CP-10: System Recovery and Reconstitution

CP-10 requires you to restore a system to a known-good state within a defined time after a disruption, compromise, or failure, and to be able to prove you can do it. Operationalize it by defining the recovery time objective, documenting reconstitution steps, pre-staging required resources, and running recovery tests that produce auditor-ready evidence. ¹

Key takeaways:

• Define what “known state” means for each system and how you validate it after recovery. ¹
• Set an explicit recovery time requirement and map it to runbooks, backups, images, keys, and access needed to rebuild. ¹
• Treat evidence as part of the control: logs, tickets, test results, and reconstitution checklists must be repeatable and retained. ¹

“Recovery” is easy to claim and hard to demonstrate. CP-10: system recovery and reconstitution requirement is the NIST SP 800-53 control that forces the issue: after an outage or security event, you must be able to restore the system and reconstitute it to a known state within an explicitly defined time window. ¹

For a Compliance Officer, CCO, or GRC lead, the practical challenge is alignment. Security teams often focus on backup success, IT focuses on uptime, and incident response focuses on containment. CP-10 cuts across all three. You need a single, auditable story for “how we get back to known-good,” including who does what, the order of operations, and the proof you can meet the required timeframe. ¹

This page translates CP-10 into implementable steps: scoping, defining the recovery requirement, building reconstitution runbooks, instrumenting evidence, and test routines that stand up in an assessment. It also calls out common audit hangups (for example, “known state” not defined, or restore tested but reconstitution not validated) and provides a practical execution plan. ¹

cp-10: system recovery and reconstitution requirement (what it is)

CP-10 is a contingency planning control focused on restoring operations after adverse events. The requirement is explicit: you must provide for recovery and reconstitution of the system to a known state within a defined time after a disruption, compromise, or failure. ¹

“Recovery” usually means returning service. “Reconstitution” means rebuilding or restoring system components and configurations to a verified, approved baseline (a “known state”) so you can trust the environment again, especially after compromise. CP-10 expects both. ¹

Plain-English interpretation

You need documented, repeatable procedures and pre-arranged resources to:

1. restore the system quickly enough to meet your defined recovery time requirement, and
2. prove the restored system matches a known-good baseline and is safe to resume processing. ¹

Regulatory text

NIST SP 800-53 Rev. 5 CP-10 excerpt: “Provide for the recovery and reconstitution of the system to a known state within [organization-defined time period] after a disruption, compromise, or failure.” ¹

Operator meaning: you must pick the time period ¹, document it as a control requirement, and build operational capability (runbooks, tooling, access, backups/images, validation checks) to meet it after outages and security events. Assessors will expect evidence that the capability works, not just that it is written down. ¹

Who it applies to

CP-10 applies wherever NIST SP 800-53 is in scope, including federal information systems and contractor systems handling federal data. ¹

Operationally, it applies to:

• Production systems that process, store, or transmit sensitive data (especially regulated workloads).
• Shared services (identity, logging, key management, network controls) because you cannot reconstitute an application without its dependencies.
• Cloud and hybrid environments where reconstitution may rely on infrastructure-as-code, golden images, and managed service restore features.

If you run a multi-tenant platform, treat CP-10 as per-environment (prod vs non-prod) and per-critical service tier. Your “known state” definition should be consistent with your change management baselines and security configuration standards. ¹

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

Use this sequence to operationalize CP-10 with minimal rework.

Step 1: Define scope and recovery objectives

• Identify the systems in scope and their upstream/downstream dependencies.
• Define the required recovery timeframe for each system or tier (this is the CP-10 organization-defined parameter). Record where it is approved (risk committee, system owner, or authority to operate package). ¹

Deliverable: a recovery objectives register (system → required recovery timeframe → owner → dependency notes).

Step 2: Define “known state” in a way you can validate

“Known state” must be testable. Define it as a combination of:

• Approved baseline configuration (for example, hardened OS image version, container base image digest, or IaC commit/tag).
• Approved application release (artifact version or deployment manifest).
• Security-critical state checks (patch level, endpoint agent healthy, logging connected, time sync working, IAM policies restored, key material rotated where required after compromise). ¹

Deliverable: a “known state definition” per system, written as a checklist with objective checks (commands, dashboards, or controls).

Step 3: Build recovery + reconstitution runbooks

Create runbooks that separate:

• Restore service (get it running),
• Reconstitute trust (prove it is clean and matches baseline).

Minimum runbook sections:

1. Trigger criteria (disruption vs compromise vs failure).
2. Roles and handoffs (IT ops, security/IR, application owner).
3. Recovery method (restore from backup, redeploy from images, rebuild from IaC).
4. Reconstitution checks (baseline and security verification).
5. Decision gate to return to service (who authorizes, what evidence is required).
6. Communications and escalation.

Make runbooks executable. Include exact locations for images, backups, IaC repos, secrets recovery procedures, break-glass access steps, and contact lists. ¹

Step 4: Pre-stage the resources you will need under stress

CP-10 fails in practice when the team “could recover” but lacks access or dependencies during an incident.

Validate, ahead of time:

• Backup integrity and restore paths.
• Access to artifact repositories and IaC pipelines during outages.
• Break-glass accounts, MFA bypass procedures (if allowed), and documented approval for emergency access.
• Key management restoration and post-compromise rotation procedures aligned to incident response.

Deliverable: a recovery dependency checklist with owners and a periodic verification cadence. ¹

Step 5: Test the process and capture evidence

Testing is where CP-10 becomes real. Your tests should demonstrate:

• You can recover within the defined timeframe, and
• You can reconstitute to a known state using objective validation checks.

Run at least two test types over time:

• Operational failure scenario (service outage, corruption, failed deployment).
• Compromise-informed scenario (assume the host or credentials were exposed; rebuild from trusted sources and verify clean baseline). ¹

Deliverable: test reports with start/end timestamps, steps performed, screenshots or logs of validation checks, and approvals to resume service.

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

Assessments stall when “everyone owns recovery.” Assign a named control owner (and delegate operators). Then map CP-10 to:

• Implementation procedure(s),
• Evidence list and collection method,
• Review cadence and sign-offs. ¹

If you use Daydream for GRC workflows, this is where it helps: you can assign CP-10 ownership, attach runbooks/test reports as recurring evidence tasks, and keep an audit-ready trail without chasing artifacts across chat logs and shared drives. ¹

Required evidence and artifacts to retain

Keep artifacts that prove design and operation:

Governance & definitions

• Recovery timeframe approvals for each in-scope system. ¹
• “Known state” definitions and validation checklists. ¹
• Control owner assignment and RACI. ¹

Operational procedures

• Recovery/reconstitution runbooks with version history. ¹
• Dependency checklist (access, backups, images, keys, tooling). ¹

Testing & execution

• Exercise plans, tickets, and after-action reports. ¹
• Logs/screenshots showing baseline validation checks passed. ¹
• Incident records where recovery/reconstitution was performed, including approval to return to service. ¹

Common exam/audit questions and hangups

Expect these lines of inquiry:

1. “Show me the defined recovery timeframe for this system and who approved it.” If it’s tribal knowledge, you will lose time in the audit. ¹
2. “What is ‘known state’ here, specifically?” Auditors push for objective criteria, not “looks normal.” ¹
3. “Prove you can do it.” They will ask for test results or incident evidence and whether reconstitution checks were performed. ¹
4. “How do you handle compromise vs failure?” Reconstitution after compromise often requires rebuild from trusted sources and stronger validation. ¹
5. “What about dependencies?” If identity, logging, or key management are down, recovery claims may be incomplete. ¹

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails CP-10	Fix
“Known state” is undefined	You cannot prove reconstitution	Write a checklist tied to baselines, versions, and security checks. 1
Backups tested, reconstitution not tested	Restore ≠ trusted rebuild	Add validation gates: baseline, IAM, logging, patch, endpoint health. 1
One runbook for all scenarios	Compromise recovery needs different steps	Split runbooks by event type or add branches with required security actions. 1
Access breaks during incidents	Teams can’t execute under pressure	Pre-stage break-glass access and dependency verification. 1
Evidence scattered across tools	Audit becomes a scavenger hunt	Centralize evidence tasks and attach artifacts to the control record (Daydream or your GRC system). 1

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so treat CP-10 primarily as an assessment and operational resilience expectation under NIST SP 800-53. ¹

Risk-wise, CP-10 gaps show up as:

• Extended downtime because recovery is unpracticed or blocked by missing access.
• Returning to service from an untrusted state after compromise (reinfection, persistence, or data integrity issues).
• Assessment findings for missing evidence even if teams believe recovery is “obvious.” ¹

Practical execution plan (30/60/90)

You asked for speed. Use these phases as a delivery plan and tailor depth by system criticality.

First 30 days: define and document what auditors will ask for

• Inventory in-scope systems and dependencies.
• Set the recovery timeframe requirement per system/tier and obtain approvals. ¹
• Define “known state” checklists for the most critical services.
• Assign CP-10 control owner and evidence owners; set up an evidence register (what, where, who, how often). ¹

By 60 days: make it executable

• Draft recovery + reconstitution runbooks for critical systems.
• Validate prerequisites: backups, images, IaC, break-glass access, key restoration steps.
• Run a tabletop that forces teams to walk the runbook and identify missing dependencies.
• Implement evidence capture templates (test report format, validation checklist, approval gate). ¹

By 90 days: prove it works and industrialize evidence

• Execute at least one practical recovery test for top-tier services and capture artifacts end-to-end. ¹
• Close gaps found in testing; update runbooks and “known state” definitions.
• Expand coverage to remaining in-scope systems based on risk.
• Operationalize recurring evidence collection in your GRC workflow (Daydream can schedule collection tasks and keep versioned artifacts attached to CP-10). ¹

Frequently Asked Questions

What does “reconstitution to a known state” mean in practice?

It means you can rebuild or restore the system and then verify it matches an approved baseline (config + software versions) with objective checks. For compromise scenarios, it also means you can re-establish trust, not just uptime. ¹

Do I need separate processes for “disruption” vs “compromise”?

You need at least a documented decision branch. Compromise recovery often requires rebuilding from trusted images/IaC and performing additional validation steps before returning to service. ¹

How do I set the CP-10 recovery timeframe parameter?

Set it as an organization-defined requirement per system or service tier and document the approval. Align it to business impact and dependency realities, then test that you can meet it. ¹

What evidence is strongest for CP-10 in an audit?

Executed recovery test records with timestamps, runbook steps performed, validation outputs proving the “known state,” and documented approval to return to service. Pair that with runbooks and the approved recovery timeframe. ¹

Does CP-10 apply to cloud-native systems that can redeploy quickly?

Yes. Fast redeploy helps, but CP-10 still expects reconstitution to a known state and evidence that the process works after failure or compromise, including dependencies like IAM, logging, and key management. ¹

How should we operationalize CP-10 if multiple teams own parts of recovery?

Assign a single CP-10 control owner, then document a RACI across IT ops, security/IR, and application owners with runbook handoffs. Use a central evidence workflow so tests and incidents produce consistent artifacts. ¹

Footnotes

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