CP-7(6): Inability to Return to Primary Site

CP-7(6): Inability to Return to Primary Site requires you to plan for a scenario where the primary processing site is not recoverable in a practical timeframe and operations must continue from an alternate arrangement. Operationalize it by defining “no return” triggers, designing a long-duration alternate processing capability, and proving you can run there through tested procedures and retained evidence. ¹

Key takeaways:

• Treat “can’t return” as a distinct disaster scenario with its own triggers, decision rights, and operating model. ¹
• Build and test a sustained alternate processing capability, not a short outage workaround. ¹
• Auditors will focus on evidence: decision criteria, runbooks, test results, and proof critical services can run away from the primary site. ¹

CP-7 is the NIST SP 800-53 contingency planning control for alternate processing sites. Enhancement (6) narrows the problem: you are planning for the case where the primary site is not just down, but cannot be used again for an extended period. That might be a fire, flood, long-term utility loss, structural damage, a site access prohibition, or a third-party facility failure where you do not control remediation.

For a Compliance Officer, CCO, or GRC lead, the fastest path to “done” is to turn CP-7(6) into three operational decisions: (1) what conditions qualify as “cannot return,” (2) who declares that condition and authorizes the sustained move, and (3) what minimum processing capability must be continuously available elsewhere to meet mission and regulatory obligations. The control is deceptively short; the work is in making it executable, testable, and provable with artifacts.

This page gives requirement-level implementation guidance you can hand to IT, security, facilities, and application owners, then collect clean evidence for assessors. Primary reference: NIST SP 800-53 Rev. 5. ²

Regulatory text

Requirement (verbatim): “Plan and prepare for circumstances that preclude returning to the primary processing site.” ¹

Operator meaning: You need a contingency approach for a “no return” scenario where the primary site is not a viable target for recovery in a reasonable operational window. Your plan must cover the decision to abandon the primary site (temporarily or long-term), the alternate processing arrangement that can sustain operations, and the procedures and resources to operate from that arrangement. ¹

Plain-English interpretation (what the assessor expects)

Assessors typically read CP-7(6) as: “Show me you can keep critical systems running even if the primary site is gone for a while, and show me you have thought through the moment you stop trying to go back.” The difference from general DR is intent and duration:

• General DR often assumes you return once the incident clears.
• CP-7(6) assumes you may have to operate away from the primary site for an extended period, possibly with a permanent migration decision. ¹

If your DR plan says “fail over to secondary, then fail back,” but you have no defined criteria for when failback is impossible, you will struggle to show conformance.

Who it applies to (entity + operational context)

This control is commonly scoped to:

• Federal information systems and programs adopting NIST SP 800-53 control baselines. ²
• Contractor systems handling federal data (including systems authorized under federal requirements or assessed against NIST-aligned frameworks). ¹

Operationally, it applies to any system or service where loss of a processing location could stop mission/business functions, including:

• On-prem data centers and colocations
• IaaS/PaaS regions and “single-region” architectures
• SaaS dependencies that can become a de facto “primary processing site” for a critical workflow (treat this as a third-party risk input to your contingency plan)

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

Use this sequence to get from requirement to operational capability.

1) Define the “inability to return” scenario in writing

Create a short “No Return Scenario Definition” and attach it to your Contingency Plan/DR plan.

• Trigger categories: structural damage, long-term power loss, environmental hazard, legal/access restrictions, sustained network carrier failure, third-party facility closure, region-wide cloud impairment.
• Practical threshold: define qualitative criteria such as “site access is unavailable beyond our recovery window” or “repairs require relocation.” Avoid fuzzy language like “major event” without decision criteria.
  Deliverable: documented trigger list + how you will validate the trigger (facilities report, cloud provider status, landlord notice, incident commander assessment). ¹

2) Assign decision rights and escalation

Document:

• Who recommends a “no return” declaration (Incident Commander, Facilities lead, SRE lead).
• Who approves it (CIO/CTO, Business Continuity leader, Authorizing Official delegate where applicable).
• Who must be informed (system owners, security, privacy, key third parties, customer comms, regulators/contracting officer when required by your contract terms).
  Deliverable: RACI + contact roster integrated with incident response and business continuity communications. ¹

3) Design an alternate processing capability that can be sustained

This is the control’s center of gravity. Your alternate site must support ongoing operations, not a brief stopgap.

• Architecture choice: secondary data center, warm site, cloud multi-region, cross-account restore, or contracted alternate processing arrangement.
• Dependencies: identity, DNS, certificate management, key management, logging/SIEM, monitoring, software delivery pipeline, secrets management, and third-party integrations.
• Capacity planning (qualitative): define what “minimum viable service” is at the alternate site so you can run essential business processes.
  Deliverable: an “Alternate Processing Design” document or runbook that lists which services run where, and how you operate there for an extended period. ¹

4) Write “operate-from-alternate” procedures (not just failover steps)

Create runbooks that answer operational questions people ask on day two:

• How do releases, patches, and hotfixes work from the alternate environment?
• How do you handle user provisioning and access reviews when the primary IAM components are unreachable?
• How do backups run and where are they stored while operating in alternate mode?
• How do you collect logs, detect threats, and respond to incidents from the alternate site?
• How do you handle third-party connectivity (VPNs, allowlists, API endpoints, SFTP targets)?
  Deliverable: “Sustained Operations in Alternate Mode” runbook with named owners. ¹

5) Test the “no return” path and keep the receipts

A basic failover test is not enough if it never exercises “we are not coming back soon.” Your test should include:

• Declaring the “no return” condition
• Cutting over critical services
• Operating for a meaningful period (long enough to execute routine tasks like batch jobs, user onboarding, monitoring, backups, and a change)
  Deliverable: test plan, execution record, issues list, and retest evidence after remediation. ¹

6) Map the requirement to an owner, procedure, and recurring evidence

Make CP-7(6) assessable:

• Control owner (BCP lead, DR program manager, or SRE/IT resilience lead)
• Implementation procedure (the documents above)
• Recurring evidence (tests, reviews, architecture attestations)
  Daydream can help you keep this mapping clean and continuously audit-ready by linking CP-7(6) to owners, tasks, and evidence requests on a cadence that matches your risk. ¹

Required evidence and artifacts to retain

Keep artifacts in an assessor-friendly package (single folder per system, consistent naming):

1. No Return Scenario Definition (triggers + validation inputs) ¹
2. Decision/RACI + escalation paths (including alternates) ¹
3. Alternate processing architecture/design (diagrams accepted if they show dependencies) ¹
4. Runbooks (failover, operate-from-alternate, and failback decision logic even if failback is deferred) ¹
5. Test plan + test results (including issues and remediation actions) ¹
6. Evidence of readiness reviews (periodic contact list verification, restoration validation, third-party dependency review) ¹

Common exam/audit questions and hangups

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

• “Show me how you determine you cannot return to the primary site.” ¹
• “Who has authority to declare that condition, and how is it documented during an incident?” ¹
• “Can you operate critical business processes from the alternate site, or only restore infrastructure?” ¹
• “What third parties must change endpoints or connectivity when you move?” ¹
• “When was the last test that included sustained operations and not just a cutover?” ¹

Hangup pattern: teams provide a DR policy, a single-page BCP summary, and a backup report. Assessors want the decision logic and proof of operating capability away from the primary site. ¹

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails CP-7(6)	Fix
Only planning for “fail back soon”	No plan for extended displacement from primary site	Add “no return” triggers and an alternate-mode operating model 1
Alternate site exists, but dependencies don’t	IAM, DNS, logging, secrets, third-party allowlists block operations	Build a dependency checklist and test it end-to-end 1
Tests are tabletop-only	No proof systems actually run from alternate	Run a technical exercise with real cutover and operations 1
Evidence is scattered	Audit delays and “not demonstrated” findings	Centralize artifacts and map them to CP-7(6) with an owner 1

Enforcement context and risk implications

No public enforcement cases were provided in the source material for this requirement, so treat enforcement context as “audit and authorization risk” rather than a specific penalty narrative. Practically, CP-7(6) gaps show up as:

• Authorization delays for federal systems
• Contract risk for contractors handling federal data
• Operational resilience risk: long-duration outages, data integrity issues during migration, and elevated security risk if teams bypass controls under pressure ¹

Practical 30/60/90-day execution plan

Use this as a sequencing guide. Adjust for system criticality and architecture complexity.

First 30 days (stabilize scope and decisions)

• Confirm in-scope systems and identify the “primary processing site” for each (data center, colo, cloud region).
• Draft “No Return Scenario Definition” and get sign-off from IT, security, and business owners. ¹
• Publish RACI and escalation contacts; integrate into incident response call tree. ¹
• Create an evidence index for CP-7(6) so collection is consistent from day one. ¹

Days 31–60 (build the sustained alternate capability)

• Document alternate processing design and validate dependency coverage (IAM, DNS, keys, logging, monitoring, CI/CD). ¹
• Write the “operate-from-alternate” runbook, including third-party coordination steps. ¹
• Define readiness checks and who performs them (for example, restore validation and contact roster verification). ¹

Days 61–90 (prove it works and lock evidence)

• Execute a test that declares “no return,” cuts over, and runs in alternate mode long enough to perform routine ops tasks. ¹
• Track issues to closure, then retest the specific failures. ¹
• Finalize control mapping: owner, procedure links, and recurring evidence cadence in Daydream or your GRC system so the control stays alive after the audit. ¹

Frequently Asked Questions

Does CP-7(6) require a second physical data center?

No specific architecture is mandated in the text; it requires planning and preparation for a “no return” scenario. You can meet it with cloud multi-region, a contracted alternate site, or another design, as long as you can sustain operations away from the primary site. ¹

How is this different from CP-7 (base control) in practice?

CP-7 addresses alternate processing broadly; CP-7(6) forces you to handle extended loss of the primary site and the decision to stop planning on a near-term return. Your evidence should show triggers, decision rights, and sustained operations procedures. ¹

What’s the minimum evidence an auditor will accept?

Provide a documented “no return” trigger definition, an alternate processing design, runbooks for operating in alternate mode, and test results showing you can actually run from the alternate arrangement. Missing test evidence is a common reason for “not demonstrated.” ¹

We’re fully SaaS. What is the “primary processing site”?

For SaaS-heavy environments, treat the “primary site” as the primary SaaS dependency and your integration/identity/control plane that makes it work. Your plan should address prolonged SaaS unavailability and the alternate way you continue critical processing (manual procedures, alternate provider, or alternate workflow). ¹

Do we need to document failback if CP-7(6) assumes we can’t return?

Yes, document how you decide whether failback is possible, even if the default in this scenario is “operate away from primary for an extended period.” Assessors want clear decision logic and governance, not a single technical switch. ¹

How do we keep CP-7(6) from becoming a one-time project?

Assign a control owner, define recurring evidence (tests, readiness reviews, dependency updates), and keep artifacts current as architectures and third-party dependencies change. Daydream can track owners and evidence requests so you can demonstrate ongoing operation without scrambling before an assessment. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5