CP-5: Contingency Plan Update

To meet the cp-5: contingency plan update requirement, you must keep your contingency plan current by establishing a defined update trigger set (system changes, organizational changes, lessons learned, test results) and a repeatable process to revise, re-approve, and redistribute the plan with provable evidence. CP-5 is operationally satisfied only when updates are controlled, timely, and traceable. ¹

Key takeaways:

• Treat CP-5 as a change-management-integrated update workflow, not a once-a-year document refresh. ¹
• Maintain audit-ready evidence: triggers, version history, approvals, distribution records, and test-driven updates. ²
• Assign a single accountable owner and recurring artifacts so CP-5 is continuously assessable, not a scramble before an ATO or customer audit. ¹

CP-5 sits in the Contingency Planning (CP) family and focuses on keeping the contingency plan accurate as your environment changes. In practice, most CP programs fail audits for one reason: teams can produce a plan, but they can’t show a disciplined mechanism for updating it after meaningful changes, tests, or incidents.

For a Compliance Officer, CCO, or GRC lead, CP-5 is one of the fastest controls to operationalize because it can ride on processes you already have: change management, incident response retrospectives, BCDR testing, and periodic control reviews. The operational challenge is governance: who decides an update is required, what qualifies as “significant,” how quickly the plan must change, and how you prove the plan in production matches reality.

This page gives requirement-level implementation guidance you can put in place quickly: roles, triggers, workflow steps, evidence to retain, and the audit questions you should expect. It also includes a practical execution plan and FAQs for the real edge cases (cloud services, third parties, inherited controls, and frequent releases). Control reference: CP-5 in NIST SP 800-53 Rev. 5. ³

CP-5 overview (what the control is trying to prevent)

CP-5 reduces the risk of relying on an obsolete contingency plan during a disruption. An outdated plan commonly breaks in predictable places: wrong system owners, missing dependencies, deprecated recovery procedures, and inaccurate restoration priorities. The control expectation is straightforward: when reality changes, the contingency plan changes too, and you can prove it. ¹

Regulatory text

Excerpt (as provided): “NIST SP 800-53 control CP-5.” ²

Operator interpretation of what you must do: Implement CP-5 by defining and executing a repeatable process to update your contingency plan, including:

• Triggers that force review/update (for example: system architecture changes, new dependencies, changes in recovery strategy, test findings, incident lessons learned).
• Governance (owner, reviewers, approver, and distribution).
• Evidence that updates occurred, were approved, and were communicated.
  This is assessed as an operating control: auditors look for change-driven updates and clean version history, not a static document. ¹

Who CP-5 applies to

Entity scope

• Federal information systems implementing NIST SP 800-53. ¹
• Contractor systems handling federal data where NIST SP 800-53 is a contractual or program requirement (common in regulated federal contracting contexts). ¹

Operational scope (what systems and teams are in play)

• Systems with defined recovery objectives and restoration priorities (production services, key internal platforms, security services).
• Shared responsibility environments: cloud-hosted apps, SaaS dependencies, and managed service providers. CP-5 still applies; you update your plan to reflect what you inherit vs. what you operate. ¹

Plain-English requirement (what “good” looks like)

You have a contingency plan that reflects the current system and current recovery approach. When you change architecture, add a critical third party, change backup tooling, or run a test that exposes gaps, you update the plan, re-approve it, and make sure responders can access the latest version during an outage. You can show an auditor the trigger, the edit, the approval, and the distribution. ¹

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

1) Assign ownership and define the control boundary

• Control owner: name the accountable person (often BCDR lead, IT Ops leader, or system owner for the boundary).
• Supporting roles: SRE/Infrastructure, Security, Application owners, Service Desk, third-party management, and Compliance for evidence quality.
• Boundary statement: list which services, environments, and dependencies the plan covers (include critical third parties and shared services).
  Output: a simple RACI and boundary note attached to the plan. ¹

2) Define “update triggers” that require plan revision

Create a trigger list and route each trigger to your CP-5 workflow. Common triggers:

• Material system changes (new regions, new identity provider, new storage tier, new network segmentation).
• Critical third party change (new MSP, new backup provider, new DNS/CDN provider, contract change affecting restore support).
• BCDR test or tabletop findings (gaps, outdated steps, missing contacts).
• Incident postmortems that touch availability, integrity, or recoverability.
• Organizational changes (new on-call rotations, team re-org, escalation paths).
  Output: CP-5 trigger register or checklist integrated with change management. ¹

3) Implement a controlled document lifecycle (versioning + approvals)

Put the contingency plan under document control:

• Version numbering and change log (what changed, why, who requested).
• Approval workflow (system owner + continuity authority; include security sign-off when recovery steps affect security controls).
• Distribution rules (where the authoritative copy lives; how responders access it during an outage).
  Output: a versioned plan with a recorded approval trail. ²

4) Tie CP-5 updates to testing and real operational signals

A plan that never changes is a red flag. Build a feedback loop:

• After each BCDR exercise: log findings, assign remediation owners, and update the plan where procedure or dependencies changed.
• After high-severity incidents: require a “BCDR relevance” check in the post-incident review template.
  Output: test reports and postmortems that explicitly show whether a plan update was required and completed. ¹

5) Prove people can execute the current plan

Operationalize access and awareness:

• Ensure responders have access during identity outages (break-glass access method or offline export, consistent with your security policy).
• Confirm on-call rotations, escalation contacts, and third-party support paths are current.
  Output: distribution record + periodic validation that contact lists and access methods work. ¹

6) Map CP-5 to recurring evidence (make audits routine)

Turn CP-5 into a checklist-driven evidence routine:

• Control owner identified
• Update triggers documented
• Plan updated when triggers occurred
• Approvals and distribution captured
  If you use Daydream, track CP-5 as a control with assigned ownership, an implementation procedure, and recurring evidence artifacts so collection is continuous instead of reactive. ¹

Required evidence and artifacts to retain (audit-ready)

Maintain a single “CP-5 evidence packet” per system boundary:

• Contingency plan (current) with version history and change log. ¹
• Documented update triggers and decision criteria (what counts as significant). ¹
• Approval records (ticket, e-signature, meeting minutes, or workflow approval). ²
• Distribution/availability proof (link to authoritative repository, access control list, offline copy procedure). ¹
• Evidence of trigger events and resulting updates:
  • Change tickets with CP impact assessment
  • BCDR test reports and action items
  • Incident postmortems referencing plan updates ¹
• Exceptions register (if a trigger did not result in an update, record the rationale and approver). ¹

Common exam/audit questions and hangups

Auditors and assessors tend to probe the same failure modes:

• “Show me the last time the contingency plan changed and what triggered it.” ¹
• “How do you know this plan reflects the current architecture and third-party dependencies?” ¹
• “Who approves updates, and how do responders know they are reading the current version?” ¹
• “What happens if a major change is implemented under an emergency change process?” Expect scrutiny here; make CP-5 part of the emergency change retrospective. ¹
• “Where is the plan stored, and can the team access it during an outage that affects SSO or email?” ¹

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails CP-5	Fix
Annual refresh only	Ignores change-driven updates	Add triggers tied to change management and incident reviews. 1
No version control	Can’t prove which plan was effective	Use controlled versions and maintain a change log. 2
Plan updated but not approved	Weak governance; assessors treat it as informal	Require recorded approvals for updates. 1
Third parties missing	Recovery depends on providers you don’t name	List critical third parties and their recovery support path in the plan. 1
“Access during outage” not addressed	Plan becomes unreachable when needed	Define break-glass or offline access method and test it. 1

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for CP-5. The practical risk is operational: outdated contingency plans increase outage duration, increase recovery error rates, and complicate incident response coordination. In federal assessment contexts, weak CP-5 evidence can delay authorization decisions or result in plan-of-action items because assessors need to see controlled updates and traceability. ¹

Practical execution plan (30/60/90)

First 30 days (stabilize governance and evidence)

• Assign CP-5 owner and approver(s); document the system boundary. ¹
• Put the plan in a controlled repository with version history and an approval workflow. ¹
• Draft the trigger list and add a CP-5 check to change tickets and post-incident reviews. ¹
• Create an evidence checklist and start a CP-5 evidence folder per system.

Days 31–60 (connect to operations)

• Run a targeted review against current architecture diagrams, third-party inventory, and on-call rotations; update the plan where mismatched. ¹
• Validate “access during outage” with security and IT (break-glass, offline export, alternate comms reference). ¹
• Train incident commanders and service owners on when to trigger a plan update and how to route it for approval.

Days 61–90 (prove continuous operation)

• Execute a tabletop or recovery exercise and feed findings into a controlled plan update with recorded approvals. ¹
• Sample recent change tickets and verify CP impact assessment is working; fix gaps in routing.
• If you use Daydream, formalize CP-5 as a recurring control: owner, procedure, and scheduled evidence prompts for version history, approvals, and trigger sampling. ¹

Frequently Asked Questions

What counts as a “significant change” that triggers a contingency plan update?

Define this locally based on what would change recovery steps, dependencies, roles, or restoration order. Use concrete triggers tied to architecture changes, third-party dependency changes, and BCDR test findings. ¹

Do we need to update the contingency plan after every change ticket?

No. You need a process to evaluate change impact and update the plan when changes affect recoverability or execution. Prove the evaluation happened, even when the decision is “no update required.” ¹

Who should approve contingency plan updates?

The system owner (or service owner) should approve because they own operational risk, and your continuity authority should approve for consistency across the program. Add security review when recovery steps touch privileged access or security tooling. ¹

How do we handle third-party (vendor/SaaS) dependencies in CP-5?

List critical third parties in the plan with support contacts, escalation paths, and what you expect them to provide during restoration. Update the plan when contracts, SLAs, or technical integration points change. ¹

Our contingency plan is “inherited” from a parent organization. Are we done?

Only if the inherited plan accurately reflects your system boundary and your actual recovery execution. Keep local addenda for system-specific dependencies, contacts, and procedures, and maintain evidence of updates when your environment changes. ¹

What is the minimum evidence set to satisfy an assessor quickly?

Provide the current plan with version history, one or more examples of a trigger that led to an update, the approval record for that update, and proof that responders can access the current version. ²

Footnotes

1. NIST SP 800-53 Rev. 5

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

3. NIST SP 800-53 Rev. 5; Source: NIST SP 800-53 Rev. 5 OSCAL JSON