CP-7(5): Equivalent Information Security Safeguards

CP-7(5): equivalent information security safeguards requirement means your alternate site and failover approach must provide security protections that are effectively comparable to your primary environment, so resilience does not create a weaker security posture. Operationalize it by defining “equivalent,” mapping controls between primary and alternate sites, closing gaps, and retaining objective evidence that the safeguards work in practice. ¹

Key takeaways:

• Define “equivalent safeguards” as measurable security outcomes, not “same tooling.”
• Build a primary-to-alternate control mapping with documented compensating controls and approvals.
• Keep assessor-ready evidence: configurations, access controls, testing results, and exception rationale. ²

CP-7 is the NIST SP 800-53 Contingency Planning control for alternate processing sites. Enhancement (5) focuses the conversation on a common operational failure mode: teams build an alternate site to meet availability objectives, but the alternate environment ends up with weaker identity, logging, encryption, segmentation, vulnerability management, or change control than production. CP-7(5) exists to prevent resiliency architecture from becoming a security backdoor. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path is to translate “equivalent safeguards” into a concrete definition your engineering teams can implement and your assessors can verify. That means: (1) scoping which alternate site patterns you actually have (warm standby, hot site, cloud multi-region, third-party DR provider), (2) mapping security safeguards that must carry over, (3) documenting any differences as compensating controls with risk acceptance where needed, and (4) validating equivalence through testing and review. ²

This page gives requirement-level guidance you can assign, track, and audit.

Regulatory text

Control reference: “NIST SP 800-53 control CP-7.5.” ¹

Operator interpretation of the excerpt: CP-7(5): Equivalent Information Security Safeguards requires you to ensure that the information security safeguards at the alternate processing site are equivalent to those at the primary site. Treat “equivalent” as “comparable protection for confidentiality, integrity, and availability under the alternate site’s operating conditions,” not “identical technology stacks.” ²

What the operator must do:

• Establish a defined standard for equivalence (what must match, what may differ, and how you prove it).
• Implement and verify equivalent safeguards across the alternate site path (infrastructure, identity, network, endpoints, data, monitoring, and operations).
• Document exceptions and compensating controls in a way an assessor can trace from requirement → implementation → evidence. ¹

Plain-English interpretation (what the requirement is really asking)

If you can run critical workloads in an alternate site, attackers can target that site too. CP-7(5) expects that your DR or failover environment does not become a “less secure production.” You should be able to answer, with evidence:

• If we fail over today, do we still enforce the same access decisions (who can do what)?
• Do we still protect data the same way (encryption, key management, backups)?
• Do we still detect and respond the same way (logs, alerts, incident procedures)?
• Do we still manage change and vulnerabilities the same way (patching, scanning, approvals)?

Equivalence is about security outcomes. It is acceptable for the mechanisms to differ if the protection is comparable and justified. ²

Who it applies to (entity and operational context)

This requirement is relevant to:

• Federal information systems implementing NIST SP 800-53 controls. ²
• Contractor systems handling federal data where NIST SP 800-53 is flowed down contractually or used as the system control baseline. ¹

Operational contexts where CP-7(5) commonly applies:

• Cloud multi-region architectures (active/active or active/passive).
• Secondary data centers or colocation facilities.
• Third-party disaster recovery or managed hosting.
• “Pilot light” DR patterns where only minimal services run until failover.

If you have no alternate processing capability, CP-7 may be scoped differently, but if you claim alternate processing, CP-7(5) becomes a design-and-evidence requirement.

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

1) Define “equivalent safeguards” for your environment

Create a short “equivalence standard” that teams can build to and auditors can test against. Include:

• Safeguard domains: IAM, network security, cryptography/key management, vulnerability management, secure configuration, logging/monitoring, incident response integration, backups, and change control.
• “Must be equivalent” items (non-negotiables): e.g., MFA required, encryption required, centralized logging required.
• “May differ” items with conditions: e.g., different SIEM collectors allowed if logs reach the same monitoring and retention outcomes.

Deliverable: Equivalent Safeguards Standard for Alternate Sites mapped to your control set and system boundary. ²

2) Inventory alternate site patterns and in-scope workloads

Build an inventory that answers:

• What is the alternate site (region, facility, third party)?
• What workloads fail over, and under what conditions?
• What data classes exist in the alternate site during normal ops and during failover?
• Who administers the environment (internal staff vs third party)?

Deliverable: Alternate Processing Site Register linked to the system inventory/CMDB.

3) Map primary-site safeguards to alternate-site implementations

Create a control mapping table that a reviewer can follow end-to-end. Example structure:

Safeguard area	Primary site control mechanism	Alternate site mechanism	Equivalence result	Gap / compensating control	Evidence
Admin access	SSO + MFA + PAM	SSO + MFA (no PAM)	Not equivalent	Comp control: just-in-time admin, session recording, quarterly review; risk acceptance until PAM deployed	Access policy, configs, review logs

Keep the table narrowly focused on safeguards that plausibly diverge across sites (identity, keys, logging, vulnerability tooling, network boundaries). ¹

4) Close gaps or document compensating controls with approvals

For each “not equivalent” finding, choose one:

• Remediate: implement the missing safeguard in the alternate site.
• Compensate: implement alternative measures that achieve comparable risk reduction.
• Accept risk: only with explicit documented rationale, scope limits, and time-bound remediation plan.

Minimum operator discipline:

• Assign a control owner for each gap.
• Track to closure in your GRC system with milestones.
• Require security sign-off for any equivalence exception.

5) Validate equivalence through operational testing

Your evidence should show that equivalence holds during real conditions, not only in diagrams. Include tests such as:

• Failover test verifying authentication paths, MFA enforcement, and admin break-glass controls.
• Log generation and forwarding test from alternate site assets into your monitoring stack.
• Vulnerability scanning coverage validation for alternate subnets/accounts/projects.
• Backup/restore test that confirms encryption and access controls around restored data.

Deliverable: Alternate Site Security Equivalence Test Report with pass/fail results, issues, and remediation tracking.

6) Bake equivalence into change management and procurement

Equivalence breaks when the primary site evolves faster than DR. Add two gating checks:

• Change management: changes to security baselines trigger “alternate site parity” updates.
• Third-party due diligence: DR/hosting providers must meet your equivalence standard contractually (security requirements, audit rights, incident notification, access controls).

If you use Daydream for third-party risk management, treat CP-7(5) as a vendor requirement clause and map it to recurring evidence requests (e.g., access control attestations, SOC reports where applicable, configuration statements, DR test outputs). Daydream also helps keep the control owner, procedure, and evidence cadence tied together so CP-7(5) doesn’t degrade after the audit window. ¹

Required evidence and artifacts to retain

Keep artifacts that prove design and operating effectiveness:

Governance and scope

• Equivalent Safeguards Standard for Alternate Sites (approved, versioned)
• Alternate Processing Site Register (scope, owners, workloads, data types)
• System boundary diagram(s) including alternate site traffic flows

Technical and operational

• IAM configuration screenshots/exports (MFA, SSO, role assignments) for alternate site
• Network segmentation and firewall/security group rules for alternate site
• Encryption and key management evidence (KMS policies, key rotation settings, access logs)
• Centralized logging configuration and sample logs from alternate site assets
• Vulnerability scanning coverage reports including alternate site assets
• DR/failover test reports showing security checks, not only uptime outcomes
• Exception register entries for any non-equivalent safeguards with compensating controls and approvals

Third-party (if applicable)

• Contract/SOW security clauses reflecting equivalence expectations
• Third-party security attestations and evidence packages aligned to your standard

Common exam/audit questions and hangups

Assessors commonly probe:

• “Show me your definition of ‘equivalent’ and who approved it.”
• “During failover, does privileged access follow the same controls?”
• “Do you collect and monitor logs from the alternate site at the same level?”
• “Is vulnerability management coverage demonstrably the same?”
• “Where are exceptions documented, and what compensating controls exist?”
• “How do you ensure parity after changes in production?” ²

Hangups that slow audits:

• Evidence scattered across teams with no single mapping to CP-7(5).
• DR test reports that only validate recovery time, not security controls.
• “We intend to” language without implemented settings or test outputs.

Frequent implementation mistakes (and how to avoid them)

1. Treating equivalence as “same vendor/tool.”
   Avoid: tool checklists.
   Do: outcome-based requirements (MFA enforced, logs centralized, keys controlled). ²

2. Ignoring identity and break-glass paths.
   Avoid: separate local admin accounts at DR without centralized governance.
   Do: document and test emergency access, approvals, and monitoring.

3. Logging parity only on paper.
   Avoid: “SIEM covers it” without confirming alternate site sources are onboarded.
   Do: keep sample events and ingestion proof from alternate assets.

4. Failover network paths bypass inspection.
   Avoid: DR VPNs or interconnects that skip security controls used in primary.
   Do: review alternate routing, firewall rules, DNS changes, and inspection points.

5. Exception sprawl without expiry.
   Avoid: permanent “temporary” compensating controls.
   Do: require an owner, rationale, and a closure plan tracked in GRC.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat CP-7(5) primarily as an assessment and authorization risk: failure typically results in audit findings, ATO delays, contract performance issues, and increased incident exposure if attackers pivot to weaker alternate infrastructure. ¹

Practical execution plan (30/60/90-day)

First 30 days: establish scope and definition

• Assign a control owner and technical counterparts (IAM, network, cloud/platform, IR).
• Publish the Equivalent Safeguards Standard (draft → approve).
• Inventory alternate sites and failover-capable workloads.
• Build the first version of the primary-to-alternate safeguard mapping for the highest-impact workloads. ²

By 60 days: close obvious gaps and formalize exceptions

• Remediate high-risk gaps (privileged access, logging, encryption/key access).
• Create an exception workflow: required fields, approvers, expiration triggers.
• Update DR test plans to include explicit security equivalence test steps.
• Add change-management gates for alternate site parity checks.

By 90 days: validate, evidence, and operationalize

• Execute a failover or tabletop that produces security evidence (access, logs, scans).
• Package artifacts into an assessor-ready folder indexed to CP-7(5).
• Add recurring reviews (parity review after material changes, periodic evidence refresh).
• If third parties operate the alternate site, align contracts and evidence requests to your equivalence standard and track delivery in your GRC workflow. ¹

Frequently Asked Questions

What does “equivalent” mean if my alternate site is a different cloud region or provider?

Treat equivalence as comparable security outcomes (access control, logging, encryption, vulnerability coverage), even if mechanisms differ. Document differences as compensating controls and test them during failover. ²

Do I need identical logging retention and SIEM rules in the alternate site?

You need monitoring and logging safeguards that are comparable in effectiveness for detection and investigation. If retention or rule coverage differs, document the rationale and implement compensating controls you can defend with evidence. ²

How do I handle “pilot light” DR where most services are off until failover?

Secure the dormant infrastructure (accounts, network boundaries, keys, images) and prove that, upon activation, required safeguards come online automatically (IaC baselines, enforced MFA, logging pipelines). Your evidence should include pre-failover configuration plus activation checks. ¹

Can a third-party DR provider satisfy CP-7(5) on my behalf?

A third party can operate controls, but you remain responsible for defining equivalence, contracting for it, and collecting evidence. Require attestations and artifacts that map to your equivalence standard and confirm through your own testing where feasible. ²

What evidence is most persuasive to auditors for CP-7(5)?

A control mapping that ties each safeguard to alternate-site configurations, plus failover/security test results showing those safeguards operate during real conditions. Pair that with an exception register for any gaps and documented approvals. ²

How do we keep equivalence from drifting over time?

Add parity checks to change management and schedule periodic reviews of the alternate site baseline against production. Track gaps and evidence on a recurring cadence in your GRC tooling so ownership and artifacts stay current. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5