CP-10(5): Failover Capability

CP-10(5): Failover Capability requires you to engineer and operate a proven failover capability for designated systems so mission/business functions can continue during a disruption. To operationalize it fast, define which services require failover, implement a secondary capability (site/region/system), test real failover, and retain repeatable evidence that it works. ¹

Key takeaways:

• Scope first: identify the specific services and dependencies that must fail over, and document the criteria that triggers failover. ¹
• Build for execution: implement technical runbooks, roles, and access so failover can occur under stress without ad-hoc approvals. ¹
• Prove it continuously: run failover tests and keep artifacts that show results, remediation, and sustained readiness. ¹

The cp-10(5): failover capability requirement is an operational control, not a policy exercise. Auditors and authorizing officials look for evidence that you can shift processing to an alternate capability when a component, site, or primary hosting environment becomes unavailable, and that the organization can do it on purpose, on time, and without improvisation. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path is to translate CP-10(5) into three things operators can execute: (1) a clear scope of “what must fail over” mapped to mission/business functions, (2) an implemented failover design with assigned roles and access, and (3) a recurring test and evidence cadence that proves the failover path works end-to-end, including critical dependencies like identity, DNS, secrets, and data replication. ¹

This page gives requirement-level implementation guidance you can hand to infrastructure, application, and service owners. It emphasizes what to build, what to test, and what artifacts to retain so CP-10(5) can be assessed without debate.

Regulatory text

Regulatory excerpt: “NIST SP 800-53 control CP-10.5.” ²

Operator interpretation: CP-10(5) is the “Failover Capability” enhancement to CP-10 (System Recovery and Reconstitution). Practically, you must have a working, repeatable method to fail over designated systems from primary to alternate capability during disruptions, and you must be able to demonstrate that capability through operational evidence. ¹

What an operator must do:

• Define which systems/services require failover, and under what conditions failover is invoked. ¹
• Implement the alternate capability (technology + procedures + access) to support failover. ¹
• Test failover and retain evidence that the organization can execute it and recover service in alignment with continuity expectations. ¹

Plain-English interpretation (what the requirement really asks)

Failover capability means you can switch service operation to a standby/alternate environment when the primary environment is degraded or down, and you can do so in a controlled way that protects security and data integrity.

A good CP-10(5) implementation answers four questions clearly:

1. Fail over what? The specific services, components, and dependencies that must continue.
2. Fail over to where? The alternate site/region/system and how it stays ready.
3. Fail over how? The exact technical steps, automation, approvals, and access needed.
4. Fail over with what proof? Test records, logs, tickets, and after-action results.

Who it applies to

Entity types: Federal information systems and contractor systems handling federal data. ²

Operational context where CP-10(5) is typically assessed:

• Systems supporting mission/business processes where unavailability materially impacts delivery, safety, finances, or regulatory commitments. ¹
• Moderate/high impact systems, shared services (identity, logging, network), and customer-facing platforms with explicit availability objectives. ¹
• Environments using third parties for hosting, managed databases, DNS, identity, incident response, or critical SaaS integrations; their resilience becomes part of your failover story. Use “third party” in scope even if the technical design is “cloud-native.” ¹

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

Step 1: Set scope and ownership (make it assessable)

• Inventory in-scope services: identify systems/components that require failover. Tie each to a business function and system boundary.
• Assign a control owner: name the accountable role (often the service owner or infrastructure lead) and a GRC point of contact for evidence coordination.
• Define failover triggers: document what conditions initiate failover (monitoring thresholds, site outage, loss of dependency, security event requiring isolation).
• Define success criteria: what “service restored via failover” means (user impact, data currency, authentication working, audit logging active).

Deliverable: a one-page “CP-10(5) Failover Scope & Ownership” register.

Step 2: Design the failover architecture (and document decisions)

Pick a failover pattern per service; mix patterns across your stack.

• Active/active (two environments serve traffic) for high-availability services.
• Active/passive (warm standby) where cost or complexity prevents active/active.
• Cold standby for less critical services, but ensure it still meets continuity expectations.

For each service, document:

• Traffic steering: DNS failover, load balancer switch, routing policies.
• State management: database replication approach, replication lag handling, backup restore path if replication fails.
• Identity and access: ensure authentication/authorization works in the alternate environment; pre-stage break-glass access.
• Secrets and keys: how secrets are available post-failover; how key management survives regional/site failure.
• Observability: logging/monitoring must remain intact after failover, including security telemetry.

Deliverable: “Failover Design Decision Record” per service and a dependency map.

Step 3: Build the runbooks and automation (humans must be able to execute)

• Write a failover runbook with exact commands/console steps, ownership per step, and rollback steps.
• Pre-provision required access in the alternate environment; avoid “we’ll request access during the outage.”
• Automate where safe: infrastructure-as-code for standby, scripted cutover for routing, automated health checks.
• Add a communications plan: internal escalation and external stakeholder notifications tied to failover events.

Deliverable: approved runbooks stored in a controlled repository, plus access/control records.

Step 4: Test failover like you mean it (tabletop + technical)

Run two kinds of exercises:

• Tabletop exercise: validate decision-making, roles, escalation paths, and whether the trigger criteria are understood.
• Technical failover test: shift traffic/processing to the alternate capability and validate end-to-end function, including security controls.

Minimum test assertions to capture:

• Service is reachable and functional after failover.
• Data integrity checks pass (no unexpected loss/corruption).
• Authentication works; least privilege is maintained.
• Audit logs and monitoring continue without gaps you can’t explain.

Deliverable: a test report with evidence (logs, screenshots, change records) and a remediation plan for failures.

Step 5: Operationalize recurrence (make it continuous, not episodic)

• Put failover tests on an operations calendar aligned to release cycles and major architecture changes.
• Require a failover readiness review for material changes (new region, new managed service, new third party dependency).
• Track open issues as problems with owners and due dates; auditors will ask whether failed tests were fixed.

Deliverable: recurring test schedule, issue tracker entries, and closure evidence.

Required evidence and artifacts to retain

Use an evidence pack that an assessor can review quickly:

Evidence artifact	What it proves	Typical source
Failover scope register	Which services are in scope and who owns them	GRC system, CMDB
Architecture diagrams + dependency map	Alternate capability exists and dependencies are known	Architecture repo
Failover runbooks + rollback steps	Procedures exist and are actionable	Ops wiki, Git
Access list / break-glass procedure	Staff can execute failover under stress	IAM system, tickets
Test plans + test results	Failover was executed and validated	Change records, test reports
Monitoring/logging screenshots or exports	Telemetry survives failover	SIEM/APM exports
After-action reviews + remediation tickets	Issues are managed to closure	ITSM tool

If you use Daydream to manage control operations, map CP-10(5) to a named control owner, implementation procedure, and recurring evidence artifacts so the evidence pack assembles cleanly each cycle. ²

Common exam/audit questions and hangups

Expect these questions from assessors or internal audit:

• “Show me which systems are required to fail over, and why those are the ones you chose.”
• “Walk me through the last failover test. Who approved it? What changed? What failed?”
• “How do you know your dependencies will work in the alternate environment (DNS, identity, third-party APIs, key management)?”
• “Where is the runbook, and who is trained to run it?”
• “What evidence shows this is repeatable and current after recent system changes?”

Common hangups:

• Vague scope (“all critical systems”) with no mapping to actual services.
• Testing that doesn’t move real workload (a “backup restored in isolation” story presented as failover).
• Dependency blindness (identity works only in primary region; logging disabled in DR).

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Treating backups as failover.
   Fix: document both backup/restore and failover paths; prove traffic/processing can move to the alternate capability.

2. Mistake: Runbooks that assume perfect conditions.
   Fix: include “what if X is down” branches, and pre-stage credentials and tooling.

3. Mistake: Failing over the app but not the security controls.
   Fix: validate logging, alerting, and access controls after failover; capture evidence.

4. Mistake: Third-party dependencies ignored.
   Fix: identify third parties that can break failover (DNS provider, IdP, managed database, CDN). Document mitigations and contractual expectations where appropriate.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for CP-10(5). ²

Operational risk still matters. Weak failover capability increases the likelihood that an incident becomes a prolonged outage, and it can turn a contained event (like a regional cloud issue) into broader business interruption. Assessors often treat “no evidence of failover testing” as a control failure because it implies the capability is unproven.

Practical 30/60/90-day execution plan

First 30 days (foundation)

• Define in-scope services and name owners.
• Document failover triggers and success criteria per service.
• Create or update architecture diagrams and dependency maps for in-scope services.
• Draft runbooks and validate access (including break-glass).

By 60 days (build and prove once)

• Implement missing pieces in the alternate capability (routing, replication, IAM, secrets).
• Run tabletops for top services, then execute at least one technical failover test for a representative critical service.
• Open remediation items for test failures and assign owners.

By 90 days (make it repeatable)

• Expand technical testing across remaining in-scope services based on criticality.
• Integrate failover readiness checks into change management for material releases.
• Assemble a CP-10(5) evidence pack in a single location (GRC repository or Daydream) with version control and clear timestamps.

Frequently Asked Questions

Does CP-10(5) require a second data center or second cloud region?

CP-10(5) requires an alternate capability that can take over processing; the form depends on your risk and system design. Document what you chose and keep test evidence that failover works. ¹

Can we meet CP-10(5) with backups and manual restore procedures?

Backups support recovery, but CP-10(5) is assessed as failover capability. If your approach is restore-based, be explicit and prove it meets the organization’s continuity expectations through realistic tests and runbooks. ¹

How do auditors typically verify failover capability?

They ask for documented design, runbooks, and test results that show you switched to the alternate capability and validated service, identity, and logging. Weak or missing evidence is a common failure point. ¹

What systems should be in scope first?

Start with systems that support mission/business functions and shared dependencies that can block recovery, such as identity, DNS, networking, and logging. Then expand by criticality and dependency impact. ¹

How do we handle third-party services in a failover plan?

Treat third parties as dependencies with failure modes. Document what breaks if the third party is unavailable, what your workaround is (alternate provider, cached mode, degraded operations), and how you test that behavior. ¹

What’s the cleanest way to stay audit-ready on CP-10(5)?

Assign a control owner, maintain a recurring test cadence, and store artifacts in a single evidence pack. Tools like Daydream help keep the mapping from requirement to procedure to evidence consistent across teams. ²

Footnotes

1. NIST SP 800-53 Rev. 5

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