PL-6: Security-related Activity Planning

PL-6: security-related activity planning requirement means you must proactively plan, coordinate, and document security-related activities (tests, scans, maintenance, exercises, changes) so they are authorized, scheduled, resourced, and controlled. To operationalize it quickly, assign an owner, define which “security-related activities” are in scope for your system, then run them through a repeatable planning workflow with retained evidence. ¹

Key takeaways:

• Define the security-activity inventory and planning triggers per system boundary, not as a generic enterprise checklist.
• Require authorization, scheduling, and communications for each activity, with pre- and post-activity records.
• Retain planning artifacts that prove the activity was controlled (scope, approvals, timing, results, and follow-up).

PL-6 sits in the Planning (PL) control family, so auditors expect more than “we do security work.” They expect evidence that security work is planned: somebody owns it, the activity is defined, it’s scheduled or triggered, dependencies are coordinated, risks are assessed ahead of time, and outputs feed back into remediation and continuous monitoring. In federal and federal-adjacent environments, this is where teams get tripped up: they have mature execution (scans happen, patches happen, tabletop exercises happen) but weak planning records (why this week, who approved, what changed, what was impacted, and what follow-up occurred).

Operationally, treat PL-6 as your “security activity runbook layer” that sits above individual technical controls. The goal is consistency across security-related activities: vulnerability scanning, penetration tests, disaster recovery exercises, configuration baselines, key rotations, incident response exercises, major change windows, and security-impacting maintenance. You should be able to show a repeatable planning mechanism and a clean trail of artifacts for each activity cycle. This page gives requirement-level steps, evidence checklists, and an execution plan for a CCO, GRC lead, or system owner who needs assessment-ready implementation quickly. ¹

Regulatory text

Excerpt (framework control reference): “NIST SP 800-53 control PL-6.” ²

Operator interpretation: PL-6 expects you to plan security-related activities, not just perform them. “Plan” must be visible in artifacts: defined activities, ownership, authorization, scheduling, coordination, and documentation that the activity occurred as planned and drove follow-up actions. The precise activities and rigor should match your system’s mission, impact level, and change cadence, but you still need a repeatable method and consistent evidence. ¹

Plain-English interpretation (what the control is really asking)

PL-6: security-related activity planning requirement is your proof that security work is governed like production work:

• You know what security activities exist for the system.
• You decide when and why they happen (calendar-based or trigger-based).
• You control how they happen (authorization, scope, safety checks).
• You record what happened and what you did next.

A practical way to think about it: PL-6 is the “planned work order system” for security. If an activity can impact confidentiality, integrity, availability, safety, or compliance, you should be able to show a plan and a record.

Who it applies to

Entities

• Federal information systems and contractor systems handling federal data implementing NIST SP 800-53 controls as part of their compliance obligations. ³

Operational context (where PL-6 shows up)

• Systems with formal authorization and assessment expectations (ATO-like processes).
• Environments with shared operations across teams (Security, IT Ops, DevOps, Networking, third parties).
• Programs where security activities can disrupt services (maintenance windows, scanning load, incident simulations).

If you rely on third parties for security-related activities (managed detection, penetration testing, managed vulnerability scanning), PL-6 still applies to you. The planning artifacts can be shared across you and the third party, but ownership and evidence collection remain your responsibility.

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

Step 1: Assign ownership and define the system boundary

1. Name a PL-6 control owner (often GRC + Security Operations, with system owner accountability).
2. Confirm the system boundary you will assess against (applications, infrastructure, SaaS components, enclaves).

Output: PL-6 ownership record in your control register and a scoped system inventory reference.

Step 2: Build the “security-related activity” inventory for the system

Create a list of activities that you will plan and evidence. Start with the ones that routinely fail audits due to missing coordination:

• Vulnerability scanning (internal/external)
• Penetration testing or adversary simulation
• Patch and firmware maintenance with security impact
• Security configuration baseline changes
• Access recertifications tied to security posture
• Incident response tabletop exercises
• Disaster recovery / backup restore tests
• Key/certificate rotations
• Logging/monitoring coverage changes
• Major architecture changes (network segmentation, identity changes)

Decision rule: If the activity can affect production availability or security posture, it belongs in the inventory.

Output: “Security-Related Activities Register” mapped to the system boundary.

Step 3: Define planning triggers and frequency logic (without guessing numbers)

For each activity, document:

• Trigger type: calendar-based (scheduled) or event-based (triggered by change, incident, new exposure, new asset).
• Pre-reqs: approvals, test plans, notifications, maintenance windows, backups, rollback plans.
• Dependencies: third party coordination, access requirements, environment readiness.

Keep it simple: auditors prefer a clear trigger statement over an arbitrary frequency that you cannot sustain.

Output: Activity planning matrix (activity → trigger → prerequisites → owner → evidence).

Step 4: Standardize the planning workflow (a lightweight “security work order”)

Implement a workflow that every in-scope activity must follow:

1. Intake: ticket/request created with scope, systems, tools, and proposed window.
2. Risk check: safety and impact notes (production impact, data exposure, IR implications).
3. Authorization: approval from system owner (or delegate) and security (as required).
4. Communication: notifications to stakeholders (Ops, Helpdesk, impacted business owners, third parties).
5. Execution record: who ran it, when, what changed, what was tested.
6. Results + follow-up: findings, exceptions, remediation ticket links, and closure criteria.

Output: A consistent template in your ticketing system or GRC platform.

Step 5: Connect PL-6 to related controls and operational programs

PL-6 rarely stands alone in an assessment. Build explicit cross-references in your control narrative to:

• Change management (security-impacting changes)
• Vulnerability management (findings → remediation tracking)
• Incident response (exercises and lessons learned)
• Configuration management (baselines and deviations)

This reduces “orphan evidence” where you have scan reports but no plan, or you have a tabletop exercise but no record of follow-up actions.

Step 6: Make evidence collection automatic

Most PL-6 failures are evidence failures, not execution failures. Treat evidence as a workflow output:

• Require attachments before ticket closure.
• Store artifacts in a system-of-record with retention.
• Use naming conventions per system and activity type.

If you run Daydream for control operations, map PL-6 to a control owner, an implementation procedure, and recurring evidence artifacts so the next assessment is evidence assembly, not archaeology. ²

Required evidence and artifacts to retain

Use this as your minimum evidence set per activity cycle:

Artifact	What it proves	Where it typically lives
Security activity register	You defined what “security-related activities” mean for the system	GRC repository / SSP annex
Activity plan / ticket	Scope, timing, and ownership were defined	Jira/ServiceNow/GRC workflow
Approval record	Authorization occurred before execution	Ticket approvals / email capture
Stakeholder communications	Coordination occurred	Change calendar, email, chat export
Pre-checks (backup/rollback notes)	You planned for failure	Change record attachments
Execution log	Activity happened as planned	Tool logs, runbook output
Results report	Outcomes were captured	Scan reports, test reports
Remediation tracking	Findings turned into actions	POA&M / backlog tickets
Exceptions/risk acceptance	Deviations were approved	Risk register entries

Common exam/audit questions and hangups

Expect these questions, and prepare “show me” answers:

1. “Define your security-related activities.”
   Hangup: teams provide a generic list not scoped to the system boundary.

2. “Show planning evidence for the last activity.”
   Hangup: you show a report (scan/pen test) but not the approvals, comms, or scope.

3. “How do you prevent unapproved security testing from disrupting production?”
   Hangup: no standardized workflow or maintenance windows.

4. “How do findings feed remediation?”
   Hangup: reports exist, but no linked tickets, owners, or closure criteria.

5. “What about third parties performing these activities?”
   Hangup: contract/SOW exists but no proof of scheduling, authorization, or receipt and review of results.

Frequent implementation mistakes and how to avoid them

1. Mistake: Treating PL-6 as “we have a security program.”
   Fix: Make PL-6 about planned activities with artifacts. Keep the narrative operational.

2. Mistake: Evidence scattered across email, chat, and personal drives.
   Fix: Require a ticket/work item as the evidence spine. Everything attaches to it.

3. Mistake: Using a single enterprise schedule that ignores system boundary.
   Fix: Create a per-system activity register (you can inherit enterprise activities, but document the inheritance).

4. Mistake: No defined triggers for ad hoc work.
   Fix: Write event-based triggers such as “new internet-exposed endpoint,” “major version upgrade,” or “post-incident verification.”

5. Mistake: Third party work is “outsourced,” planning is missing.
   Fix: Make the third party deliverable include plan, approvals, and results receipt. Store the receipt and review notes.

Enforcement context and risk implications

No public enforcement cases were provided in the source material for this requirement, so do not treat PL-6 as a “fine-driven” control in isolation. The practical risk is operational and assessment-driven: weak planning records create gaps during audits, delay authorizations, and increase the chance that security activities disrupt production or fail to produce actionable remediation. ³

Practical 30/60/90-day execution plan

First 30 days (stand up the minimum viable PL-6)

• Assign PL-6 owner and backups.
• Define system boundary and draft the security-related activities register.
• Implement a single planning template (ticket fields + required attachments).
• Run one planned activity end-to-end using the new workflow and keep the full evidence package.

Days 31–60 (make it repeatable and auditable)

• Add triggers and prerequisites for each activity in the register.
• Train operators and third parties on the workflow and “no ticket, no activity” rule.
• Link results to remediation tracking (POA&M/backlog), including exception workflow.
• Build an assessment-ready evidence index for recent activities.

Days 61–90 (harden and scale)

• Expand coverage to all in-scope activities and all components in the system boundary.
• Add quality checks: periodic review that activities are planned, executed, and closed with follow-up.
• Use a GRC tool (including Daydream if you have it) to map PL-6 to the owner, procedure, and recurring evidence artifacts so collection becomes routine. ²

Frequently Asked Questions

What counts as a “security-related activity” for PL-6?

Any recurring or triggered action that can materially affect your security posture or production stability should be in scope. Start with scans, tests, patching/maintenance with security impact, exercises, and security-impacting changes.

Do we need a separate PL-6 plan document?

Not necessarily. Auditors usually accept a controlled workflow (tickets + calendar + templates) if it clearly shows defined activities, authorization, coordination, and retained results tied to follow-up actions.

How do we handle third parties performing penetration tests or scanning?

Require a planning artifact (scope, timing, approvals, comms plan) plus a results receipt and internal review record. Store these in your system-of-record and link any findings to remediation tracking you control.

Our security work is agile and ad hoc. How can we “plan” without slowing teams down?

Use event-based triggers and lightweight tickets. The plan can be short, but it must exist before execution and include scope, owner, timing, and an approval path.

What will an assessor ask for first to evaluate PL-6 quickly?

A security-related activities register and a recent sample activity package showing planning through follow-up. If you can produce that in minutes, PL-6 is usually in good shape.

How does Daydream help with PL-6 specifically?

Daydream can hold the PL-6 mapping to a control owner, the implementation procedure, and the recurring evidence artifacts so you have a consistent evidence spine across activity types and assessment periods. ²

Footnotes

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

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

3. NIST SP 800-53 Rev. 5