

Days 61–90 (operationalize and harden)

• Expand test coverage to remaining in-scope systems and third-party dependent services within the boundary.
• Add monitoring/alerting for failed test runs.
• Require periodic management review of results and remediation status.
• Package an assessor-ready evidence set: procedure, test matrix, last runs, logs, tickets, retests.

If you manage this in Daydream, configure recurring evidence tasks for test runs, logs, and AARs, and assign owners so collection does not depend on ad hoc requests during audit season.

Frequently Asked Questions

What counts as “automated mechanisms” for CP-4(3)?

Any system-driven method that executes contingency tests or key recovery steps and produces machine-generated results, such as scheduled restore jobs, DR orchestration workflows, or CI/CD pipelines with validation checks. Document your chosen mechanisms in your CP-4(3) procedure. ¹

Do we need to automate the entire contingency plan?

No. CP-4(3) requires testing the contingency plan using automated mechanisms, but you can scope automation to the portions that are practical and highest risk, then expand over time. Keep a mapping that shows which plan elements are covered by automation. ¹

Is a screenshot of a successful restore enough evidence?

Screenshots help, but assessors usually prefer raw logs, job histories, and exported reports because they are timestamped and harder to dispute. Store the system-generated outputs and reference them from your after-action notes.

How do we handle third-party services in automated contingency tests?

Define what you can test within your control (configuration, failover actions, restore procedures) and collect third-party-provided reports where they are part of the recovery chain. Tie all dependencies back to your test matrix so the boundary is clear.

What should the control narrative say to satisfy auditors?

State the automated mechanisms, test scope, frequency approach, who reviews outcomes, where evidence is stored, and how failures become corrective actions with retesting. Keep it short, specific, and mapped to artifacts.

What is the fastest way to fail CP-4(3) in an assessment?

Running tests without keeping retrievable machine-generated outputs, or having repeated failures with no documented remediation and retest. Treat evidence capture and ticket closure as part of the control, not extra work.

Footnotes

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

2. NIST SP 800-53 Rev. 5