CP-10(1): Contingency Plan Testing

A written contingency plan is not enough to satisfy auditors, authorizing officials, or customer security teams. CP-10(1): contingency plan testing requirement is about proving, with evidence, that your recovery approach can be executed under realistic constraints: the right people can act, the runbooks are usable, the backups restore, and critical dependencies (identity, DNS, network paths, third-party services, facilities) don’t become single points of failure.

This requirement shows up in federal information systems and contractor environments handling federal data, and it often becomes a finding because teams confuse “we have a DR plan” with “we tested the plan end-to-end and fixed what broke.” Your goal is simple: make testing a governed control with a defined owner, a repeatable procedure, and recurring artifacts that demonstrate performance over time. ¹

If you want to operationalize quickly, treat CP-10(1) as an evidence production problem: decide what “testing” means for your environment, run an exercise that produces credible proof, and document corrective actions. Tools like Daydream help by mapping the requirement to a control owner and generating an evidence checklist you can execute every cycle without rebuilding the program. ²

Regulatory text

Provided excerpt: “NIST SP 800-53 control CP-10.1.” ²

Operator interpretation of the excerpt: CP-10(1): contingency plan testing requirement expects you to test the contingency plan, not just review it. Your testing must be planned, performed, and evidenced in a way that a third party (assessor, auditor, customer, AO) can validate: (1) what you tested, (2) how you tested it, (3) what happened, and (4) what you fixed afterward. ¹

Plain-English interpretation

You need a repeatable way to validate that your organization can execute its contingency plan for in-scope systems. That means:

• People know their roles and escalation paths.
• Procedures are actionable under stress (step order, prerequisites, access, tools).
• Recovery actions actually work (restore, failover, rebuild, communicate).
• Gaps become tracked corrective actions, not tribal knowledge.

Testing can include tabletop exercises, functional tests (restore a backup), technical failovers, or integrated exercises. The key is credibility: the test should meaningfully reduce uncertainty about your ability to recover. ¹

Who it applies to

Entity scope

• Federal information systems.
• Contractors and service providers operating systems that handle federal data (including hosted SaaS, managed services, and cloud workloads supporting federal missions). ¹

Operational context Apply CP-10(1) to:

• Production systems that support critical services or mission/business processes.
• Supporting systems whose failure blocks recovery (identity providers, secrets management, logging/monitoring, network routing, storage, CI/CD, ticketing/communications).
• Key third parties where dependency failure changes your recovery path (cloud provider services, managed database, incident response retainer, colocation/facilities, telecom).

A common scoping error is testing only one application runbook while ignoring the dependency chain required to execute the plan.

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

Use the steps below as a minimum operator playbook.

1) Assign ownership and define the “testable unit”

• Name a control owner (often BC/DR lead, SRE/IT ops manager, or GRC with ops co-owner).
• Define the testable unit(s): by system boundary, application tier, or service. Pick what aligns to your authorization boundary and how you report controls. ¹

Output: CP-10(1) control record with owner, in-scope systems/services, and test cadence expectation (document your internal standard even if the framework excerpt here does not specify frequency).

2) Build a CP-10(1) test plan that an assessor can follow

For each in-scope system/service, document:

• Scenario(s): ransomware recovery, region outage, database corruption, insider error, key staff unavailable.
• Assumptions and constraints: no admin console access, degraded network, limited staff, third-party outage.
• Success criteria: what “recovered” means (service reachable, data integrity checks pass, critical workflows run).
• Roles and communications: who declares contingency mode, who communicates internally/externally.
• Evidence to capture during the test: screenshots, logs, tickets, restore reports, bridge notes. ¹

Operator tip: Write success criteria in verification language (“can authenticate a standard user,” “can process a test transaction,” “restore completes and hash check matches”) rather than “system is back.”

3) Execute a test that proves more than a document review

Pick at least one meaningful method per system:

• Tabletop exercise: validates decisioning, roles, escalation, comms, and runbook usability.
• Functional restore test: restores from backup to a safe environment and validates integrity.
• Failover or rebuild test: proves infrastructure-as-code, automation, and access pathways work.

During execution:

• Use a ticket/bridge channel to capture timeline and decisions.
• Record deviations from the plan and why they happened.
• Capture artifacts as you go; don’t rely on memory after the fact. ¹

4) Write a results report that ties directly to the plan

Your test report should include:

• Date, scope, participants, and scenario.
• What steps were executed vs. skipped (and rationale).
• Observed gaps and risks (access failures, missing runbook steps, unclear ownership, third-party dependency issues).
• Whether success criteria were met.
• Corrective actions with owners and target completion dates (your internal targets; avoid presenting them as a framework mandate). ²

5) Track corrective actions to closure (this is where audits focus)

Create a remediation register (or use your GRC tool) and track:

• Finding/severity (internal rating is fine).
• Owner, due date, status, and evidence of fix.
• Retest requirement (some fixes need retesting to prove effectiveness).

If you stop at “lessons learned,” auditors will treat CP-10(1) as partially implemented because the control did not measurably improve resilience.

6) Operationalize as a recurring control (make evidence production routine)

• Add CP-10(1) testing to your annual compliance calendar (or your internal cadence).
• Maintain an evidence checklist by system and test type.
• Keep a consistent naming convention for artifacts (system, date, scenario).

Daydream fits here as the system of record: map CP-10(1) to the control owner, store the procedure, and define recurring evidence artifacts so each test cycle produces the same audit-ready package. ²

Required evidence and artifacts to retain

Keep artifacts in a controlled repository with access controls and retention aligned to your governance program:

Planning artifacts

• Contingency plan and runbooks (current approved versions).
• CP-10(1) test plan(s) with scope, scenario, success criteria, participant list. ¹

Execution artifacts

• Change tickets/approvals (if production-impacting).
• War room/bridge notes or incident channel export.
• Screenshots/log excerpts proving restore/failover steps executed.
• Backup/restore job reports and validation outputs. ¹

Results and remediation

• After-action report (AAR) / test results report.
• Corrective action plan (CAP) with owners and status.
• Evidence of remediation (updated runbook, access fixes, automation PRs, retest artifacts). ²

Common exam/audit questions and hangups

Expect these lines of questioning:

1. “Show me the last test and the results.”
   Auditors want the full chain: test plan → execution proof → results → remediation. Missing links create findings. ¹

2. “How did you choose scope and scenarios?”
   They look for rationale tied to critical services and credible failure modes, not convenience.

3. “Who participated, and were roles exercised?”
   If only GRC attended a tabletop, the test lacks operational validity.

4. “Did you test third-party dependencies?”
   If your recovery requires cloud IAM, a managed database, or a DNS provider, the test should include those assumptions and contingency steps.

5. “How do you ensure lessons learned are implemented?”
   A remediation tracker with closure evidence answers this cleanly. ²

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Treating a policy review as “testing”	Doesn’t prove recovery actions work	Run at least one exercise with observable outputs (restore validation, comms drill, failover rehearsal).
Testing one app while ignoring identity, network, and secrets	Recovery will stall on dependencies	Map dependency chain and include it in scope and success criteria.
No success criteria	You can’t show pass/fail	Define verification steps (logins, transactions, integrity checks).
Findings don’t become tracked work	Repeated audit findings	Put corrective actions in your ticketing/GRC workflow and require closure evidence.
Artifacts scattered across chat, email, and personal drives	Evidence gaps	Centralize in a controlled repository with naming standards.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat CP-10(1) primarily as an assessment and authorization risk: weak or unevidenced testing commonly results in control deficiencies, delayed authorizations, customer trust issues during due diligence, and higher operational impact when real outages occur. ¹

The practical risk is straightforward: a contingency plan that hasn’t been tested tends to fail at the worst time due to missing access, outdated contacts, unverified backups, and undocumented dependencies.

A practical 30/60/90-day execution plan

Use phases rather than fixed day commitments; the exact timeline depends on system complexity and change windows.

First 30 days (Immediate)

• Confirm in-scope systems and owners for CP-10(1).
• Collect current contingency plans/runbooks and identify gaps (missing steps, stale contacts, unclear RACI).
• Draft a test plan for the highest-criticality service with clear success criteria and evidence checklist.
• Set up a central evidence folder structure and artifact naming standard. ¹

Next 60 days (Near-term)

• Run one tabletop exercise for the highest-criticality service and produce an after-action report.
• Run one functional test (backup restore or equivalent) that generates technical evidence.
• Open corrective action tickets and assign owners; prioritize access, runbook, and dependency fixes. ¹

Next 90 days (Operationalize)

• Expand testing to remaining in-scope services using the same template.
• Establish a recurring test calendar and integrate it with change management.
• Perform a targeted retest for the highest-risk corrective actions.
• Implement a GRC evidence workflow in Daydream: control owner mapping, procedure, and recurring artifacts so the next audit package is one export, not a scramble. ²

Frequently Asked Questions

What counts as “testing” for CP-10(1): contingency plan testing requirement?

A test is an exercise that produces objective evidence that contingency procedures work (tabletop, restore test, failover rehearsal). A document review can support readiness, but by itself it rarely proves recoverability. ¹

Do I need to take production down to meet CP-10(1)?

No. Many teams meet the intent through controlled tabletop exercises plus non-production restore tests that validate backups and runbooks. If you do production testing, route it through change management and capture approvals. ¹

How should we scope CP-10(1) in a cloud/SaaS environment?

Scope by service boundary and include critical dependencies like IAM, DNS, CI/CD, secrets, and managed services that you need to recover. Document assumptions about the cloud provider and your contingency steps if those assumptions fail. ¹

What evidence do auditors usually reject?

“We talked about DR in a meeting” without a test plan, results write-up, and proof of what was executed. Auditors also reject tests without participant names/roles or without corrective action tracking. ²

How do we handle third-party dependencies during contingency plan tests?

Name the third party dependency, the failure mode you assume, and the workaround you will execute (alternate provider, manual process, recovery sequencing). If you cannot test the third party, test your side of the dependency and document the limitation. ¹

How does Daydream help with CP-10(1) operationalization?

Daydream helps you map CP-10(1) to a control owner, store the implementation procedure, and standardize recurring evidence artifacts so each test cycle produces consistent, audit-ready documentation. ²

Footnotes

1. NIST SP 800-53 Rev. 5

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