RA-2: Security Categorization

The ra-2: security categorization requirement means you must formally categorize each system and the information it processes, stores, and transmits, then retain evidence of that categorization so it drives downstream control selection and authorization decisions. Operationalize RA-2 by defining scope, identifying data types, documenting impact levels, obtaining approvals, and keeping the categorization current as the system changes.

Key takeaways:

• RA-2 is a documented decision: system boundary + information types + impact level, with approval and change control.
• Your categorization must be traceable to what the system actually handles (not what you wish it handled).
• Auditors look for artifacts and governance: who approved, when it was reviewed, and how changes trigger recategorization.

RA-2 sits early in the risk management lifecycle because it sets the “impact” lens for everything that follows: the baseline controls you select, the rigor of testing, the intensity of monitoring, and the seriousness of incidents. The requirement text is short, but operators still fail RA-2 for one predictable reason: they treat categorization as a one-time spreadsheet exercise instead of a governed, repeatable decision tied to real system behavior and data flows.

For a CCO, GRC lead, or security compliance owner, the fastest path is to turn RA-2 into a lightweight, reviewable package: define the system boundary, inventory the information types the system touches, decide the impact level, and secure written approval from the right accountable owner. After that, the main job is change discipline. A new integration, a new dataset, or a new third party processor can invalidate last year’s categorization overnight.

This page gives requirement-level implementation guidance you can run as a playbook: who participates, what steps to follow, what artifacts to retain, and how to avoid the audit traps that commonly show up in control assessments aligned to NIST SP 800-53 Rev. 5. ¹

RA-2: Security Categorization requirement (operator view)

RA-2 requires you to categorize the system and the information it processes, stores, and transmits. ²

In practice, categorization is a documented, approved statement of:

• System boundary: what is “in” and “out” of scope.
• Information types: the data the system touches across its lifecycle (ingest, processing, storage, transmission, logging, backups).
• Impact level: the effect of a loss of confidentiality, integrity, or availability based on the system’s information and mission context.

If you cannot show those decisions and the basis for them, you do not have an RA-2 implementation that will hold up in an assessment.

Regulatory text

“Categorize the system and information it processes, stores, and transmits;” ²

What the operator must do: produce and maintain a written categorization for each in-scope system that explicitly covers information processed, stored, and transmitted, and keep that categorization aligned to reality through documented review and change control. The control is satisfied through evidence of a completed categorization, approval, and a mechanism that forces updates when the system or information changes.

Who it applies to (entity + operational context)

RA-2 is typically applied wherever NIST SP 800-53 is used as a control baseline, including:

• Federal information systems and programs aligning to NIST SP 800-53. ¹
• Contractor systems handling federal data (for example, systems supporting federal missions or processing federal information under contract) where NIST SP 800-53 is required by customer or program terms. ¹

Operationally, RA-2 applies to:

• SaaS and internal applications
• Infrastructure platforms (cloud accounts, Kubernetes clusters, shared services)
• Data platforms (warehouses, analytics, ETL)
• Supporting systems with sensitive logs, audit trails, or backups
• Third-party hosted or co-managed systems where your organization still owns compliance outcomes (even if a third party operates components)

Plain-English interpretation

RA-2 asks a simple question: What is this system, what data does it touch, and how bad is it if that data or system is compromised or unavailable? Your answer must be written down, approved, and kept current.

Most teams fail in two ways:

1. They describe the system at a high level and miss key data paths (exports, logs, backups, support tooling).
2. They do not connect categorization to governance (no accountable owner, no review trigger, no audit-ready artifact trail).

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

Use this as a repeatable operating procedure per system.

Step 1: Establish the system boundary (documented)

• Name the system (and aliases used by engineering).
• Define boundary components: application, infrastructure, identity plane, storage, messaging, CI/CD, monitoring, ticketing/support tools that access production data.
• List external dependencies and connected third parties (APIs, processors, hosting, managed services). Output: System boundary statement + architecture/context diagram.

Audit hint: “We host in cloud” is not a boundary. Auditors want to see what accounts, services, and admin paths are included.

Step 2: Inventory information types the system touches

Create an “information handled” table:

• Data elements (customer data, employee data, credentials, keys, telemetry, audit logs)
• Where it exists (prod DB, object storage, log platform, backups, analytics)
• How it moves (ingress sources, egress destinations, cross-region replication, exports)
• Who can access it (roles, admins, support, third parties)

Output: Information type inventory tied to real data flows.

Operational tip: include “secondary data” like debug logs, session replay, screenshots, and support attachments. Those frequently contain sensitive data even when the product database is clean.

Step 3: Determine the security category (impact rationale)

Decide the impact level based on potential harm from loss of:

• Confidentiality
• Integrity
• Availability

Write a short rationale that references your own business context (mission, contractual obligations, customer expectations) and the data inventory you just built.

Output: Categorization statement that a reviewer can defend.

Step 4: Get formal approval (named accountability)

Route the categorization package for sign-off by:

• System owner (engineering/product)
• Security owner (CISO delegate / security GRC)
• Data owner or privacy lead when regulated personal data is in scope

Output: Dated approval record (ticket, GRC workflow, or signed memo).

Step 5: Bind RA-2 to downstream compliance operations

RA-2 should automatically feed:

• Control baseline selection and SSP/control narrative scope
• Risk assessment scope and priorities
• Third-party due diligence focus (processors connected to the categorized system)
• Incident severity expectations and escalation criteria

Output: Crosswalk showing where the categorization is referenced (SSP section, risk register entry, control selection record).

Step 6: Make recategorization a change-controlled event

Define explicit triggers, for example:

• New data type introduced
• New external integration/egress
• Material architecture change (new region, new tenancy model)
• New privileged access path (support tooling, admin plane change)
• New third party that processes or can access in-scope data

Output: Change management checklist item: “RA-2 impact review required.”

Where Daydream fits naturally: Daydream can track each system’s RA-2 owner, link the categorization decision to recurring evidence (diagrams, data inventories, approvals), and generate an audit-ready record that shows when changes occurred and how the categorization stayed current.

Required evidence and artifacts to retain

Maintain these artifacts per system, in a single package assessors can open and follow end-to-end:

Artifact	What it proves	Common format
System boundary statement	You defined what the “system” is	Document or SSP section
Architecture/context diagram	Boundary is grounded in real components	Diagram (PNG/PDF)
Information types + data flow inventory	You considered processed/stored/transmitted data	Table + data flow diagram
Categorization decision + rationale	You made an impact decision tied to facts	Memo/record in GRC
Approval evidence	Accountability and governance	Ticket/workflow record
Review/change history	Categorization stays current	Change log + meeting notes
Cross-references	Categorization drives other compliance work	SSP/control mapping record

Common exam/audit questions and hangups

Expect these questions, and pre-answer them in your artifacts:

1. “Show me what information the system transmits.” Auditors often find teams only documented stored data.
2. “Where are logs and backups categorized?” If you omit them, your scope is incomplete.
3. “Who approved the categorization and when was it last reviewed?” Approval must be attributable to a role with authority.
4. “What changed since the last categorization?” If you cannot answer, you lack an operating mechanism.
5. “How did the categorization influence your control selection?” If it is a dead-end document, you will get a finding for weak implementation maturity.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Categorizing only the application, not the ecosystem.
  Fix: define boundary to include identity, admin access, CI/CD paths that touch production, logging, and backup systems.
• Mistake: Copy-pasting last year’s categorization.
  Fix: tie RA-2 review to change management triggers and require a quick re-attestation after material releases.
• Mistake: Treating third parties as “out of scope.”
  Fix: document where third parties process, store, or can access in-scope information; reflect that in the information inventory.
• Mistake: No clear ownership.
  Fix: assign a single system owner accountable for accuracy; security and privacy review, but don’t own the facts.
• Mistake: No audit trail.
  Fix: approvals and reviews must be recorded in a durable system (ticketing or GRC workflow), not informal chat.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for RA-2, so you should treat RA-2 primarily as an assessment and authorization readiness control under NIST SP 800-53. ¹

Risk-wise, RA-2 failures usually surface as:

• Mis-scoped assessments (testing the wrong boundary)
• Under-selected safeguards (controls don’t match impact)
• Incident misclassification (severity doesn’t match actual data exposure)
• Contractual noncompliance (federal customers expect disciplined categorization aligned to the adopted framework)

Practical 30/60/90-day execution plan

Use phased milestones without assuming a fixed implementation duration.

First 30 days (Immediate stabilization)

• Pick the first set of in-scope systems (start with those handling federal data or business-critical operations).
• Assign system owners and a security GRC owner for RA-2 governance.
• Publish a one-page RA-2 standard: required fields, approval path, and change triggers.
• Produce “minimum viable” categorization packages for the highest-risk systems: boundary + data inventory + initial impact rationale + approvals.

By 60 days (Operationalize and connect downstream)

• Expand categorization coverage to remaining in-scope systems.
• Connect RA-2 records to SSP/control scope documentation and risk register entries.
• Add RA-2 review as a required step in architecture review and change management.
• Standardize evidence storage so each system has a single audit-ready folder or GRC record.

By 90 days (Sustain and prove operation)

• Run an internal spot check: pick systems and verify diagrams match reality (accounts, regions, integrations, logging).
• Test triggers: confirm a recent material change resulted in an RA-2 review or re-approval.
• Prepare an assessor-ready index: for each system, link to the categorization package and last review date.
• If you use Daydream, configure recurring evidence tasks and owner attestations so RA-2 stays current without chasing people manually.

Frequently Asked Questions

Do we need a separate RA-2 categorization for every microservice?

Categorize at the level where the boundary is stable and auditable. If microservices share data stores, identity, logging, and deployment pipelines, a system-level categorization with clear component listings is usually more defensible than hundreds of disconnected records.

What if we don’t know all the data types the system handles yet?

Document what you know, explicitly record assumptions and gaps, and assign actions to close them (data discovery, log sampling, integration review). Auditors tolerate uncertainty if you show a controlled process to resolve it and you update the categorization.

Does RA-2 require a specific template?

NIST SP 800-53 defines the requirement but does not mandate a template in the provided excerpt. Use a template that forces completeness: boundary, processed/stored/transmitted inventory, rationale, and approvals. ¹

How do we handle third parties that process data for the system?

Include third-party processing and access paths in the “transmits” and “processes” portions of the information inventory. Then ensure your third-party due diligence and contract controls reflect the system’s categorization.

What’s the fastest way to make RA-2 audit-ready?

Build a single evidence package per system with links to diagrams, data flow inventory, the categorization decision, and approval records. Put the review trigger into change management so you can prove it stays current.

Who should approve the security categorization?

The system owner must approve because they own architecture and data reality; security and privacy should review and co-approve when relevant. The key is named accountability and a dated record that an assessor can trace.

Footnotes

1. NIST SP 800-53 Rev. 5

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