IR-2(1): Simulated Events

To meet the ir-2(1): simulated events requirement, you must add realistic incident simulations (tabletops, technical drills, and role-based scenarios) to your incident response training so staff practice their actions under pressure. Operationalize it by defining scenarios, roles, cadence, and success criteria, then documenting participation, outcomes, and corrective actions. ¹

Key takeaways:

• Simulations must be part of incident response training, not an ad hoc exercise. ¹
• You need evidence of execution: scenarios, attendance, results, gaps, and follow-up actions. ¹
• The fastest path to audit readiness is mapping ownership, procedure, and recurring artifacts to IR-2(1). ¹

IR-2(1): Simulated Events is a requirement-level expectation that your incident response training includes “simulated events” so personnel can perform required actions during crisis conditions. The point is operational: people should rehearse decisions, communications, escalations, and technical steps before a real incident forces them to do it live. ¹

For a Compliance Officer, CCO, or GRC lead, the win condition is simple and testable: you can show (1) your incident response training program includes simulations, (2) the right roles participate, (3) scenarios reflect your real risk profile and systems, and (4) issues discovered in the simulation are tracked through remediation and retest. ¹

This page is written so you can implement quickly: who owns it, how to structure simulations, what artifacts to retain, and what auditors ask when they test whether “simulated events” were meaningful or just a check-the-box tabletop.

Regulatory text

Requirement (verbatim): “Incorporate simulated events into incident response training to facilitate the required response by personnel in crisis situations.” ¹

Operator interpretation: Your incident response training must include practice incidents that mimic real conditions. “Simulated events” can be discussion-based (tabletop) or operational (functional drills, communications tests, technical recovery exercises), but they must require participants to perform their incident roles, not just listen to a presentation. ¹

What an assessor is looking for: proof that simulations are embedded in the training program, run repeatedly, involve the right people, and produce measurable outputs (findings, improvements, and role readiness) tied to your incident response capability. ¹

Plain-English interpretation (what this really means)

• You cannot rely on “annual IR awareness training” alone. You need practice incidents.
• The simulation must force real decisions: who declares an incident, who contacts legal, who engages third parties, who approves containment, who speaks externally, who restores systems.
• The deliverable is operational readiness: people know what to do and can do it under time pressure.

Who it applies to

Entity types: This requirement is commonly applied to federal information systems and contractor systems handling federal data. ¹

Operational contexts where it matters most:

• Organizations with a formal incident response plan and on-call or escalation paths.
• Hybrid teams where IT, Security, Legal, Privacy, HR, Communications, and business owners must coordinate quickly.
• Environments dependent on third parties (cloud, MSSPs, SaaS, forensics firms), where coordination is a frequent failure point.

Roles typically in scope:

• Incident commander / IR manager
• SOC analysts / detection engineers
• IT operations and infrastructure
• Application owners
• Identity and access management
• Legal / Privacy (where applicable)
• Communications / PR
• Executive decision-makers for risk acceptance and business interruption decisions
• Key third parties (at least as “participants” or observers) when contracts or service dependencies affect response steps

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

1) Assign control ownership and define the “done” state

• Name a primary owner (often IR lead or Security GRC) and a compliance approver (CCO/GRC lead).
• Define completion criteria: simulations occur as part of IR training, participation matches role scope, and findings are remediated with tracked closure. ¹

Practical tip: Put ownership, procedure, and recurring artifacts in one place (control narrative + evidence map). This aligns with the recommended best practice to map IR-2(1) to a control owner, implementation procedure, and recurring evidence artifacts. ¹

2) Build a simulation catalog tied to your incident types

Create a small set of repeatable scenarios that reflect your environment. Examples:

• Ransomware affecting a critical server tier
• Compromised admin credentials and lateral movement
• Third party SaaS breach affecting your tenant
• Lost/stolen endpoint with regulated data
• Major DDoS or availability incident

For each scenario, document:

• Trigger and initial signals (alerts, user reports, third party notice)
• Roles involved
• Required decisions and approvals
• Key communications (internal, executives, third parties)
• Minimum technical actions (containment, evidence preservation, recovery sequencing)

3) Choose simulation formats that match maturity

Use a mix:

• Tabletop simulation: validates roles, decision-making, escalation, and comms.
• Functional drill: tests a slice of the process, such as paging/on-call, war-room setup, or third party engagement.
• Technical simulation: tests tooling and execution, such as isolating hosts, rotating credentials, restoring from backup, or log retention access.

Match format to risk. High-impact systems merit deeper drills.

4) Define success criteria and injects

Before the exercise:

• Define what “good” looks like (for example: correct escalation path followed, evidence preserved, communications approved through the right chain).
• Prepare “injects” to force decisions (e.g., new indicator of compromise, executive asks for ETA, customer support reports inbound complaints, third party requests artifacts).

During the exercise:

• Capture timestamps for key decisions and handoffs (qualitative timing is fine; you are proving you ran the simulation and learned from it). ¹

5) Run the simulation like an incident, then hold a tight after-action review

Execution expectations:

• Assign an exercise facilitator and a scribe.
• Record attendance and roles.
• Keep a decision log (what was decided, by whom, based on what inputs).
• Track gaps as actions with owners and due dates.

After-action review output:

• What worked
• What failed (process gaps, tooling gaps, unclear authority, missing contacts, third party bottlenecks)
• Action plan and retest plan (at least for critical gaps)

6) Close the loop: remediation and evidence packaging

Auditors often fail teams on “we did a tabletop” when there is no proof that outcomes improved readiness. You need:

• Ticketed remediation items (process updates, runbook changes, contact list fixes, access changes)
• A link from exercise findings to updated documentation
• Proof of completion (tickets closed, updated runbooks approved, new training delivered)

Where Daydream fits naturally: Daydream can track IR-2(1) as a requirement with an assigned owner, store the procedure and scenario catalog, and automate recurring evidence collection (agendas, attendance, after-action reports, and remediation tickets) so you do not rebuild the audit binder each cycle.

Required evidence and artifacts to retain

Keep artifacts that prove design and operation:

Program design

• Incident response training plan showing simulations are included ¹
• Simulation catalog with scenario briefs and role maps
• Exercise procedure (facilitation steps, documentation expectations)

Per-simulation execution

• Agenda and scenario brief
• Attendance roster with names, roles, and teams
• Exercise notes: decision log, injects used, communications drafted
• After-action report with findings and recommendations
• Corrective action plan with owners and due dates
• Evidence of follow-through: tickets, updated runbooks, updated call tree, revised escalation criteria ¹

Third party evidence (if involved)

• Contracts/SLAs or contact paths used during drills
• Email trails or meeting notes showing third party participation
• Any joint lessons learned that affected response steps

Common exam/audit questions and hangups

Auditors commonly ask:

1. Show me where simulated events are required in your IR training program. They want a document trail, not verbal assurance. ¹
2. Which roles participated, and how do you know the right people attended? Attendance by name and role is the usual hangup.
3. How do scenarios reflect your environment? Generic ransomware slides are weaker than a scenario tied to your actual systems and third-party dependencies.
4. What changed because of the simulation? If you cannot show remediation, the exercise looks performative. ¹
5. How do you handle turnover? You need a way to ensure new on-call staff get simulation exposure.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails IR-2(1)	Fix
Treating phishing simulations as the only “simulated event”	IR-2(1) is incident response training; awareness testing alone does not exercise IR roles	Add at least one IR scenario that tests escalation, containment decisions, and communications 1
No artifacts beyond a calendar invite	You cannot prove the simulation occurred or who participated	Standardize an exercise packet: brief, roster, notes, after-action report
Findings not tracked to closure	Shows no operational improvement	Convert findings into tickets with owners; review closure in security governance meetings
Scenarios do not include third-party dependencies	Real incidents often hinge on cloud/SaaS/MSSP coordination	Add injects requiring third-party engagement, contract review, or evidence requests
Only security attends	IR is cross-functional	Require participation from IT ops, app owners, Legal/Privacy/Comms as appropriate

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat IR-2(1) primarily as an assessment and mission-risk issue rather than a penalty-citation issue. The operational risk is straightforward: teams that do not rehearse incident decisions often lose time on basic coordination (authority, communications, evidence handling), which can increase business disruption and complicate post-incident reporting and assurance efforts. ²

Practical 30/60/90-day execution plan

First 30 days (stand up and schedule)

• Assign owner and approver for IR-2(1); document the procedure and required artifacts. ¹
• Build an initial scenario catalog with at least one scenario that stresses cross-functional decision-making.
• Create templates: scenario brief, attendance sheet, decision log, after-action report, corrective action tracker.
• Schedule the first simulation and pre-brief participants on expectations.

Next 60 days (run, learn, remediate)

• Run the simulation; capture attendance, decisions, and outputs.
• Hold an after-action review within a short window while details are fresh.
• Open remediation tickets for every material gap; assign owners.
• Update IR plan/runbooks and contact lists based on findings. ¹

By 90 days (prove closure and make it repeatable)

• Verify remediation closure for the highest-risk findings; keep evidence.
• Run a targeted drill that retests one or two corrected weaknesses (e.g., paging tree, third-party engagement, credential rotation procedure). ¹
• Package evidence into an “IR-2(1) binder” format: narrative + last simulation packet + remediation proof.
• Put simulations on a recurring governance calendar and ensure new team members are routed into the next exercise cycle.

Frequently Asked Questions

Do tabletop exercises count as “simulated events” for IR-2(1)?

Tabletop exercises can count if they are part of incident response training and require participants to perform their crisis roles through a realistic scenario. Keep the scenario brief, attendance, and after-action report as evidence. ¹

How technical does the simulation need to be?

NIST requires simulated events be incorporated into training; it does not mandate a specific technical depth in the excerpt provided. Choose depth based on your risk: add functional or technical drills for critical systems where “talking through it” has repeatedly failed in practice. ¹

Which teams must participate to satisfy auditors?

Include personnel who have required actions during an incident: IR leadership, security operations, IT operations, and system owners at a minimum, plus Legal/Privacy/Comms when their approvals or communications are part of your process. Prove participation with a role-based roster. ¹

What evidence is most persuasive in an assessment?

A complete exercise packet: scenario brief, roster, decision log, after-action report, and a corrective action tracker that shows closure. Assessors want to see learning converted into process or capability changes. ¹

How do we handle third parties during simulations?

If third parties are part of real incident execution (cloud, MSSP, forensics, SaaS), include them in at least some scenarios or injects. Retain contact paths used, meeting notes, and any joint actions that resulted from the drill. ¹

We already do security awareness phishing tests. Can we map that to IR-2(1)?

Phishing tests support awareness, but IR-2(1) is about incident response training with simulated events to facilitate required response actions under crisis conditions. Keep phishing tests separate, and add IR scenarios that exercise escalation, containment decisions, and coordination. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5