CP-10(2): Transaction Recovery

CP-10(2) requires you to implement transaction recovery for any system where business events are recorded as transactions (for example, payments, orders, claims, trades, tickets). Operationally, you must be able to restore the system after a disruption to a known-good point and reconcile committed vs. uncommitted transactions so you do not lose, duplicate, or corrupt transactional records ¹.

Key takeaways:

• Scope CP-10(2) to transaction-based systems, then define what “committed” means and how to restore to a consistent state ¹.
• Build recovery around write-ahead logging, checkpointing, idempotency, and reconciliation controls that prove transaction integrity after restoration.
• Keep assessment-ready evidence: architecture diagrams, runbooks, recovery test results, reconciliation reports, and issue tickets tied to failures and remediation.

Transaction recovery is a continuity requirement with integrity teeth. Backups and system failover are not enough for transaction-based systems because you can “successfully” restore a server and still end up with missing payments, duplicated orders, or mismatched ledgers. CP-10(2) focuses on the ability to recover the transactional state of a system so the restored environment reflects an accurate, consistent record of what was committed before disruption and what must be rolled back or replayed ¹.

For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing CP-10(2) is to treat it as a targeted engineering-and-operations control: identify transaction-based systems, define transactional consistency requirements, implement specific technical mechanisms (logs, checkpoints, replay, reconciliation), then prove through testing and retained artifacts that recovery produces correct results. Your audit risk is less about whether you have a “DR plan” document and more about whether you can demonstrate repeatable recovery for real transactional workloads.

This page gives requirement-level implementation guidance you can hand to system owners and then assess with concrete evidence.

Regulatory text

Requirement: “Implement transaction recovery for systems that are transaction-based.” ¹

What the operator must do: For each transaction-based system, you must design and operate recovery procedures and supporting technical capabilities that restore the system to a consistent transactional state after an outage, corruption event, or failover. The control is satisfied when you can show (1) recovery methods exist, (2) they are implemented for in-scope systems, and (3) you can produce evidence that recovery works as intended for transactions, not just infrastructure ¹.

Plain-English interpretation (what CP-10(2) is really asking)

A transaction-based system records discrete business events that must be correct: “money moved,” “order placed,” “claim approved,” “trade executed,” “privilege granted,” “inventory decremented.” CP-10(2) expects you to recover in a way that preserves transaction integrity:

• No silent loss: A committed transaction must not disappear after recovery.
• No duplication: A transaction must not be applied twice because of replay or retry.
• No inconsistency: The system must not recover into a state where different components disagree about what happened.

If you cannot answer “How do we know which transactions were committed at the time of failure, and how do we reconcile after restore?” you are not operationalizing CP-10(2).

Who it applies to (entity and operational context)

Entities commonly scoped

• Federal information systems and contractors handling federal data where NIST SP 800-53 is the control baseline ².
• Regulated organizations adopting NIST SP 800-53 as a control framework for resilience and system integrity ².

Systems and environments

• Payment services, billing platforms, general ledger integrations, payroll.
• Order management, subscription provisioning, entitlement and licensing.
• Claims processing, case management, ticketing systems with financial or legal outcomes.
• Any platform using message queues/event streaming for business-critical workflows.
• Shared services that affect transactional state: identity platforms (for access grants), key management systems (for signing/encryption operations), and databases that are the system of record.

Third-party operational context If a third party runs part of your transactional flow (payment processor, managed database, SaaS order system), CP-10(2) still lands on you as the service owner. You need contractual and operational hooks (SLAs, recovery guarantees, logs, export capability, test evidence) to show transaction recovery works end-to-end.

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

Use this as a build-and-assess checklist.

1) Define “transaction-based” and inventory in-scope systems

• Build a list of applications where records represent discrete business events with correctness requirements (payments, orders, approvals).
• Identify dependencies that participate in committing a transaction: database, cache, queue, downstream posting service, external gateway.

Output: scoped system list + owners + data flows.

2) Define transaction boundaries and consistency rules per system

For each in-scope system, document:

• What counts as committed (database commit, double-write to ledger, acknowledgment from external processor).
• What counts as durable (written to log, replicated, checkpointed).
• What is acceptable after recovery: rollback vs replay vs compensating transactions.

Tip for operators: “Committed” must be observable in artifacts (logs, tables, message offsets). If it’s conceptual only, reconciliation becomes guesswork.

3) Implement technical recovery mechanisms aligned to the architecture

Pick the pattern(s) that match your stack:

Database-centric transactions

• Use database transaction logs / write-ahead logging and point-in-time recovery features.
• Ensure backups include log chains and restore procedures include applying logs to a consistent point.

Event-driven / message-based transactions

• Implement idempotency keys and deduplication at consumers.
• Persist message processing state so replay does not double-apply.
• Use outbox/inbox patterns where needed to prevent “DB commit but message lost” scenarios.

Distributed/microservice transactions

• Use sagas/compensating transactions where atomic commit across services is not feasible.
• Make compensations part of the recovery runbook, not tribal knowledge.

External gateways

• Ensure you can reconcile with external “source of truth” records (processor settlement files, provider APIs) and map them to internal transaction IDs.

4) Write an executable transaction recovery runbook

Your runbook should be specific enough for an on-call engineer to follow during a real incident:

• Trigger conditions (data corruption, region failover, partial outage).
• Step order: isolate writes, snapshot state, restore, replay/rollback, reconcile, reopen writes.
• Clear decision points: “If restore point is after checkpoint X, do Y; otherwise do Z.”
• Ownership and escalation: engineering, SRE/ops, security, business operations (finance/fulfillment).

5) Add post-recovery reconciliation and integrity checks

Transaction recovery is incomplete without proof of correctness. Minimum expectations in practice:

• Reconciliation report: list of transactions in the “uncertain window” around the failure, their final disposition (committed/rolled back/replayed/compensated).
• Data integrity checks: totals match, balances match, referential integrity holds, queue lag aligns with processed offsets.
• Exception handling: a queue/worklist for manual review when automated reconciliation cannot decide.

6) Test it and keep the evidence

Run recovery exercises that reflect real failure modes:

• Restore from backup/logs and validate transaction counts and totals.
• Replay messages and prove idempotency (no duplication).
• Simulate partial commit scenarios (DB commit succeeded, downstream publish failed) and show the system reaches a correct final state.

Record defects and remediation work. Auditors accept findings; they do not accept “we think it would work.”

Required evidence and artifacts to retain

Keep artifacts mapped per system (system-by-system evidence beats generic program evidence).

Design / configuration

• System architecture and data flow diagrams highlighting transaction commit points.
• Configuration evidence for backups/log retention, point-in-time recovery, replication settings.
• Idempotency/deduplication design notes and key schemas.

Procedures

• Transaction recovery runbook with step sequence and decision points.
• Incident response integration notes (who declares recovery mode, who approves reopening writes).

Operational proof

• Recovery test plans and results (including screenshots/log excerpts where helpful).
• Reconciliation reports from tests (and from real incidents when they occur).
• Tickets showing defects found, root cause, and closure evidence.

GRC mapping (assessment readiness)

• Control ownership assignment and an evidence cadence that matches how the system changes.
• If you use Daydream, store per-system control mappings, evidence requests, and recurring collection tasks so CP-10(2) stays current as architecture changes.

Common exam/audit questions and hangups

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

1. “Which systems are transaction-based, and why?”
   Hangup: teams scope too narrowly (only payments) and ignore order state, entitlements, or queues.

2. “Show me how you recover a transaction to a consistent state.”
   Hangup: documentation describes restoring servers, not reconciling committed/uncommitted transactions.

3. “How do you prevent duplicates during replay?”
   Hangup: retries exist, but no idempotency keys or dedup logic.

4. “What happened in your last incident or test?”
   Hangup: tests are ad hoc; results are not retained; lessons learned are not tracked to closure.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Treating CP-10(2) as a backup control.
  Fix: require a reconciliation step and evidence of correctness, not just restore success.

• Mistake: No defined commit point.
  Fix: document commit semantics per transaction type and where the system records durable state.

• Mistake: Relying on a third party’s generic DR statement.
  Fix: require transaction-level artifacts (logs/exports/reports) and a joint recovery procedure for the integration boundary.

• Mistake: Replays cause double posting.
  Fix: implement idempotency keys end-to-end, including at the boundary where external APIs are called.

Enforcement context and risk implications

No public enforcement cases were provided in the supplied source catalog for this requirement, so you should treat enforcement risk as indirect: CP-10(2) gaps surface after incidents as customer impact, financial misstatement risk, regulatory reporting errors, and material control failures. In audits, the most common failure mode is an inability to prove transactional correctness after recovery, even if infrastructure recovery is strong.

A practical 30/60/90-day execution plan

Use these phases as a way to execute quickly without inventing timelines that may not fit your environment.

First 30 days (triage and scoping)

• Identify transaction-based systems and rank by business criticality and transaction volume.
• Assign a control owner per system (engineering lead + GRC partner).
• For top systems, document commit points, dependencies, and failure scenarios.
• Gather existing runbooks, backup configs, and prior incident notes into a single evidence folder per system.

Days 31–60 (build the missing pieces)

• Create or rewrite transaction recovery runbooks with reconciliation steps and decision points.
• Implement or formalize idempotency, deduplication, checkpointing, and replay controls where gaps exist.
• Define reconciliation queries/reports and exception workflows (who reviews, how outcomes are recorded).
• Update third-party requirements for any external dependency needed to complete reconciliation.

Days 61–90 (prove operation and lock evidence)

• Execute recovery tests for each in-scope Tier 1 system; capture results and reconcile output.
• Log defects, remediate, and retest the specific failure mode.
• Package assessment-ready evidence: diagrams, runbooks, test results, reconciliation samples, ticket closures.
• Operationalize ongoing evidence collection in your GRC workflow (Daydream can track owners, evidence cadence, and collection status across systems without chasing screenshots in chat).

Frequently Asked Questions

What qualifies as a “transaction-based” system for CP-10(2)?

Any system where discrete events must be correct and traceable after recovery, such as payments, orders, claims, trades, or entitlement changes. If you need to reconcile “what happened” after an outage, treat it as transaction-based ¹.

Is a successful database restore enough to meet CP-10(2)?

Usually not. You also need transaction reconciliation to confirm committed transactions persisted and replays or retries did not duplicate outcomes ¹.

How do we handle transaction recovery when a third party processes part of the workflow?

Define the system-of-record for each transaction attribute, require export/reconciliation artifacts from the third party, and document the joint recovery procedure for the integration boundary. Keep evidence that you can match external records to internal transaction IDs.

What evidence do auditors ask for most often?

Runbooks that include transaction-level steps, recovery test results, and reconciliation outputs that show how you determined final transaction state. They also ask who owns the control and how often recovery is tested.

What’s the biggest technical control to prevent duplicate transactions during recovery?

Idempotency: a stable transaction identifier plus deduplication logic at every point a transaction can be replayed or retried, including consumers and external API calls.

How do we operationalize CP-10(2) across many teams without constant follow-up?

Standardize the minimum evidence pack per transaction-based system (diagram, runbook, test result, reconciliation sample) and track ownership and collection cadence in one place. Daydream helps by assigning owners, scheduling recurring evidence, and keeping the audit trail attached to the requirement.

Footnotes

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

2. NIST SP 800-53 Rev. 5