RA-5(11): Public Disclosure Program

RA-5(11) requires you to establish a public reporting channel where external parties can submit vulnerability reports about your systems and components, and you must run it as an operational intake process, not a mailbox. To operationalize it quickly, publish a clear “Report a vulnerability” page, route reports into a tracked workflow, define triage/response ownership, and retain evidence that the channel works end to end. ¹

Key takeaways:

• RA-5(11) is satisfied by a public, discoverable vulnerability reporting channel tied to an internal triage workflow. ¹
• Auditors look for proof of operation: submissions received, triage decisions, and closure records tied to defined owners. ¹
• The fastest path is a scoped VDP-style intake (web form/email) integrated to your ticketing and vulnerability management process. ²

The ra-5(11): public disclosure program requirement is simple in wording and easy to fail in practice: you need a public channel that real people outside your organization can use to report vulnerabilities in your systems and components. “Public” means discoverable without a contract, support login, or insider knowledge, and “channel” means more than posting an email address with no process behind it. ¹

Compliance teams often inherit a security inbox, a generic support form, or a bug bounty link and assume that’s sufficient. Assessors typically push one level deeper: Who monitors it? How is a report authenticated and triaged? How do you prevent reports from getting lost? How do you ensure reports route to the right system owners, including for third-party-hosted components? ²

This page gives requirement-level implementation guidance you can execute quickly: scoping, ownership, intake design, triage workflow, communications, and evidence. If you need a tight control narrative and an assessment-ready evidence loop, treat RA-5(11) like a mini customer-facing incident intake program for vulnerabilities, with the same rigor you apply to internal vuln management. ¹

Regulatory text

Requirement (RA-5(11)): “Establish a public reporting channel for receiving reports of vulnerabilities in organizational systems and system components.” ¹

Operator interpretation (what you must do):

• Provide an externally accessible method for anyone to submit vulnerability information about systems you operate or components you own. ¹
• Ensure the channel actually receives reports and routes them into an internal process where they are tracked, triaged, and acted on. RA-5(11) is the “front door”; your existing vulnerability management program is the “back office.” ²

Plain-English interpretation (what “public disclosure program” means here)

RA-5(11) is not asking you to publish vulnerabilities. It is asking you to accept vulnerability reports from the public through a clear, documented channel. The term “Public Disclosure Program” is commonly implemented as a Vulnerability Disclosure Program (VDP)-style intake: a web page that explains what to report, how to report it, what the reporter can expect, and how you will coordinate remediation. ¹

A practical standard: if a security researcher lands on your homepage and searches “security” or “vulnerability,” they should find a reporting path that works without a support contract. If they submit a report, it should create a tracked record with a defined owner and a triage outcome. ²

Who it applies to (entity and operational context)

RA-5(11) commonly applies in these contexts:

• Federal information systems implementing NIST SP 800-53 controls. ¹
• Contractor systems handling federal data, including environments where you operate systems or components in scope for federal security requirements. ¹

Operationally, it applies to:

• Internet-facing applications, APIs, portals, and public websites.
• Corporate infrastructure that could be discovered externally (email, VPN, identity endpoints).
• Products or system components you distribute or manage, including where a third party hosts parts of the stack but you remain responsible for coordinating remediation. ²

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

Step 1: Define scope and ownership

1. Define “in scope” assets for public reporting (domains, apps, APIs, key systems, and major components). Keep the initial scope tight if needed, but make it explicit. ²
2. Assign a control owner (often Product Security, AppSec, or Security Operations) and a compliance owner (GRC) for evidence and periodic review. ¹
3. Define routing rules: which team owns triage by asset class (cloud, endpoints, applications, identity, third-party platforms). ²

Deliverable: a one-page RACI for intake, triage, communications, and closure.

Step 2: Stand up the public reporting channel

Minimum viable options that usually satisfy “public reporting channel”:

• A public web page “Report a vulnerability” plus a monitored security email address (e.g., security@company).
• A public web form that writes directly into your ticketing system.
• A platform-supported VDP intake, if it is publicly accessible and your workflow is documented. ¹

On the page, include:

• What to include in a report (affected URL/component, steps to reproduce, proof-of-concept details, impact, reporter contact).
• What not to do (avoid destructive testing; avoid accessing data not belonging to the reporter).
• How you will respond (acknowledgment and follow-up expectations).
• A safe harbor statement if your legal team supports it. If you cannot add safe harbor quickly, at least provide submission instructions and a commitment to review. ²

Step 3: Integrate intake into a tracked workflow

1. Create a ticket type: “External vulnerability report.”
2. Define required fields: reporter contact, asset, description, reproduction steps, attachments, initial severity, triage status, owner, dates, closure code.
3. Automate acknowledgment: auto-reply for email, or confirmation screen/email for web form.
4. Set escalation paths for credible reports affecting sensitive systems or high-risk components. ²

If your teams already run vulnerability management, reuse existing states (New → Triaged → Accepted → Fix in progress → Fixed → Verified → Closed), but tag “external source” so you can produce evidence quickly. ²

Step 4: Establish triage procedures (make them assessable)

Write a short SOP that answers:

• How you validate reports (repro steps, environment replication, logs, scanning confirmation).
• How you determine severity (your chosen rubric).
• How you handle third-party dependencies (coordinate with the third party, track comms, confirm fix).
• How you communicate with the reporter (what you will share and when). ¹

Keep it practical. Auditors accept lightweight documentation if it matches actual tickets.

Step 5: Train the operators and test the channel

• Train the team that will monitor the inbox/form and the team that will own technical triage.
• Send a test submission from an external email and confirm it becomes a ticket, routes to an owner, and can be closed with evidence. Retain the test record. ²

Step 6: Build the evidence loop (what you’ll show an assessor)

Map RA-5(11) to:

• Control owner
• Implementation procedure
• Recurring evidence artifacts (what you can export on demand) ¹

If you run Daydream for control management, store the control narrative, owner, SOP, and an evidence checklist so you can produce the same artifacts every assessment cycle without rebuilding the story.

Required evidence and artifacts to retain

Keep evidence that proves existence, public accessibility, and operation:

Channel existence and public access

• Screenshot/PDF of the public “Report a vulnerability” page (dated).
• URL and proof it is accessible without authentication (e.g., browser capture).
• Copy of the published reporting instructions. ¹

Process documentation

• Vulnerability reporting SOP (intake, triage, routing, communications).
• RACI/ownership list with current names/roles.
• Triage criteria or severity rubric reference (internal standard is fine). ²

Operational records

• Ticketing exports showing external vulnerability reports, status changes, assignment, and closure notes.
• Inbox monitoring evidence (shared mailbox access list, alerting rules, or on-call rotation notes).
• Example acknowledgments and reporter communications templates (sanitized). ²

Testing

• Periodic test submission record and resulting ticket lifecycle (sanitized). ²

Common exam/audit questions and hangups

Expect these questions:

• “Show me the public channel and the exact URL. Is it accessible without logging in?” ¹
• “Who monitors it, and how do you ensure coverage during holidays and staff changes?” ²
• “Demonstrate an end-to-end example from receipt to closure, with timestamps and approvals.” ²
• “How do you prevent reports from landing in spam or being treated as general support?” ²
• “What happens when the report implicates a third-party product or hosted component?” ²

Hangups that slow audits:

• A public email exists, but no tickets exist because nothing is tracked.
• Tickets exist, but they are mixed into general support with no way to filter external vulnerability submissions.
• Ownership is unclear, so assessors cannot identify who is accountable. ¹

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails RA-5(11)	Fix
Posting “security@” with no SOP	Assessors can’t see controlled operation	Publish an SOP and show ticket workflow evidence. 2
Channel requires login or support contract	Not meaningfully public	Provide a public web page and unauthenticated submission path. 1
Reports go to a single person	Creates gaps and lost reports	Use a shared mailbox or intake platform with role-based access and backup coverage. 2
No defined scope	You end up debating what “counts” during the audit	Publish scope on the page and in the SOP, then expand iteratively. 2
No closure criteria	Tickets linger, metrics are meaningless	Define closure codes: duplicate, not reproducible, accepted and fixed, third-party referred. 2

Enforcement context and risk implications

No public enforcement cases are provided in the source catalog for this requirement, so treat this as an assessment-readiness and operational resilience control rather than an enforcement-driven control in this write-up. ¹

Risk you are managing with RA-5(11):

• Time-to-awareness risk: external parties often discover issues before you do; without a channel, you learn late or not at all. ²
• Operational risk: reports arriving through informal channels (personal LinkedIn, random support tickets) get mishandled.
• Governance risk: inability to prove to assessors that your vulnerability program accepts external input, which can translate into control deficiencies. ¹

Practical execution plan (30/60/90 days)

You asked for speed. Here is a plan that maps to real work without pretending every organization has the same throughput.

First 30 days (stand up the minimum viable program)

• Publish a public vulnerability reporting page and a monitored channel (email or form). ¹
• Assign owners and document a short SOP for intake and triage. ²
• Integrate intake to ticketing with an “external vulnerability report” tag.
• Run a test submission from outside your environment and retain evidence. ²

By 60 days (make it reliable and auditable)

• Add routing rules by asset type and define escalation paths. ²
• Create reporter communication templates (ack, needs-more-info, accepted, closed).
• Build an evidence package: page capture, SOP, RACI, sample tickets. ¹
• In Daydream (or your GRC system), map RA-5(11) to the control owner, procedure, and recurring evidence artifacts so the next audit is pull-not-panic. ¹

By 90 days (operate it like a program)

• Conduct a tabletop walk-through of a high-impact vulnerability report and confirm cross-team handoffs.
• Add periodic operational checks (spam filtering review, mailbox access review, queue aging review).
• Expand scope if needed, based on what you can support with credible triage capacity. ²

Frequently Asked Questions

Does RA-5(11) require a bug bounty program?

No. The text requires a public reporting channel for vulnerability reports, not payment or a bounty structure. A simple public intake page and monitored channel can satisfy the requirement if it is operational. ¹

Can we meet RA-5(11) with a general “Contact Us” form?

Usually no for audit purposes, because it doesn’t clearly solicit vulnerability reports or route them into a defined triage workflow. If you use a form, label it for security/vulnerability reporting and connect it to a tracked process. ²

What counts as “public” in practice?

Public means an external party can find and use the channel without credentials, contracts, or insider routing. A published webpage with submission instructions is the cleanest proof. ¹

How do we handle vulnerabilities in third-party-hosted systems or SaaS components?

Accept the report through your channel, track it, and document coordination with the third party as part of the ticket record. Assessors mainly want to see ownership, action, and closure evidence. ²

What evidence is most persuasive to auditors?

A working public URL plus end-to-end ticket evidence from receipt through triage and closure is hard to argue with. Pair it with an SOP and an ownership matrix so the assessor can see governance, not heroics. ²

We rarely receive external vulnerability reports. How do we prove operation?

Run periodic test submissions from an external address and retain the resulting ticket trail. That demonstrates the channel works even if inbound volume is low. ²

Footnotes

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

2. NIST SP 800-53 Rev. 5