IR-5: Incident Monitoring

To meet the ir-5: incident monitoring requirement, you must continuously track and document security incidents from detection through closure, so you can prove what happened, when you knew, what you did, and what you learned. Operationalize IR-5 by defining what counts as an incident, centralizing logging and case management, and retaining complete incident records as assessable evidence. ¹

Key takeaways:

• IR-5 expects a real incident record lifecycle: detection → triage → investigation → containment → recovery → closure, with documentation throughout. ¹
• Your fastest path to audit readiness is a single incident register plus standardized required fields and attachments. ¹
• Evidence matters as much as response: if you can’t produce incident tickets, timelines, and outcomes, IR-5 will fail in practice. ¹

IR-5 is a deceptively short requirement with a long operational shadow: “track and document incidents.” ¹ Assessors and internal auditors rarely accept informal narratives or scattered artifacts across chat, email, and point tools. They look for a consistent incident monitoring practice that produces repeatable evidence: when an incident was detected, who assessed it, what data informed decisions, what actions were taken, and how the organization closed the loop.

For a Compliance Officer, CCO, or GRC lead, the practical challenge is not picking a tool. The challenge is building a minimum viable incident documentation system that works across IT, Security, Legal/Privacy (when relevant), and third parties. Your goal is to make incident handling observable and defensible: a defined incident taxonomy, a centralized record (ticket/case), supporting telemetry or logs, and a closure discipline that captures root cause and corrective actions.

This page translates the ir-5: incident monitoring requirement into a requirement-level checklist you can assign, test, and evidence—without over-engineering.

Regulatory text

Requirement (excerpt): “Track and document incidents.” ¹

What the operator must do:
You need an operational process that (1) identifies and tracks incidents as formal records, and (2) documents each incident with enough detail to support response, reporting, lessons learned, and auditability. IR-5 is satisfied when you can demonstrate a consistent, repeatable practice that turns detections and reports into documented incident cases, then retains those records. ¹

Implementation anchor: Assign IR-5 to a control owner, document the procedure, and define recurring evidence artifacts you will retain and present during assessment. ¹

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Plain-English interpretation (what IR-5 really means)

IR-5 means your organization must maintain an incident record of truth. Every incident that meets your definition must be:

• Tracked: you can list incidents, status, owners, and timelines without hunting across systems.
• Documented: you can show the narrative and proof—alerts, logs, screenshots, forensic notes, actions taken, approvals, communications, and closure notes. ¹

In practice, IR-5 is where many programs fail “quietly.” The team may respond well operationally, but documentation is incomplete, inconsistent, or spread across tools with no single case file.

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Who it applies to (entity and operational context)

IR-5 is commonly applied in environments aligned to NIST SP 800-53, including:

• Federal information systems
• Contractor systems handling federal data ¹

Operationally, it applies wherever incidents can occur and must be managed:

• Security operations (SOC), IT operations, cloud operations
• Corporate systems and production environments
• Third-party connected systems and shared responsibility environments (for example, SaaS, managed services), where you still need to track and document what you observed and how you coordinated response

If you have multiple business units or subsidiaries, IR-5 usually becomes a federated execution problem: centralized standards and evidence requirements, distributed incident handling.

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

Use this as a build sheet you can assign to Security Ops and GRC.

1) Name the control owner and define governance

• Assign an IR-5 owner (often Head of SecOps or IR Lead) and a GRC evidence owner who can produce artifacts on request. ¹
• Define which teams can open/close incidents (Security, IT, Fraud, Privacy, Product).

Deliverable: IR-5 control statement with owner, in-scope systems, and evidence list. ¹

2) Define “incident” and severity levels for your environment

• Write a short incident definition that matches your operating reality (security events become incidents when they meet criteria).
• Define severity tiers with clear triggers (examples: confirmed malware, unauthorized access, data exposure, privileged credential misuse).

Practical test: Ask “If an alert fires at 2 AM, what makes it an incident vs noise?” If you can’t answer consistently, documentation will drift.

3) Centralize incident case management (one register)

You need a single place to track:

• Incident ID
• Open/closed status
• Severity
• Detection source (tool, user report, third party notification)
• Dates/times for key milestones
• Owner and responders
• Affected systems/data
• Containment and remediation actions
• Closure and lessons learned ¹

This can be a ticketing system, an IR platform, or a GRC workflow. The key is consistency and retrievability.

Daydream fit (earned): If your bottleneck is evidence consistency across teams and tools, Daydream can map IR-5 to a control owner, the implementation procedure, and the recurring evidence artifacts you’ll need each cycle, so incident records don’t become a scramble at audit time. ¹

4) Standardize required incident record fields (minimum viable schema)

Create an “IR-5 required fields” template and enforce it:

• Summary and scope (what happened, what’s impacted)
• Timeline (detection, triage, containment, recovery, closure)
• Indicators of compromise / observables (as applicable)
• Evidence attachments (alerts, logs, screenshots, forensic output)
• Decision log (why you escalated or de-escalated)
• Third-party involvement (who notified whom; tickets opened with provider)
• Corrective actions and follow-ups (what changed to prevent recurrence) ¹

Operator tip: Make missing fields block closure, or require an exception reason.

5) Connect monitoring to documentation (so cases are born from signals)

IR-5 does not require specific tooling, but you need a reliable path from detection to documentation:

• Alert triggers a case automatically, or
• Analyst opens a case and links the alert IDs/log references

What auditors want to see is traceability: “Show me the alert, then show me the incident record that tracked it.” ¹

6) Implement closure discipline (where IR-5 becomes defensible)

Define closure criteria:

• Root cause recorded (even if preliminary)
• Containment and eradication steps recorded
• Recovery verification recorded
• Lessons learned captured
• Required notifications assessed and documented (even if “not applicable”)
• Corrective actions ticketed and assigned owners/dates ¹

7) Run recurring QA on incident documentation

Put a lightweight review in place:

• Sample recent incidents
• Check required fields completeness
• Validate evidence attachments are present and accessible
• Confirm closure criteria met

This is how you prevent “paper compliance” and detect drift early.

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Required evidence and artifacts to retain

For assessment readiness, retain artifacts that show both tracking and documentation:

Core artifacts (expected in most audits)

• Incident response procedure that includes tracking/documentation steps ¹
• Incident register export (IDs, dates, severities, status, owners)
• Completed incident records (tickets/cases) with required fields populated
• Evidence attachments referenced in the incident (alerts, logs, screenshots, analyst notes)
• Post-incident reviews / lessons learned notes (when performed)

Governance and mapping artifacts (make audits faster)

• Control-to-owner mapping for IR-5
• Evidence matrix: what you collect, where it lives, who provides it, how often ¹

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Common exam/audit questions and hangups

Expect these questions, and prepare a clean “exam packet” with direct answers:

1. “Show me how you define an incident and how you decide severity.”
   Hangup: inconsistent definitions between SecOps and IT.

2. “Provide a list of incidents for the period and pick one to walk through end-to-end.”
   Hangup: missing timelines or missing attachments.

3. “How do you ensure incidents are tracked from detection through closure?”
   Hangup: detections exist in tools, but incidents are tracked in email/chat.

4. “How do you track third-party-originated incidents or notifications?”
   Hangup: the third party has a ticket, but you didn’t open your own internal record.

5. “Who owns IR-5 and who is accountable for evidence production?”
   Hangup: shared ownership with no accountable single owner. ¹

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Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails IR-5	What to do instead
Treating “alert volume” as incident tracking	Alerts are not curated incident records	Require a case/ticket for each incident and link alerts to it 1
Incidents documented in chat threads	Not durable, not searchable, not reviewable	Make the ticket the record; paste key decisions into the case
No minimum required fields	Incomplete narratives, weak timelines	Enforce a template and block closure if fields are missing
“We responded, trust us”	Audits grade evidence, not intent	Keep attachments and a timestamped timeline in the case 1
Third-party incidents handled informally	You still need your own record	Create an internal incident and attach third-party communications

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Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for IR-5. Your practical risk is still clear: weak incident tracking and documentation creates gaps in governance, delayed containment, inconsistent reporting, and poor audit outcomes against NIST-aligned requirements. ¹

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Practical 30/60/90-day execution plan

First 30 days (stabilize the minimum viable control)

• Assign IR-5 owner and evidence owner; publish the IR-5 control statement. ¹
• Define incident criteria and severity tiers; socialize with SecOps and IT.
• Stand up a single incident register (even a controlled workflow in your ticketing system).
• Create the required-fields template and closure checklist.

Days 31–60 (make it repeatable and testable)

• Connect detection sources to cases (manual linking is acceptable if consistent).
• Train responders on “ticket as record” expectations.
• Run a documentation QA on a sample of recent incidents; fix template gaps.
• Build an evidence matrix for IR-5 (owner, system of record, retention location). ¹

Days 61–90 (operational maturity and audit readiness)

• Add recurring reporting (incident trends, time-to-close, common causes) if it helps oversight; keep it evidence-backed.
• Conduct a tabletop or retrospective review focused on documentation quality (not response speed).
• Package an “IR-5 audit binder”: procedure, register export, and a few complete incident examples with attachments. ¹
• If evidence collection is fragmented, implement Daydream-style control mapping and artifact scheduling so IR-5 evidence is produced consistently across cycles. ¹

Frequently Asked Questions

Do we need a SIEM to meet the ir-5: incident monitoring requirement?

IR-5 does not mandate specific tools; it requires that you track and document incidents. If your current monitoring produces reliable detections and you consistently create documented incident cases, you can meet the requirement. ¹

What counts as “documented” for an incident?

A documented incident has a durable record with a timeline, scope, actions taken, and supporting evidence attachments or references. If you can’t reconstruct what happened and what you did from the case file alone, documentation is likely insufficient. ¹

How do we handle incidents that are fully contained by a third party (cloud/SaaS provider)?

Open an internal incident record anyway, document the notification, your internal impact assessment, actions you took, and closure rationale. Attach third-party communications and ticket references to your case. ¹

Can we sample incidents for evidence, or do we need to retain every record?

IR-5 is framed as “track and document incidents,” which implies maintaining incident records as a standard practice. For audits, you can often present a subset as examples, but your register should show that all incidents are tracked consistently. ¹

Who should own IR-5: Security, IT, or GRC?

Put operational ownership with the team running incident response (often Security Operations) and assign GRC as accountable for evidence readiness and control mapping. The key is a single accountable owner for the control and a clear evidence production path. ¹

What’s the fastest way to become audit-ready for IR-5?

Standardize required incident fields, enforce closure criteria, and produce a clean incident register export plus a few complete incident case files with attachments. Map IR-5 to an owner, procedure, and recurring evidence artifacts so the process stays consistent over time. ¹

Footnotes

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