PM-9: Risk Management Strategy

PM-9: risk management strategy requirement is where your risk program either becomes “paper” or becomes the operating system for security and compliance decisions. In NIST SP 800-53 Rev. 5, PM controls sit above individual technical controls. They explain how the organization runs risk management across the enterprise and how that direction flows down into system security plans, authorizations, continuous monitoring, and third-party oversight.

For a CCO, CISO, or GRC lead, the practical goal is simple: be able to show (1) what your risk management strategy is, (2) who is accountable for it, (3) how it is applied consistently, and (4) what evidence proves it is used. PM-9 fails most often because teams write a high-level policy statement but can’t demonstrate decision traces: why a risk was accepted, which leader approved it, what monitoring is in place, and how exceptions are handled.

This page gives requirement-level implementation guidance you can execute without waiting on a full program redesign. It focuses on tight artifacts, clear ownership, and audit-ready evidence that maps directly to PM-9 expectations in NIST SP 800-53 Rev. 5. ¹

Requirement overview (PM-9)

PM-9 expects an organization to develop a risk management strategy that guides how risk is managed across the enterprise, not just within a single system. Treat it as the “how we do risk” document that standardizes decisions across security, privacy (where applicable), operations, and third-party relationships.

Operator intent: create a strategy that is specific enough that two different teams will make consistent risk decisions, and measurable enough that you can prove it is in effect during audits.

Regulatory text

Excerpt: “Develops a comprehensive strategy to manage:” ²

What the operator must do:
Because the excerpt is short in the provided source, you should implement PM-9 as an enterprise strategy document backed by governance, repeatable procedures, and evidence. Assessors will test whether your “strategy” is real by looking for consistent risk methods, clear accountability, and decision records that align to your stated approach. ¹

Plain-English interpretation

Your PM-9 deliverable is a Risk Management Strategy that answers, in plain language:

• What risks you manage (security, operational resilience, third-party, compliance, project, and system risks within scope).
• How you assess them (common scales, criteria, and what “high” means in your environment).
• What you do with them (mitigate, transfer, avoid, accept) and who can approve each.
• How you monitor them over time (review triggers, KRIs/metrics if you use them, and how changes re-open risk decisions).
• How it connects to system-level work (SSPs, authorizations, continuous monitoring, POA&Ms, and exception handling).

If your organization handles federal data (including through a third party relationship) or operates federal information systems, PM-9 is typically expected as part of an audit-ready NIST SP 800-53-aligned program. ³

Who it applies to

Entity types (typical):

• Federal information systems (agency-run environments)
• Contractor systems handling federal data (including many service providers and SaaS organizations supporting federal customers) ²

Operational context where PM-9 is tested hardest:

• Multiple business units with inconsistent risk decisions
• Rapid product delivery where exceptions are common
• Significant third party dependency (cloud, MSPs, critical suppliers)
• Mergers, divestitures, or major architecture shifts that change risk posture

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

1) Assign a single accountable owner and governance forum

• Name an executive accountable for the strategy (often GRC lead with executive sponsor).
• Define the decision-making body (risk committee, security steering committee, or equivalent).
• Document escalation paths: what goes to the committee vs what teams can decide.

Done looks like: a RACI that states who proposes, reviews, approves, and who is informed for risk decisions, exceptions, and risk acceptance.

2) Write the Risk Management Strategy (keep it tight, make it testable)

Include these sections, with organization-specific detail:

1. Scope and objectives (what environments, business lines, and third parties are in scope).
2. Risk appetite and tolerance statements (qualitative if needed, but explicit).
3. Risk taxonomy (categories you track; include third party risk as a category if relevant).
4. Risk assessment method (scales, impact/likelihood definitions, and how you rate inherent vs residual risk).
5. Risk treatment options and required approvals (who can accept which level of risk).
6. Exception handling (how control exceptions are requested, time-bounded, and reviewed).
7. Integration points (system authorization, continuous monitoring, POA&M management, third party due diligence).
8. Review triggers (material changes, incidents, major vendor changes, audit findings).

Practical test: if you remove your company name, the document should still be specific enough that it could not apply to every organization.

3) Map PM-9 to procedures and recurring evidence (audit readiness)

This is the fastest way to avoid the most common PM-9 failure: “We have a strategy but no evidence.”

Create a one-page mapping that links:

• PM-9 control owner
• Where the strategy is stored (system of record)
• Procedures that implement it (risk assessment SOP, risk acceptance workflow, exception SOP, third party risk process)
• Recurring evidence artifacts and cadence

This mapping is explicitly recommended in the provided guidance: “Map PM-9 to control owner, implementation procedure, and recurring evidence artifacts.” ²

4) Operationalize with workflows that produce decision records

Stand up lightweight workflows that generate consistent artifacts:

• Risk register workflow: intake → assessment → treatment plan → owner → due date → status.
• Risk acceptance workflow: documented rationale → compensating controls → expiration/review date → approver sign-off.
• Control exception workflow: what control is deviated from → scope → duration → monitoring → approval.
• Third party risk alignment: ensure due diligence outputs (security reviews, SOC report reviews, contract requirements) roll up into the same risk register categories and scoring method.

5) Connect PM-9 to system authorization and ongoing monitoring

Assessors will look for strategy-to-execution alignment. Practical connections:

• System authorization packages should reference the enterprise risk method.
• POA&Ms should reflect your risk treatment approach.
• Continuous monitoring reports should show how risk posture is tracked and re-assessed when the environment changes.

6) Put the strategy on a review cycle and prove the reviews happened

You do not need a complex mechanism. You need proof:

• Version-controlled strategy document
• Meeting minutes or approvals showing periodic review and updates
• Evidence of updates after triggering events (major incident, architecture change, new critical third party)

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

Maintain these artifacts in a system of record (GRC tool or controlled repository):

• Risk Management Strategy document (versioned, approved)
• RACI for risk decisions and escalation
• Risk assessment methodology (definitions, scales, scoring rules)
• Risk register exports or reports (showing lifecycle and ownership)
• Risk acceptance memos/records (with approver and rationale)
• Exception records (scope, duration, compensating controls, approvals)
• Risk committee charter, agendas, and minutes
• Evidence of periodic review (document change log + approval trail)
• Crosswalk showing PM-9 owner, procedures, and recurring evidence artifacts ²

Common exam/audit questions and hangups (what to prep for)

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

1. “Show me your risk management strategy and who approved it.”
2. “How do you define and score risk? Is it consistent across teams?”
3. “Who can accept risk, and what is the approval evidence?”
4. “How do third party risks enter your enterprise risk process?”
5. “Show examples where the strategy changed a decision (roadmap, architecture, compensating control, contract term).”
6. “How do you ensure risk decisions are revisited after change?”

Hangups usually appear when approvals are informal (chat/email) and not retained, or when risk acceptance has no expiration/review trigger.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Strategy reads like a policy poster	Not testable; no decision criteria	Add scoring rules, approval thresholds, and required artifacts
No evidence mapping	Assessors can’t trace operation	Maintain a PM-9 evidence map tied to procedures and outputs 2
Risk acceptance is ad hoc	Risk accumulates without oversight	Require rationale, approver, compensating controls, and re-review trigger
Third party risk handled “somewhere else”	Enterprise view is incomplete	Normalize third party findings into the same risk register and scoring method
“One-and-done” strategy	Becomes stale	Implement periodic review and event-triggered review with recorded approvals

Enforcement context and risk implications

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

Operationally, PM-9 gaps increase the chance of inconsistent risk decisions, uncontrolled exceptions, and weak governance over third party and system risks. Those gaps also make audits slower and more disruptive because teams must reconstruct decisions after the fact.

Practical 30/60/90-day execution plan

First 30 days (stabilize and publish)

• Assign PM-9 owner and approval chain; document RACI.
• Draft the Risk Management Strategy with testable criteria (scales, approvals, exception handling).
• Create the PM-9 mapping sheet: owner → procedures → recurring evidence artifacts. ²

Days 31–60 (make it real with workflows)

• Standardize the risk assessment template and risk register fields.
• Implement risk acceptance and exception workflows with required fields and approvals.
• Run one risk committee review using the new format; retain minutes and outputs.

Days 61–90 (prove it operates end-to-end)

• Select a few systems and third parties; trace their risks through assessment → treatment → monitoring evidence.
• Update strategy language based on what broke in practice (missing fields, unclear approvals, inconsistent scoring).
• Package an “audit-ready PM-9 binder” (digital folder) with the evidence list above.

Where Daydream fits naturally: If you struggle to keep the PM-9 strategy, mappings, workflows, and evidence synchronized across teams, Daydream can act as the system of record that ties control ownership to procedures and recurring artifacts, so PM-9 stays continuously testable instead of a quarterly scramble.

Frequently Asked Questions

What is the minimum acceptable artifact for the pm-9: risk management strategy requirement?

A written Risk Management Strategy document with clear ownership, approval, and defined methods for assessing and treating risk. You also need evidence it drives decisions, such as risk acceptance records and a maintained risk register.

Does PM-9 require a specific risk framework or scoring model?

NIST SP 800-53 Rev. 5 does not mandate a single scoring model in the provided excerpt. Auditors usually care that your method is defined, consistently applied, and produces documented decisions. ¹

How do I show PM-9 is “operational,” not just a document?

Prepare decision traces: risk assessments, risk treatment plans, approvals for risk acceptance, exception records, and committee minutes. Tie each artifact back to the strategy sections and show recent examples.

Where should third party risk management plug into PM-9?

Your strategy should define third party risk as a risk category, specify how due diligence results become enterprise risks, and set approval rules for accepting third party-related residual risk. Keep third party-driven exceptions and compensating controls in the same evidence system.

Who should approve risk acceptance under PM-9?

Your strategy must define risk acceptance authority by role and risk level, then you must retain proof of approvals. Keep the approval thresholds realistic so teams do not route routine items to executives.

What’s the fastest way to get audit-ready for PM-9?

Build a one-page map of PM-9 to an owner, procedures, and recurring evidence artifacts, then fill the evidence list with recent, real examples. This directly aligns with the recommended control mapping approach. 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