RA-3(1): Supply Chain Risk Assessment

RA-3(1) requires you to explicitly assess supply chain risks tied to the systems, components, and services you depend on, then capture results as actionable risk decisions (accept, mitigate, transfer, avoid) backed by evidence. To operationalize it fast, define scope, map your supplier dependencies, run a repeatable risk assessment, and retain artifacts that prove the assessment happened and drives controls. ¹

Key takeaways:

• Scope supply chain risk to real dependencies: products, services, and sub-tier providers that can affect confidentiality, integrity, or availability.
• Produce auditable evidence: a defined method, completed assessments, and decision records tied to remediation and monitoring.
• Embed results into procurement, architecture, and change management so the assessment changes what you buy and how you operate.

The ra-3(1): supply chain risk assessment requirement is about proving you can identify and evaluate the risk introduced by third parties and the technology supply chain before it becomes a security incident or an operational outage. For most compliance teams, the hard part is not writing a policy. It is building a repeatable assessment motion that keeps up with procurement, cloud adoption, software dependencies, and service provider change.

RA-3(1) sits inside NIST SP 800-53 Rev. 5’s risk assessment family and is commonly expected in federal information systems and contractor environments handling federal data. ² Practically, auditors will look for three things: (1) your defined assessment approach, (2) completed assessments for in-scope dependencies, and (3) evidence that results drive action (contract terms, compensating controls, monitoring, or disallow decisions). If you only have security questionnaires, you will likely have gaps because supply chain risk includes upstream dependencies (subprocessors, libraries, hosting, and managed service paths), not just the immediate vendor.

Regulatory text

Requirement excerpt: “Assess supply chain risks associated with {{ insert: param, ra-03.01_odp.01 }} ; and” ¹

Operator interpretation: You must perform a supply chain risk assessment for the defined scope parameter in your implementation (the “organization-defined parameter” placeholder). In practice, you define what you assess (for example: critical suppliers, specific system components, or specific services), then you perform and document assessments against that defined scope on an ongoing basis. ¹

Plain-English meaning

• Identify what parts of your environment depend on third parties or externally sourced components.
• Evaluate the risk those dependencies introduce, including security, resilience, integrity of delivered software/hardware, and exposure created by sub-tier providers.
• Record decisions and required controls based on the assessed risk, then track those controls to completion.

Who it applies to

Entity scope

• Federal information systems implementing NIST SP 800-53 Rev. 5 controls. ²
• Contractor systems handling federal data where NIST SP 800-53 controls are flowed down contractually or used as the control baseline. ²

Operational scope (where the work shows up)

• Procurement and sourcing (new third parties, renewals, and major scope changes)
• Architecture and engineering (new platforms, new integrations, new externally sourced components)
• IT operations (managed service providers, cloud service providers, datacenter and network providers)
• Product/security (software supply chain, CI/CD, dependency ingestion, signing/attestation decisions)

If your environment relies on SaaS, cloud hosting, managed security services, payment processors, or externally developed components, you have a supply chain and RA-3(1) applies in real terms.

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

Step 1: Define the RA-3(1) scope parameter (your “what”)

RA-3(1) includes an organization-defined scope placeholder. Turn that into a crisp statement such as:

• “All critical third parties supporting in-scope systems,” or
• “All externally provided components and services used by System X,” or
• “All third parties with privileged access or sensitive data access.”

Deliverable: RA-3(1) control statement with scoping criteria and triggers (new onboarding, renewal, material change, new integration). ¹

Step 2: Build a supply chain dependency inventory (your “where”)

Create a practical inventory that ties:

• System/application → third party/service → data types accessed → access paths → sub-tier dependencies (if known)

Start with what you already have: vendor lists, SaaS catalogs, SSO app inventory, cloud accounts, CMDB, procurement records. Your goal is coverage, not perfection.

Tip that reduces audit pain: Put an “assessment required?” flag on each dependency and record why (meets criteria vs. excluded). Auditors accept exclusions when they are explicit and consistent.

Step 3: Define an assessment method (your “how”)

Document a repeatable method that includes:

• Risk categories (security, availability/resilience, integrity/tampering, compliance, concentration risk, geopolitical/location where relevant to your program)
• Inherent risk scoring (based on data sensitivity, privilege level, connectivity, criticality)
• Control strength evaluation (evidence-based review, not marketing claims)
• Residual risk outcome and required actions

This can be lightweight, but it must be written down and used consistently. ¹

Step 4: Perform assessments for in-scope dependencies (your “do”)

For each in-scope third party/component/service:

1. Collect evidence (contracts, SOC reports if available, architecture diagrams, security documentation, incident history provided by the third party, dependency mapping to subprocessors where available).
2. Interview internal owners (system owner, procurement, engineering, and service owner).
3. Rate inherent risk and document rationale.
4. Evaluate controls that reduce the risk (technical controls you operate, controls the third party operates, and contractual controls).
5. Decide: accept / mitigate / transfer / avoid. Tie mitigations to an owner and a due date.

Practical minimum standard: A completed assessment should read like a decision memo, not a questionnaire export.

Step 5: Operationalize outcomes (your “make it real”)

RA-3(1) fails in practice when assessments don’t change anything. Add hard gates and workflows:

• Procurement gate: no contract signature (or no production access) without a completed supply chain risk assessment for in-scope purchases.
• Architecture gate: no new integration or privileged access without assessment and required compensating controls.
• Change management trigger: reassess on material change (new data types, new access, major service change, acquisition, or a new subprocessor chain).

Step 6: Set review and monitoring expectations (your “keep it current”)

Define what triggers a reassessment and what is monitored between assessments:

• Third party incident notifications and escalation paths
• Contractual reporting requirements
• Subprocessor change notifications (if applicable)
• Internal performance and outage tracking for critical service providers

You do not need a perfect external intelligence program to meet RA-3(1), but you do need a defined mechanism to revisit risk when the supply chain changes. ²

Required evidence and artifacts to retain

Auditors will ask for proof of design and operation. Keep artifacts that show both.

Governance

• RA-3(1) control narrative: scope definition, triggers, method, roles, approvals ¹
• RACI (who owns assessments, who approves risk acceptance)

Inventory and scoping

• Supply chain dependency inventory (systems → third parties → components/services)
• Inclusion/exclusion rationale per dependency

Assessment execution

• Completed assessment records ¹
• Evidence pack per assessment (what you reviewed)
• Risk decision record (accept/mitigate/transfer/avoid) with approver
• Remediation tickets and closure evidence for required mitigations

Operationalization

• Procurement/architecture/change-management workflow artifacts showing assessment gates
• Exception process and approved exceptions with compensating controls

Daydream (or a similar GRC workflow system) becomes useful when you need consistent evidence packets, automated reminders, and clean mapping from RA-3(1) to control owners, procedures, and recurring artifacts without spreadsheets breaking every quarter. ¹

Common exam/audit questions and hangups

What auditors ask

• “Show me your scope definition for RA-3(1). What is included, and why?”
• “How do you know you assessed all critical suppliers?”
• “Pick a critical third party. Show the assessment, the evidence reviewed, and the resulting actions.”
• “How do you reassess when something changes?”
• “Who can accept residual supply chain risk, and where is that documented?”

Typical hangups

• No clear definition of the RA-3(1) scope parameter, leading to inconsistent coverage.
• Assessments performed, but no risk decisions or remediation tracking.
• Supplier lists exist, but they are not tied to systems and access paths, so critical dependencies slip through.

Frequent implementation mistakes and how to avoid them

1. Mistake: treating RA-3(1) as a vendor questionnaire program.
   Fix: Keep questionnaires as an input, but require a risk decision memo that addresses the specific dependency and integration risk.

2. Mistake: no linkage to systems and architecture.
   Fix: Map third parties to systems, data, and privilege. If you cannot explain “what breaks or leaks if this supplier fails,” you cannot defend the risk rating.

3. Mistake: assessing only tier-1 vendors.
   Fix: For critical services, record known subprocessors/sub-tier providers and document how you track change notifications.

4. Mistake: evidence is scattered and non-repeatable.
   Fix: Standardize an assessment packet template and a single system of record. The best practice is to map RA-3(1) to the control owner, a written procedure, and recurring evidence artifacts. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source materials for this requirement, so this page does not cite enforcement outcomes. Operationally, RA-3(1) is still high-stakes because supply chain failures often surface as confidentiality breaches (third party compromise), integrity issues (tampered components), or availability events (critical provider outage). Your risk is compounded if you cannot show a documented assessment process and completed assessments for critical dependencies. ²

Practical 30/60/90-day execution plan

First 30 days (foundation and scope)

• Name the RA-3(1) control owner and approver for residual risk.
• Write the scope parameter statement (what gets assessed and what triggers reassessment). ¹
• Build the first-pass dependency inventory for your highest-impact systems.
• Publish the assessment template (method, scoring, required evidence, decision outcomes).

Days 31–60 (execute on critical dependencies)

• Triage and prioritize in-scope third parties/components/services by criticality and access.
• Complete assessments for the highest-risk dependencies first.
• Stand up a remediation workflow: findings to tickets, owners assigned, approvals recorded.
• Add a procurement and access gate for new in-scope onboarding (even if the gate is manual at first).

Days 61–90 (operationalize and harden)

• Extend coverage across remaining in-scope dependencies.
• Implement reassessment triggers in change management and vendor renewal workflows.
• Run an internal audit-style check: sample assessments, verify evidence, verify mitigations closed.
• Centralize evidence and mapping. If you are scaling beyond spreadsheets, set RA-3(1) up in Daydream with control ownership, procedures, and recurring evidence artifacts so assessments don’t reset each cycle. ¹

Frequently Asked Questions

Does RA-3(1) apply only to vendors, or also to open-source and cloud services?

It applies to supply chain risk, so treat third parties broadly: SaaS, cloud, managed services, and externally sourced components can all be in scope. Your scope parameter defines exactly what you assess, and auditors will expect it to match your real dependencies. ¹

What’s the minimum acceptable “assessment” artifact for RA-3(1)?

A written record that shows scope, evidence reviewed, inherent risk, residual risk, and a decision with approver. A questionnaire alone rarely shows the decision logic or the resulting actions. ¹

How do we handle subcontractors/subprocessors we can’t fully see?

Document what you know, require contractual change notifications where feasible, and record monitoring expectations for critical providers. The key is to show you considered sub-tier exposure as part of the supply chain risk assessment. ²

How often do we need to reassess supply chain risk?

Use triggers tied to change: new access, new data types, major service changes, renewals, or security incidents. Define the triggers in your procedure and apply them consistently. ¹

Who should approve residual supply chain risk acceptance?

Assign an approver with accountability for the impacted system and business outcome (often a system owner with security sign-off). Keep approval evidence with the assessment record so it is auditable. ¹

We have a vendor risk program already. What’s different for RA-3(1)?

RA-3(1) expects supply chain-specific thinking: dependency mapping to systems and components, sub-tier considerations, and outcomes that change procurement or architecture decisions. Map the requirement to an owner, a procedure, and recurring evidence artifacts so your existing program produces audit-ready proof. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5