RA-3: Risk Assessment

RA-3: Risk Assessment requires you to run and maintain a documented, repeatable risk assessment for each in-scope system so you can identify threats, vulnerabilities, likelihood, impact, and resulting risk, then drive risk responses and control selection. To operationalize it fast, define scope, pick a method, assess on a set cadence and upon major change, and retain evidence that proves the assessment was performed and acted on. ¹

Key takeaways:

• RA-3 is an operating process, not a one-time report; audits fail on missing repeatability and missing evidence.
• Your assessment must connect to real decisions: risk treatment, control selection, exceptions, and POA&Ms.
• The fastest path is to map RA-3 to an owner, a written procedure, and a standing evidence set. ²

RA-3: risk assessment requirement work breaks down into two parts: (1) performing a risk assessment with a defined method and (2) proving you did it, consistently, for the right scope. The control text is short, but the operational expectation is not. If you cannot show how you identify threats and vulnerabilities, score likelihood and impact, and translate results into risk decisions, RA-3 will be treated as a control gap even if you have many security controls deployed.

For a CCO or GRC lead, the practical objective is simple: make risk assessment a repeatable “system lifecycle” activity that triggers on meaningful changes (architecture, data, third parties, hosting, identity model) and on an established schedule. Your outputs must feed governance: authorization decisions, prioritization, exceptions, and remediation tracking.

This page gives requirement-level implementation guidance you can put into motion quickly: who owns RA-3, what artifacts auditors expect, the minimum process to stand up, and the failure modes that create findings. It also shows how to structure RA-3 so your program scales across multiple systems and third parties without turning into a quarterly fire drill.

Regulatory text

Requirement excerpt: “Conduct a risk assessment, including:” ²

Operator meaning: You must perform and document a risk assessment for the system(s) in scope. Even though the excerpt is brief in the provided catalog extract, auditors typically evaluate RA-3 as a complete lifecycle practice: documented methodology, defined scope and triggers, performed assessment activity, and demonstrable outcomes (risk decisions and tracked actions) aligned to your system’s mission and data sensitivity. ¹

Plain-English interpretation (what RA-3 really demands)

RA-3 expects you to answer, in a disciplined and repeatable way:

• What can go wrong? (threats and threat events)
• Where are we weak? (vulnerabilities, exposures, control gaps)
• How bad would it be? (impact to confidentiality, integrity, availability, and mission)
• How likely is it? (likelihood given exposure and existing controls)
• So what? (risk rating, risk acceptance thresholds, and required actions)

Then you must use the results: update control selection, prioritize remediation, open and manage POA&Ms, and document risk acceptances or exceptions when you decide not to remediate. A risk assessment that does not change decisions is hard to defend.

Who it applies to (entity and operational context)

RA-3 applies wherever NIST SP 800-53 Rev. 5 is your governing control baseline, including:

• Federal information systems operated by agencies.
• Contractor systems handling federal data (common in regulated federal supply chains and authorization-driven environments). ¹

Operationally, apply RA-3 at the system level (your SSP boundary), and also in shared services that materially affect system risk (identity provider, logging/SIEM, endpoint management, cloud landing zone). If your organization runs multiple products, treat each as a system or subsystem with its own scope statement, dependencies, and risk posture.

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

Below is a practical build sequence that stands up RA-3 quickly and makes it auditable.

1) Assign ownership and define governance

• Name a control owner (usually the system owner, ISSO, or GRC lead) and a performer (risk analyst, security architect, or assessment team).
• Define the approval authority for risk acceptance (often the Authorizing Official or delegated risk committee).
• Set a rule for when RA-3 must be refreshed, tied to “significant change” and a routine cadence you can sustain. Document the triggers in your procedure. ¹

Fast operational win: implement the recommended control mapping: map RA-3 to a control owner, an implementation procedure, and recurring evidence artifacts. ²

2) Lock the scope (system boundary and crown jewels)

• Identify the system boundary (what’s in/out): environments, accounts, networks, SaaS dependencies, and data flows.
• Identify data types and critical services (authentication, payment, case management, operational tech, etc.).
• List inherited controls and shared responsibility boundaries for cloud and third parties.

Artifact to produce: “RA-3 Scope Statement” (1–2 pages) that points to the SSP boundary, key dependencies, and change triggers.

3) Choose a repeatable risk methodology you can defend

You need consistency more than sophistication. Your method should define:

• Risk factors you consider (threat, vulnerability, impact, likelihood, existing controls).
• The rating scale (qualitative scales are acceptable if consistent).
• How you convert findings into risk levels and into required actions.

Tip: If your enterprise already has ERM risk scoring, align to it, but keep system-level security specifics (attack surface and control effectiveness) visible.

Artifact to produce: “Risk Assessment Methodology” appendix or SOP section.

4) Build the inputs checklist (so you’re not improvising)

Minimum inputs most teams should pull before scoring risk:

• Current architecture diagram and data flow diagram (or cloud reference architecture + app specifics)
• Asset inventory for system components
• Vulnerability scan summaries and open critical issues
• Identity and access model (roles, privileged access paths)
• Incident history and lessons learned (system-specific)
• Third-party dependency list (SaaS, MSPs, critical suppliers)
• Prior risk assessments and open POA&Ms

Hangup auditors focus on: missing linkage between vulnerabilities/control gaps and the risk register. Your RA-3 write-up should explicitly reference the sources you used.

5) Perform the assessment (structured workshop + evidence trail)

Run a working session with the people who can validate reality:

• system owner/product owner
• security engineering/architecture
• operations/SRE
• privacy (if applicable)
• third-party risk owner (for major dependencies)

For each top scenario, document:

• threat event description
• affected assets/data
• existing controls and control weaknesses
• likelihood rationale
• impact rationale
• overall risk rating
• required treatment (mitigate/transfer/avoid/accept)
• owner and due date for mitigation items

Practical example scenarios to include (adapt to your system):

• credential compromise of privileged admin path
• misconfiguration of cloud storage exposing sensitive data
• third-party outage affecting mission operations
• logging gaps that prevent incident reconstruction

6) Translate results into decisions and tracking

RA-3 becomes real when outputs drive governance:

• Create or update a system risk register with unique IDs for each risk.
• For mitigation items, create POA&Ms (or your equivalent backlog) with owners and target dates.
• For accepted risks, record a risk acceptance memo with rationale, conditions, and expiration/review date.
• Update SSP/control implementation notes where the assessment identified control gaps or compensating controls.

7) Make it recurring (calendar + triggers + versioning)

You need evidence that RA-3 is not a one-off:

• Put the reassessment on a calendar.
• Require reassessment upon significant change (documented triggers).
• Version the risk assessment and keep change notes: what changed, why, and what decisions changed.

8) Operationalize in a GRC system (optional, but accelerates audit readiness)

A tool is not required, but it reduces drift:

• control owner assignment
• evidence request workflows
• risk register and exception lifecycle
• linkage between RA-3 risks and control gaps

Daydream can help by structuring RA-3 as a managed requirement with an owner, a defined procedure, and recurring evidence artifacts so you can answer auditor questions with a consistent evidence pack. ²

Required evidence and artifacts to retain (auditor-ready)

Maintain an “RA-3 evidence pack” per system:

1. RA-3 Procedure / SOP

• scope, roles, triggers, cadence, methodology, approval flow

2. Current Risk Assessment Report

• dated, versioned, scoped to the system boundary
• includes threat/vulnerability/likelihood/impact/risk rating
• includes treatment decisions

3. System Risk Register

• risks, owners, status, last reviewed date, linkage to mitigations

4. POA&M / Remediation Tracker Extract

• items derived from RA-3 with ownership and progress

5. Risk Acceptances / Exceptions

• approvals, rationale, compensating controls, review conditions

6. Inputs Evidence

• scan summaries, architecture diagrams, third-party dependency list, incident lessons learned

Common exam/audit questions and hangups

Expect these questions:

• “Show me the most recent risk assessment for System X and the method you used.”
  Hangup: report exists but method is undocumented, or report is not tied to the current architecture.

• “What triggers a new risk assessment?”
  Hangup: no defined triggers; the process relies on memory and good intentions.

• “Pick one high risk item. Where is the remediation plan, and who owns it?”
  Hangup: risks are written as narratives with no accountable action tracking.

• “Which risks were accepted, by whom, and for how long?”
  Hangup: informal acceptance in email/Slack with no approval trail.

• “How do third parties factor into the system risk assessment?”
  Hangup: third-party dependencies appear in procurement files but not in RA-3 outputs.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Treating RA-3 as a template exercise.
   Fix: require “decision outputs” (POA&Ms, acceptances, control changes) as part of completion criteria.

2. Mistake: No clear system boundary.
   Fix: publish a one-page boundary statement and keep it versioned with the assessment.

3. Mistake: Scoring without rationale.
   Fix: capture brief likelihood/impact justifications so reviewers can reproduce your rating.

4. Mistake: No evidence trail.
   Fix: store inputs (scan summaries, diagrams, dependency lists) with the assessment version.

5. Mistake: Risks don’t map to control gaps.
   Fix: include a field “related controls/control weaknesses” and link to your control baseline and SSP notes. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should frame RA-3 risk in audit and authorization terms rather than citing specific penalties. The practical exposure is consistent: if you cannot demonstrate an operating risk assessment process and evidence, assessors can treat your risk management program as ineffective, which can delay ATO decisions, increase oversight, and expand testing scope. ¹

Practical 30/60/90-day execution plan

Because this page cannot cite time-to-implement benchmarks from the provided sources, treat the plan below as a pragmatic sequencing model, not a promise of effort.

First 30 days (stand up the minimum viable RA-3)

• Assign RA-3 owner, performer, and approver; publish RACI.
• Draft RA-3 SOP: scope, triggers, methodology, and approval workflow.
• Define system boundary and dependency inventory for each in-scope system.
• Run one pilot assessment on a high-impact system; produce a risk register and POA&M entries.

Days 31–60 (make it repeatable and auditable)

• Standardize templates: risk scenarios, scoring rationale fields, and treatment decision log.
• Build the evidence pack structure in your GRC repository (folders or a tool workflow).
• Add governance: risk acceptance memo template and expiration/review rule.
• Train system owners on how RA-3 outputs become remediation and exceptions.

Days 61–90 (scale across systems and integrate with change management)

• Roll RA-3 across remaining systems in scope.
• Integrate with change control so major changes trigger reassessment.
• Add routine reporting to leadership: top risks, aging POA&Ms, accepted risk inventory.
• Run an internal “mock audit” on RA-3 evidence for one system and close documentation gaps. ¹

Frequently Asked Questions

What is the minimum acceptable output for the ra-3: risk assessment requirement?

A dated, scoped risk assessment with a documented method, plus a risk register that shows treatment decisions and tracked actions. If you cannot show follow-through (POA&Ms or acceptances), the assessment reads as non-operational. ¹

Do I need a quantitative model (ALE/SLE) to satisfy RA-3?

No specific model is required by the provided excerpt. Use a consistent method your organization can repeat and explain, and retain the rationale for likelihood and impact ratings. ²

How do I handle third-party dependencies in RA-3?

Treat critical third parties as part of your system threat surface: availability dependency, data sharing, access paths, and inherited controls. Record them as risk drivers and link them to third-party due diligence artifacts where you store them.

What evidence most often fails an audit for RA-3?

Missing proof that the assessment was performed (dated report, versioning), missing methodology, and missing linkage to remediation or risk acceptance. “We discussed risks” without artifacts rarely holds.

How often should we reassess?

Set a cadence your team can sustain and document it, then reassess on significant change. Auditors care more about defined triggers, repeatability, and evidence than a specific interval. ¹

Can Daydream replace the need for a risk assessment workshop?

A tool can structure ownership, workflows, and evidence capture, but you still need informed participants to validate threats, impacts, and real control effectiveness. Use Daydream to standardize RA-3 procedures and make evidence collection routine. ²

Footnotes

1. NIST SP 800-53 Rev. 5

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