IR-6(3): Supply Chain Coordination

The ir-6(3): supply chain coordination requirement forces one practical outcome: during an incident, you cannot keep supply-chain stakeholders in the dark if their product or service is implicated. That includes the original provider and other organizations involved in the supply chain or supply chain governance for the affected system or component.

For a CCO, GRC lead, or compliance officer, the hard part is rarely understanding the sentence. The hard part is executing it under pressure without oversharing, breaching contractual restrictions, or missing a critical party (like a managed service provider, cloud marketplace operator, integrator, or upstream component maintainer). The control lives at the intersection of incident response, third-party risk management, legal, procurement, and security engineering.

This page gives requirement-level implementation guidance you can put into an incident response plan and a third-party governance workflow. It focuses on defining notification scope, building the mechanics of sharing, and retaining audit-ready evidence that shows the coordination happened, was timely for your environment, and was appropriate for the incident.

Regulatory text

Requirement (excerpt): “Provide incident information to the provider of the product or service and other organizations involved in the supply chain or supply chain governance for systems or system components related to the incident.” ¹

Operator meaning: If an incident involves a system or component that depends on a third party product/service (or sits inside a broader supply chain), you must (1) identify the relevant supply-chain entities and (2) share incident information with them. Your process must be defined before the incident and executable during the incident. ²

Plain-English interpretation

You need a disciplined way to answer four questions quickly during incident response:

1. Which product/service or component is implicated?
2. Who in the supply chain needs to know? (Provider plus other supply chain/supply chain governance organizations.)
3. What incident information is appropriate to share? Enough to support containment, root-cause analysis, and prevention, without disclosing unnecessary sensitive data.
4. How will you share it securely and prove you did?

This control is not satisfied by “we’ll notify vendors if needed.” Auditors look for a defined trigger, a list of parties (or a repeatable method to derive the list), content standards, secure channels, and evidence.

Who it applies to

Entities: Organizations implementing NIST SP 800-53 controls, including federal information systems and contractors handling federal data. ²

Operational context where it shows up most:

• Cloud services and managed services where the third party operates part of your environment.
• Software supply chains (commercial software, open-source dependencies maintained by third parties, marketplace add-ons).
• Hardware/firmware components (network appliances, endpoint agents) supported by an OEM or reseller channel.
• Shared governance environments (multi-tenant platforms, joint ventures, programs with coordinating bodies).

Inside your org, the control touches:

• Incident Response (IR) lead / SOC
• Third-party risk management (TPRM) and procurement
• Legal (privilege strategy, contractual notice language)
• Privacy (if personal data may be included)
• IT owners for affected systems/components

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

1) Predefine “supply chain parties” for each critical system/component

Build a mapping that links:

• System/component → product/service provider(s)
• Provider → support contacts and escalation paths (security, incident desk, account team)
• Other supply chain organizations (examples: integrator, hosting provider, marketplace operator, key subcontractor operating the service, or a program governance body)

Practical output: a “Supply Chain Incident Notification Matrix” owned by IR with TPRM/procurement inputs.

Tip: Keep it derivation-based. If the list is too static, it will rot. Use procurement records, CMDB, and contract repositories to populate it.

2) Define notification triggers tied to incident classification

Write explicit triggers into the incident response plan/runbooks. Common trigger patterns:

• Incident involves a third-party product/service (suspected exploit, outage, compromise, misconfiguration).
• Incident involves a component that is maintained by a third party (e.g., patch channel, managed detection agent).
• Incident indicators suggest upstream compromise (supply chain tampering, poisoned updates, suspicious signing, unexpected outbound traffic to vendor-controlled endpoints).

Decision rule format (auditor-friendly):

• If a third party product/service is in the causal chain or materially impacted, then notify provider and relevant supply chain governance parties per matrix.

3) Standardize “what to share” (and what not to share)

Create a tiered incident information package so responders don’t improvise:

Minimum share set (almost always appropriate):

• Affected product/service/component name and version/build details
• Incident timeline (first observed, containment actions taken)
• Observable indicators (IPs, domains, hashes, user agents, log excerpts)
• Suspected attack vector and impacted functions
• Requested actions from the provider (confirm known issue, provide mitigations, validate integrity of updates)

Conditional share set (requires approvals):

• Customer data elements, personal data, regulated data
• Internal architecture diagrams, secrets, or proprietary detection logic
• Forensic images or raw logs containing sensitive content

Route conditional sharing through legal/privacy approval paths you predefine.

4) Implement secure sharing channels and chain-of-custody habits

You need a secure method to send incident data to third parties. Pick one or more:

• Provider security portal (ticketing) with MFA
• Encrypted email to verified security contacts
• Secure file transfer with access controls and expiry
• Coordinated call bridge plus written follow-up

Add a verification step: confirm you are sending to an authenticated recipient, not an impersonator during a chaotic incident.

5) Execute coordination during the incident, not after

During active response:

• Notify the provider early with the minimum share set.
• Track responses, guidance received, and actions taken.
• If other supply chain/governance organizations exist, repeat the same structured approach.

Operationally, the goal is two-way coordination: you provide actionable details; they provide mitigations, confirmations, or broader-scoped indicators.

6) Close the loop post-incident and feed lessons back into TPRM

After containment and recovery:

• Document what you shared, when, with whom, and why.
• Update the notification matrix based on what worked or failed.
• Feed provider performance into third-party risk records (e.g., responsiveness, quality of mitigations, clarity of communications).

Where Daydream fits naturally: Daydream can serve as the system of record to map ir-6(3): supply chain coordination requirement to a named control owner, a concrete procedure, and recurring evidence artifacts, so your audit package is assembled continuously instead of rebuilt during an assessment.

Required evidence and artifacts to retain

Auditors typically want proof of design (your defined process) and proof of operation (you executed it).

Design artifacts

• Incident Response Plan section addressing supply chain notifications
• Supply Chain Incident Notification Matrix (system/component → parties → contacts → method)
• Standard incident sharing templates (minimum vs conditional data sets)
• Secure transmission procedure (including recipient verification)

Operational artifacts ¹

• Timestamped notifications (tickets, emails, portal submissions)
• Content shared (indicator package, summary notes, attachments list)
• Records of provider responses and guidance
• Decision log explaining why certain parties were notified or not notified
• Post-incident report section documenting supply chain coordination outcomes

Retention note: Align retention to your broader incident record retention standard; consistency is what examiners reward.

Common exam/audit questions and hangups

1. “Show me how you determine which supply chain organizations must be notified.”
   Hangup: teams rely on memory. Fix: matrix + derivation method from CMDB/contracts.

2. “Show evidence from a recent incident where you notified the provider.”
   Hangup: only verbal calls occurred. Fix: written follow-up and ticket exports.

3. “What incident information do you share, and who approves sensitive sharing?”
   Hangup: no pre-approved content boundaries. Fix: tiered share sets + approval workflow.

4. “How do you ensure the notification goes to the right party securely?”
   Hangup: responders email whoever answers. Fix: verified contacts and secure channels.

Frequent implementation mistakes and how to avoid them

• Mistake: Treating this as optional vendor courtesy.
  Avoid it by writing a mandatory trigger and linking it to incident severity/classification rules.

• Mistake: Only notifying the direct vendor, ignoring the rest of the supply chain.
  Avoid it by defining “other organizations involved in the supply chain or supply chain governance” for your environment and encoding them in the matrix. ¹

• Mistake: Oversharing sensitive data in the first message.
  Avoid it with a minimum share set and a gated conditional share set requiring approval.

• Mistake: No evidence package.
  Avoid it by requiring the incident commander to attach notification artifacts to the incident record before closure.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite specific enforcement outcomes.

Risk-wise, failure modes are predictable:

• Containment risk: providers cannot help if they do not receive indicators and timelines.
• Propagation risk: upstream issues persist and impact other components if coordination is late or incomplete.
• Assessment risk: you may fail an audit because you cannot prove coordination occurred, even if the response team “did the right thing” informally.

A practical 30/60/90-day execution plan

First 30 days (foundation)

• Assign a single control owner (IR leader) and named supporting owners (TPRM, procurement, legal).
• Draft the Supply Chain Incident Notification Matrix for the most critical systems/components.
• Create an incident notification template with the minimum share set and approval notes for conditional sharing.
• Add a supply-chain notification step to the incident closure checklist (evidence requirement).

Days 31–60 (operationalize)

• Validate contact paths with top third parties (security contact, portal access, escalation).
• Run a tabletop scenario that forces a vendor/product notification and capture the evidence artifacts you expect to retain.
• Add a short decision tree to IR runbooks: “Is a third party product/service involved?” and “Are other supply chain governance parties implicated?”

Days 61–90 (scale and prove)

• Expand the matrix coverage to remaining in-scope systems/components.
• Implement periodic checks for drift (contracts renewed, contacts changed, new providers introduced).
• Build an assessment-ready evidence pack format (design artifacts + last incident examples + tabletop results).
• If you use Daydream, map the requirement to the owner, procedure, and recurring evidence requests so the control stays testable.

Frequently Asked Questions

Does IR-6(3) require notifying every vendor involved with a system?

No. It requires providing incident information to the provider of the product or service and other organizations involved in the supply chain or supply chain governance that relate to the incident. Scope notifications to parties connected to the affected system/component and the incident’s causal chain. ¹

What counts as “incident information” for sharing?

Share enough detail to enable action: affected component details, timeline, observable indicators, and what you need the provider to do. Treat sensitive data (regulated data, secrets, privileged forensic material) as conditional and gate it through approvals.

How do we handle contractual restrictions or NDA concerns during an incident?

Pre-negotiate incident cooperation clauses and approved sharing channels in third-party contracts where possible. During response, default to the minimum share set and escalate conditional sharing decisions through legal.

Do we need to notify upstream open-source maintainers?

If your governance model includes established channels to upstream maintainers and the incident relates to that component, coordination can be appropriate. Operationally, many teams route this through the commercial provider, integrator, or a program governance body to avoid unmanaged disclosure.

What evidence is “enough” for an auditor?

Keep the notification record (timestamp, recipient, method), the content summary or attachment list, and the provider’s response. Also retain the decision log explaining who was notified and why, tied to the affected system/component.

We had an incident but didn’t notify the provider. Are we automatically noncompliant?

If the incident involved a system/component related to a provider or supply chain party and you did not share incident information, expect an audit gap unless you can document a defensible determination that no supply chain coordination was applicable. Write those decision criteria into the runbook so the determination is consistent.

Footnotes

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

2. NIST SP 800-53 Rev. 5