IR-8: Incident Response Plan

To meet the ir-8: incident response plan requirement, you must have a written, approved incident response plan that your teams can execute under stress, and you must be able to prove it’s current, communicated, and aligned to your system and mission needs ¹. Operationalize this by assigning ownership, defining incident phases and decision points, integrating third-party and legal notification paths, and retaining evidence of testing and updates ².

Key takeaways:

• You need a documented, approved incident response plan that is actionable, not a slide deck ¹.
• Evidence matters as much as the plan; retain approvals, versioning, training, and exercise outputs ².
• Tie the plan to real operations: on-call, tooling, communications, third-party coordination, and post-incident lessons learned ¹.

IR-8 is the control that turns “we respond to incidents” into an auditable capability: a plan, owned by named roles, that can be executed consistently and improved over time ¹. For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing IR-8 is to treat the incident response plan as a governed product with clear inputs (system scope, threat scenarios, reporting obligations, third-party dependencies) and repeatable outputs (playbooks, contact trees, exercise records, after-action items, and revisions) ².

Auditors and assessors rarely fail teams for lacking intent. They fail teams for gaps between the document and reality: a plan that doesn’t match the current environment, a response team that cannot show how they would escalate, or missing evidence that the plan is reviewed and practiced ¹. This page gives requirement-level guidance you can implement quickly: who it applies to, what to build, how to run it, and what artifacts to retain to satisfy IR-8 with minimal rework.

Requirement: IR-8 Incident Response Plan (NIST SP 800-53 Rev. 5)

IR-8 requires you to develop an incident response plan as part of your incident response capability ¹. In practice, “develop” means the plan exists in a controlled form (versioned, approved), is tailored to your environment, and is usable by responders and leadership during a real incident ².

Plain-English interpretation

You need a single source of truth that answers, without guesswork:

• What counts as an incident for your system(s) and data?
• Who does what, and who can approve high-impact decisions?
• How you detect, analyze, contain, eradicate, and recover.
• How you communicate internally and externally, including with third parties.
• How you learn from incidents and update the plan ¹.

If your plan cannot drive coordinated action across Security, IT Ops, Legal, Privacy, HR, Comms, and affected business owners, it will not hold up in an assessment or a real event ¹.

Regulatory text

Excerpt: “Develop an incident response plan that:” ²

What the operator must do: Treat the excerpt as a documentation-and-execution requirement. You must produce a plan document, keep it current, and be able to demonstrate it maps to how you actually respond (roles, workflows, communications, and follow-up) ¹.

Who it applies to

IR-8 is used for:

• Federal information systems
• Contractor systems handling federal data ²

Operationally, you should assume IR-8 applies anywhere you have:

• A defined system boundary (or product/service) with production operations.
• Security monitoring and an escalation path (SOC, on-call engineering, MSSP).
• Third-party dependencies that could trigger or complicate incident response (cloud providers, SaaS, managed services, data processors) ¹.

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

1) Assign control ownership and governance

• Name an IR Plan Owner (often Security/GRC) accountable for content, review cycles, and evidence.
• Name an IR Commander/Incident Manager role responsible for running incidents.
• Define approvers: CISO (or delegate), Legal, Privacy, Comms, and the system/business owner ¹.

Execution tip: Put owners and approvers in the plan body, not only in RACI diagrams. Assessors look for explicit accountability ².

2) Define scope and interfaces

Document:

• Systems covered (or how system-level annexes attach to an enterprise plan).
• Data types and dependencies (identity, logging, cloud accounts, CI/CD, critical third parties).
• Interfaces to related processes: vulnerability management, change management, BCP/DR, and crisis communications ¹.

3) Establish incident definitions and severity model

Your plan should include:

• A clear definition of “security incident” (and what is only an event).
• A severity classification method that drives escalation and communications.
• Decision points for “material impact” and executive notification within your org ¹.

Keep this short. Overly complex severity matrices break during high-pressure response.

4) Write the response lifecycle as an executable workflow

At minimum, document:

• Preparation: access, tooling, evidence capture readiness.
• Detection & analysis: triage, initial hypotheses, log sources, chain-of-custody basics.
• Containment: short-term containment options, isolation guidance, credential resets, third-party containment coordination.
• Eradication & recovery: patching, re-imaging, restoring services, validation steps.
• Post-incident activity: lessons learned, corrective actions, and plan updates ¹.

Practical structure that works: one “core plan” plus annexes:

• Contact and escalation tree (including alternates)
• Communications templates (internal, customer, regulator, third party)
• Forensics and evidence handling checklist
• System-specific runbooks/playbooks (cloud compromise, endpoint malware, phishing, SaaS account takeover) ¹.

5) Integrate third-party coordination explicitly

Most incidents require third-party action. Your plan should specify:

• How to engage critical third parties (contract points of contact, emergency channels).
• What you request (logs, admin actions, preservation steps).
• How you manage shared responsibility boundaries (SaaS vs your identity layer, cloud provider vs your config).
• When procurement or vendor management joins the call ¹.

Operator-grade detail: include a “third-party escalation appendix” listing your top dependencies and where to find the contracts, SLAs, and breach-notification clauses.

6) Prove the plan is implemented: training, exercises, and updates

IR-8 is hard to defend if it’s only a document. Build a lightweight operating rhythm:

• Train responders and cross-functional stakeholders on roles and escalation.
• Run tabletop exercises and capture after-action items.
• Update the plan after major environment changes and after real incidents ¹.

If you need a system to track owners, evidence, and recurring reviews, Daydream can be used to map IR-8 to a control owner, a repeatable implementation procedure, and the evidence artifacts you’ll present during assessment ².

Required evidence and artifacts to retain

Auditors typically want evidence across design, approval, communication, and operation. Retain:

• Incident Response Plan (current version) with version history and revision dates ¹.
• Approval records (sign-off by appropriate authority; meeting minutes or ticket approvals are fine).
• IR roles and on-call documentation (roster, escalation paths, alternates).
• Training records (attendance, curriculum, dates).
• Exercise artifacts: agenda, scenario, participant list, after-action report, and tracked remediation items.
• Incident records (sanitized): timelines, decisions, containment actions, communications, lessons learned.
• Third-party contact list and escalation procedures for critical providers ¹.

Evidence should be retrievable quickly. Store it in a governed repository with access controls and retention rules consistent with your internal policies.

Common exam/audit questions and hangups

Expect questions like:

• “Show me the IR plan and who approved it.” ¹
• “How do you classify incidents and escalate to executives?”
• “How do you coordinate with your cloud/SaaS providers during an incident?”
• “Provide evidence of an exercise and resulting improvements.”
• “How do you ensure the plan reflects current tooling, org structure, and system architecture?” ¹

Common hangup: teams present a plan but cannot show any training, testing, or revision trail. That becomes a finding as “policy-only control” or “not operating as designed” ¹.

Frequent implementation mistakes (and how to avoid them)

Mistake: Copy-paste plan that doesn’t match reality

Avoid it: Put environment-specific facts in annexes you can update quickly: log sources, EDR tooling, ticketing links, cloud accounts, and responder roles.

Mistake: Missing decision rights for high-impact actions

Containment can require taking systems offline or rotating keys broadly. If approval paths aren’t defined, response slows.
Avoid it: Define pre-authorized actions by severity and who can approve exceptions ¹.

Mistake: No third-party playbook

During incidents, teams scramble to find vendor contacts and contract terms.
Avoid it: Maintain a third-party escalation appendix tied to your critical third-party inventory ¹.

Mistake: Evidence scattered across chat and inboxes

Avoid it: Use one evidence folder structure and require exercise leads to publish after-action reports and remediation tickets.

Enforcement context and risk implications

No public enforcement cases were provided in the supplied source catalog for this requirement. Practically, IR-8 gaps increase operational and compliance risk: delayed containment, inconsistent communications, and inability to demonstrate due care during assessments against NIST SP 800-53 Rev. 5 expectations ¹.

Practical 30/60/90-day execution plan

Use phases to move fast without inventing timing claims.

Immediate (stabilize)

• Assign IR plan owner, incident manager role, and approvers.
• Gather current artifacts (any legacy plans, on-call docs, runbooks).
• Draft a core plan outline with scope, severity levels, and lifecycle workflow ¹.

Near-term (operationalize)

• Publish v1 in a controlled repository; collect formal approvals.
• Build annexes: contact tree, third-party escalation appendix, comms templates.
• Run one tabletop exercise on a realistic scenario tied to your environment; produce an after-action report and remediation tickets ¹.

Ongoing (prove continuous readiness)

• Integrate the plan into onboarding for responders and stakeholders.
• Track plan updates after org/tooling changes and after incidents.
• Maintain an evidence pack that maps IR-8 to owner, procedure, and recurring artifacts (Daydream can track this mapping and collection workflow) ².

Frequently Asked Questions

Do we need one incident response plan per system or one enterprise plan?

Either can work if scope is explicit. Many teams keep an enterprise core plan and attach system-specific annexes for tooling, contacts, and recovery constraints ¹.

What’s the minimum content that will satisfy IR-8 in an assessment?

A version-controlled, approved plan that defines roles, incident phases, escalation/communications paths, and post-incident improvement, plus evidence the plan is communicated and exercised ².

How should the plan address third parties (cloud/SaaS/MSSP)?

Name engagement triggers, emergency contacts, what assistance you request (logs, containment actions), and where to find contractual notification and support terms ¹.

Can we treat tickets and runbooks as the “plan”?

Tickets and runbooks help, but assessors expect a cohesive plan document that ties roles, phases, and communications together. Link runbooks as annexes and keep the plan as the governing document ¹.

How do we show evidence if we haven’t had a real incident?

Tabletop exercises, training records, and documented plan reviews provide operational evidence without relying on real events. Keep after-action reports and remediation tracking as your proof ¹.

What’s the fastest way to get audit-ready for IR-8?

Assign a single owner, publish an approved v1 plan, run an exercise, and assemble an evidence pack that maps IR-8 to owners, procedures, and recurring artifacts. Daydream can help maintain that mapping so evidence is continuously assessment-ready ².

Footnotes

1. NIST SP 800-53 Rev. 5

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