PM-1: Information Security Program Plan

PM-1 requires you to publish and distribute an organization-wide information security program plan that explains how your security program is structured, governed, resourced, and maintained. To operationalize it, assign an owner, define mandatory plan contents, map the plan to policies and controls, set a review cadence, and retain evidence that the plan was approved and disseminated. ¹

Key takeaways:

• PM-1 is a “program-level” requirement: the plan must describe governance, scope, roles, and how security work gets executed across the organization. ¹
• Auditors look for a living plan with ownership, approvals, dissemination, and traceability to controls and artifacts, not a one-time document.
• The fastest path is a one-page operating model plus appendices: control ownership map, evidence schedule, and review workflow.

A PM-1 information security program plan is the top-down blueprint for how your organization runs security as a managed program: who owns what, what the program covers, how it is maintained, and how it is communicated to stakeholders. NIST SP 800-53 frames PM-1 as an organization-wide requirement to “develop and disseminate” this plan. ¹

For a Compliance Officer, CCO, or GRC lead, the practical goal is simple: create a plan that is explicit enough that a new executive, an assessor, or a system owner can understand how security governance works in your environment and how program commitments translate into operational controls and recurring evidence. Done well, PM-1 prevents common failure modes like “policies with no operating model,” unclear accountability, and missing proof that the security program is actively managed.

This page gives requirement-level implementation guidance you can execute quickly: a step-by-step build, the minimum artifact set to retain, exam questions to pre-answer, and a practical execution plan. The target keyword for this requirement is pm-1: information security program plan requirement.

Requirement: PM-1 information security program plan (what it means)

PM-1 requires you to develop and disseminate an organization-wide information security program plan. ¹

From an operator standpoint, PM-1 is the “program charter” for security. It should answer, in plain language:

• What the information security program covers (scope and boundaries)
• How it is governed (decision rights, committees, escalation paths)
• Who is accountable (named roles, not just teams)
• How security requirements are implemented and measured (control structure, reporting, evidence)
• How the plan stays current (review triggers, approvals, distribution)

This is not a system security plan (SSP) for a single system. It is the organization’s program plan that gives structure to policies, standards, procedures, and control execution across systems.

Regulatory text

Excerpt (verbatim): “Develop and disseminate an organization-wide information security program plan that:” ¹

What you must do operationally

• Develop: Produce a written plan that defines how the security program operates across the organization (not just IT).
• Disseminate: Prove that the plan was distributed to the right audiences (executive leadership, control owners, system owners, relevant support functions) and is accessible in a controlled document repository.
• Treat it as controlled documentation: versioning, approvals, and review history must exist so you can show the plan is current and managed.

Who it applies to

PM-1 commonly applies in these contexts:

• Federal information systems where NIST SP 800-53 is the required control baseline. ¹
• Contractor systems handling federal data where NIST 800-53-aligned requirements flow down through contracts, agency requirements, or assessment programs. ¹

Operationally, it applies to:

• Central security and GRC functions (program ownership)
• IT operations and platform teams (control execution dependencies)
• Engineering/product (secure SDLC, access patterns, logging)
• HR, Legal, Procurement/third-party risk, and Facilities (cross-functional controls)

Plain-English interpretation (what the assessor expects)

An assessor expects to see a plan that is:

1. Organization-wide: covers the enterprise, not a single system.
2. Actionable: ties governance and roles to how controls are implemented, monitored, and evidenced.
3. Approved and communicated: you can show who approved it and who received it. ¹

A common hangup: teams hand over a set of security policies and call it the program plan. Policies state rules; PM-1 explains the operating model that makes those rules real.

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

Step 1: Name an accountable owner and approver

• Assign a single accountable role for PM-1 (often the CISO, Head of Security, or GRC Director).
• Identify the executive approver (often CIO, CISO, or equivalent governance body).
• Document responsibilities in the plan’s header (owner, approver, effective date, version).

Practical tip: If your org is small, keep roles simple, but still name them. “Security Team” is rarely sufficient in an audit.

Step 2: Define a minimum table of contents (keep it tight)

Use a structure that maps to what operators and auditors ask for:

1. Purpose and scope

• In-scope business units, systems, data types, and workforce
• Out-of-scope with rationale (if any)

2. Security governance

• Security steering committee or equivalent forum (membership by role)
• Decision rights (who accepts risk, who grants exceptions)
• Escalation path for material risk

3. Program structure

• How policies, standards, and procedures fit together
• Control framework mapping (NIST SP 800-53 alignment statement)
• Relationship to system-level documentation (SSPs, diagrams, inventories)

4. Roles and responsibilities

• Control owners by domain (IAM, vulnerability management, incident response, third-party risk)
• First line / second line responsibilities (if you use a three-lines model)

5. Risk management approach

• How risk is identified, documented, tracked, and accepted
• How exceptions are requested and approved

6. Measurement and reporting

• What metrics and reporting exist (risk register reporting, control testing results, audit status)
• Who receives reporting and how often (state the cadence as a requirement you can meet)

7. Plan maintenance

• Review triggers (organizational change, major incidents, audit findings, material technology changes)
• Routine review workflow (owner review, approver sign-off, publication)

Step 3: Map the plan to control ownership and recurring evidence

This is the fastest way to make PM-1 “real” and audit-ready.

Create an appendix (or linked register) that maps:

• Control/control family → control owner → implementation procedure → evidence artifacts → evidence frequency

This aligns to a recommended practice: map PM-1 to a control owner, implementation procedure, and recurring evidence artifacts. ¹

Example mapping row (keep it simple):

• Domain: Access management
• Owner: IAM Lead
• Procedure: Joiner/mover/leaver workflow
• Evidence: Access review reports, ticket samples, offboarding logs
• Storage: GRC tool or controlled repository location

If you use Daydream, treat PM-1 as the top-level requirement record, then attach the owner assignment, procedure references, and an evidence schedule so collection becomes routine rather than a scramble.

Step 4: Disseminate the plan (and prove it)

“Disseminate” needs evidence. Pick methods that produce audit trails:

• Publish in a controlled document system (with access logs if available)
• Announce via an internal channel that archives communications (email or intranet post)
• Require acknowledgement for key roles (control owners, system owners) when feasible

Retain distribution evidence that matches your dissemination method.

Step 5: Operationalize maintenance (so the plan stays true)

• Set a recurring review task in your GRC calendar.
• Tie updates to change management: when you reorganize teams, adopt a new platform, or acquire a company, your plan likely changes.
• When audits find gaps, update the plan or its appendices to reflect the new operating model.

Required evidence and artifacts to retain (audit-ready list)

Keep these artifacts together, with version history:

1. Information Security Program Plan (PM-1 document)

• Version, owner, approver, effective date, revision history

2. Approval evidence

• Signed approval page, workflow record, or governance meeting minutes capturing approval

3. Dissemination evidence

• Link to the published location plus communication record (announcement email, intranet post, ticket)
• Access/permission snapshot showing intended audience can access it

4. Control ownership + evidence map (appendix or register)

• Who owns what, what evidence exists, and where it is stored ¹

5. Review and update records

• Review tickets/tasks, change log, and rationale for material updates

Common exam/audit questions and hangups (and how to pre-answer)

Question: “Show me the program plan and where it’s communicated.”

• Provide the plan, the repository link, and dissemination proof.

Question: “How does this plan connect to control operation?”

• Provide the mapping appendix: control owner, procedure, and recurring evidence artifacts. ¹

Question: “Who can accept risk and grant exceptions?”

• Point to a named role and documented workflow.

Hangup: Plan exists, but it does not match reality.

• Fix by making the plan describe the current operating model, then link to procedures that show execution.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Writing a narrative with no ownership model

• Fix: add a RACI-style roles section and a control owner appendix.

2. Mistake: Confusing policies with the program plan

• Fix: keep policies as separate documents; the plan explains governance, structure, and how the policy set is run.

3. Mistake: No dissemination trail

• Fix: publish through a system that generates records; keep the announcement artifact.

4. Mistake: Plan is “annual compliance paperwork”

• Fix: tie updates to operational triggers (org changes, major incidents, material tech changes) and show the change history.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for PM-1, so this page does not cite enforcement actions.

Risk-wise, PM-1 failures usually surface as:

• unclear accountability for control gaps,
• inconsistent control performance across teams,
• inability to prove program governance to assessors.

Those issues tend to compound during incidents and external assessments because decision rights and evidence sources are unclear.

Practical 30/60/90-day execution plan

First 30 days (Immediate stabilization)

• Assign PM-1 owner and executive approver.
• Draft a minimum viable plan with: scope, governance, roles, maintenance workflow.
• Stand up a controlled publication location (single source of truth).
• Create the control ownership + evidence mapping appendix. ¹

Days 31–60 (Operationalize and socialize)

• Validate roles and responsibilities with IT, Engineering, HR, Legal, Procurement/third-party risk.
• Run a dissemination cycle: publish, announce, and capture proof.
• Add links from the plan to key procedures (incident response, access management, vulnerability management, third-party intake).

Days 61–90 (Assessment readiness)

• Run an internal tabletop audit: pick several controls and trace from plan → owner → procedure → evidence.
• Close gaps where evidence is missing or ownership is unclear.
• Lock in the review workflow (tasks, reminders, approval steps) so plan maintenance is routine.

Frequently Asked Questions

What is the difference between a PM-1 program plan and an SSP?

PM-1 is organization-wide and describes the security program operating model. An SSP is system-specific and describes how controls are implemented for a particular system boundary.

Who should approve the information security program plan?

Use an executive approver with authority to set enterprise expectations and allocate resources. Auditors typically expect evidence of formal approval aligned to your governance structure. ¹

What does “disseminate” mean in practice?

Publish the plan where intended readers can access it, then capture a record that you notified or distributed it to relevant stakeholders. Keep proof of publication and the communication artifact. ¹

How detailed does the plan need to be?

Detailed enough to show scope, governance, ownership, and maintenance, and to connect program statements to control execution. Put operational detail in linked procedures and in the control owner/evidence appendix.

Can we meet PM-1 if we only have policies and no program plan?

Policies alone rarely demonstrate the program’s governance, ownership, and maintenance model. Create a program plan that references the policies and explains how they are managed and evidenced. ¹

How do we keep PM-1 audit-ready without constant manual work?

Maintain a living mapping of control owners, procedures, and recurring evidence artifacts, then schedule review tasks and keep approvals/dissemination records with each revision. ¹

Footnotes

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