SA-2: Allocation of Resources

SA-2 requires you to define the system’s high-level security and privacy requirements early, during mission and business process planning, and then fund and staff the work to meet them. Operationalize it by embedding security/privacy requirements into your intake and planning gates (new systems, major changes, new third parties), assigning owners, and retaining planning-to-requirement evidence. ¹

Key takeaways:

• SA-2 is a planning-and-resourcing control: requirements must be set before design and procurement decisions lock in risk.
• Your “pass” condition is traceability: mission/business need → high-level security/privacy requirements → funded plan → implemented controls.
• The fastest path is a repeatable intake workflow with clear RACI, templates, and a small evidence set you can produce on demand.

The sa-2: allocation of resources requirement is commonly misunderstood as a budgeting control. In practice, assessors look for something more concrete: did you determine the high-level information security and privacy requirements for the system or service during mission and business process planning, before you committed to architecture, timelines, and third-party contracts? ¹

For a CCO or GRC lead, SA-2 is a forcing function that prevents “security as an afterthought” by making security and privacy requirements a prerequisite input to planning decisions. You operationalize it by creating a standard method to (1) define high-level requirements early, (2) assign accountable owners to carry them into design and acquisition, and (3) show evidence that this happened for each in-scope system or system service.

This page gives requirement-level implementation guidance you can execute quickly: who is in scope, what artifacts satisfy the control, a step-by-step workflow, and the audit questions you should be ready to answer. It assumes you are aligning to NIST SP 800-53 Rev. 5 in a federal system context or as a contractor handling federal data. ²

Regulatory text

Control requirement (excerpt): “Determine the high-level information security and privacy requirements for the system or system service in mission and business process planning;” ¹

What the operator must do

You must make security and privacy requirements an explicit output of mission/business planning for each system or system service. “High-level requirements” means statements that guide design and acquisition choices (for example, authentication strength, encryption needs, audit logging, privacy data handling boundaries), not low-level technical settings.

Your implementation should prove three things:

1. Timing: requirements were determined during planning, not after deployment.
2. Scope: requirements cover both information security and privacy where applicable.
3. Actionability: requirements are carried into delivery (architecture, acquisition, backlog, milestones) with assigned ownership and resourcing.

Plain-English interpretation

SA-2 says: before you build, buy, or materially change a system, decide what security and privacy outcomes the business process requires, then plan the work and resources to achieve them. If you cannot show that the requirements were defined early and used to drive decisions, you will struggle to defend the control in an assessment.

A simple test: if the program team can start procurement or build work without a security/privacy requirements snapshot, SA-2 is not operational.

Who it applies to (entity and operational context)

SA-2 applies where you use NIST SP 800-53 as your control baseline, including:

• Federal information systems and programs inheriting federal security requirements. ²
• Contractor systems handling federal data where contractual or program requirements flow down NIST-aligned expectations. ¹

Operationally, apply SA-2 to:

• New systems or system services (including SaaS and cloud services).
• Major changes (new data types, new integrations, new identity model, moving to a new hosting environment).
• New third parties that process, store, or can access sensitive data in the system context.

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

Step 1: Define “planning gate” triggers and ownership

Create explicit triggers that require an SA-2 requirements determination:

• New system/service intake
• Architectural “go/no-go” review
• Procurement request for third-party services
• Major change request

Assign a single accountable owner for SA-2 execution per system (often the system owner or product owner), with GRC as the process owner. Document this in a RACI.

Practical tip: Put SA-2 into your existing intake tooling (ticketing, PPM, or procurement workflow). If the work happens in email, evidence will be inconsistent.

Step 2: Standardize a “High-Level Security & Privacy Requirements” template

Use a short template that teams can complete during planning. Keep it outcome-focused and reviewable. Minimum sections:

• System/service purpose and mission/business process supported
• Data types and privacy relevance (PII, sensitive categories, retention expectations)
• Security objectives (confidentiality, integrity, availability needs)
• Identity and access requirements (who, how, privileged access boundaries)
• Logging/auditability expectations
• Encryption requirements (in transit/at rest expectations)
• Third-party dependencies and shared responsibility notes
• Regulatory/contractual drivers (if any)
• Assumptions and open questions (with owners)

This template is your primary SA-2 artifact because it shows the “determination” happened during planning. ¹

Step 3: Run a cross-functional requirements review

Hold a lightweight review meeting (or asynchronous approval) with:

• System owner / product
• Security engineering or security architect
• Privacy (or privacy counsel/lead)
• GRC (control process owner)
• Procurement/vendor management when a third party is involved

Output: approved requirements snapshot, plus a short decision log for any exceptions or deferrals.

Step 4: Convert high-level requirements into funded work

SA-2 is named “Allocation of Resources” because requirements without resources fail in delivery. Translate requirements into:

• Architecture epics or design constraints
• Implementation backlog items with owners
• Procurement requirements (security addendum, contractual requirements, SLA/security obligations)
• Milestones in the project plan

Maintain traceability from the requirements snapshot to delivery artifacts. You do not need perfect tooling; you need a consistent link (ID, ticket references, or a requirements register).

Step 5: Map SA-2 to a control owner, procedure, and recurring evidence

Make SA-2 assessable:

• Control owner: role and named backup
• Procedure: the intake gate, template, review, and traceability steps
• Recurring evidence: what you capture each time and where it is stored

This maps directly to the recommended best practice: “Map SA-2 to control owner, implementation procedure, and recurring evidence artifacts.” ¹

Where Daydream fits naturally: If you manage many systems and third parties, Daydream can keep SA-2 from turning into a spreadsheet exercise by tracking the owner, the procedure, and the evidence set per system, then producing an audit-ready packet quickly.

Step 6: Define exception handling (and keep it rare)

Create an exception path for urgent initiatives. Requirements:

• Business justification
• Compensating controls
• Time-bound remediation plan
• Explicit approval from the accountable risk owner

Auditors will accept exceptions only if they are controlled and evidenced. Untracked “temporary” gaps become chronic control failures.

Required evidence and artifacts to retain

Keep evidence that proves timing, content, and follow-through:

Core SA-2 evidence ¹:

• Completed high-level security & privacy requirements snapshot (dated)
• Approval record (meeting minutes, sign-off in ticket, or workflow approval)
• Project plan or intake record showing requirements were produced during planning
• Traceability links: requirements → architecture/backlog/procurement artifacts
• RACI or control ownership assignment for SA-2
• Exception records (if any), with approvals and remediation tracking

Storage expectation: Central repository with consistent naming and retention rules. Assessments fail when evidence is scattered across teams.

Common exam/audit questions and hangups

Be ready for these:

1. “Show me where security and privacy requirements were determined during planning for System X.” Provide the snapshot and the dated intake record. ¹
2. “How do you ensure this happens for every new system or major change?” Show triggers, workflow gates, and ownership.
3. “How do requirements influence procurement of third parties?” Show procurement checklist, contract security requirements, or security review gating.
4. “Where is privacy addressed?” Point to data type identification, collection/use constraints, retention, and disclosure boundaries in the template.
5. “How do you know requirements were implemented?” Show traceability to backlog items, architecture decisions, and completion evidence.

Typical hangup: teams provide a risk assessment or a security plan created late in the lifecycle, but cannot show early planning outputs tied to mission/business needs.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Treating SA-2 as “budget exists” without requirements	The control text is about determining requirements during planning. 1	Require a requirements snapshot as a gate before design/procurement.
Only security, no privacy	The requirement explicitly includes privacy. 1	Add privacy sections to the template and require privacy review for relevant systems.
Evidence lives in slide decks with no date/approval	Hard to prove timing and accountability	Use a controlled template with workflow approvals and immutable timestamps.
No traceability to delivery	Requirements become aspirational	Require ticket references and backlog mapping as part of completion.
One-off heroics by GRC	Doesn’t scale, breaks during staffing changes	Put process ownership in GRC, execution ownership in system teams, and automate reminders/evidence collection where possible (Daydream or equivalent).

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for SA-2. From an operational risk perspective, SA-2 failures usually surface as:

• Security controls added late, increasing delivery risk and cost.
• Privacy gaps discovered after data collection starts, forcing rework and restricting business operations.
• Weak third-party contract requirements because security/privacy needs were never articulated during procurement planning.

For federal and federal-adjacent environments, SA-2 gaps can also cascade into authorization and assessment findings because you cannot demonstrate that security/privacy requirements were defined as part of system planning. ²

Practical 30/60/90-day execution plan

First 30 days (stand up the mechanism)

• Name the SA-2 control owner and backups; publish RACI for system owners, security, privacy, procurement.
• Define triggers: “new system,” “major change,” and “new third party in scope.”
• Publish a one-page high-level security & privacy requirements template.
• Choose the system of record for evidence (GRC tool, document repository, or Daydream).

Days 31–60 (run it on real work)

• Pilot the SA-2 gate with a small set of active initiatives (new system + major change + third party procurement).
• Hold the cross-functional review, capture approvals, and create traceability links to delivery work items.
• Add an exception path with required fields and approval routing.

Days 61–90 (scale and make it audit-ready)

• Roll the gate into intake/procurement workflows so teams cannot bypass it.
• Build an “audit packet” view per system: requirements snapshot + approvals + traceability + exceptions.
• Train system owners and procurement on how SA-2 affects planning and third-party contracting.
• Run an internal spot-check: pick a sample of systems/changes and verify evidence completeness and timing.

Frequently Asked Questions

Do we need a full System Security Plan (SSP) to satisfy SA-2?

SA-2 asks for high-level security and privacy requirements determined during mission/business planning, not a full SSP. A good SSP can support SA-2, but you still need evidence the requirements were defined early. ¹

What counts as “high-level” security and privacy requirements?

Statements that constrain design and procurement decisions, like access control approach, logging expectations, encryption needs, and privacy data handling boundaries. Avoid low-level configuration details; those belong later in engineering standards.

How do we apply SA-2 to SaaS or other system services we don’t build?

Treat the SaaS as the “system service” and document requirements that must be met via vendor capabilities and contract terms. Keep traceability from requirements to due diligence results and contractual obligations. ¹

Who should approve the SA-2 requirements snapshot?

The system owner should be accountable, with security and privacy providing review and sign-off based on your governance model. If procurement is involved, include them so requirements flow into the third-party contracting process.

What’s the minimum evidence an auditor will accept?

A dated requirements snapshot tied to a planning artifact (intake/project record), plus an approval record and traceability to implementation or procurement actions. Missing timestamps and missing ownership are the common failure points.

We have many small changes. Do all of them trigger SA-2?

No. Define “major change” triggers that reflect changes in data sensitivity, exposure, identity model, integrations, or third-party access. Document the trigger criteria so you can explain why a change did or did not require SA-2 processing.

Footnotes

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

2. NIST SP 800-53 Rev. 5