SA-15(10): Incident Response Plan

SA-15(10) requires you to make the developer of a system, component, or service provide an incident response plan, then ensure that plan is implemented and tested as part of delivery and ongoing operations. To operationalize it, bake IR-plan deliverables into contracts and acceptance criteria, run at least one evidence-backed test, and retain artifacts that prove it happened. ¹

Key takeaways:

• Your control objective is third-party accountability: the developer must provide the plan, and you must ensure it is implemented and tested. ¹
• “Tested” must produce audit-ready evidence (scenario, participants, results, corrective actions), not a slide deck.
• Treat the incident response plan as a deliverable tied to go-live and change acceptance, not a policy that sits in a binder.

The sa-15(10): incident response plan requirement sits in the System and Services Acquisition (SA) family, which means it is fundamentally a supply chain and delivery requirement, not only a security-operations requirement. The key operational nuance is in the verb sequence: you must require the developer to provide the plan, you must ensure it is implemented, and you must ensure it is tested. ¹

For a Compliance Officer, CCO, or GRC lead, this control usually fails for one of three reasons: contracts do not clearly obligate incident response deliverables; engineering treats the developer’s plan as separate from the organization’s incident response program; and “testing” is interpreted as informal discussion without evidence, remediation, or retest. SA-15(10) forces you to close each of those gaps with procurement language, delivery gates, and recurring proof.

This page gives you requirement-level implementation guidance you can put into a contract template, a system acceptance checklist, and an audit evidence plan. It also highlights audit hangups you should preempt, and the artifacts that make this control easy to defend during assessments.

Regulatory text

Requirement (excerpt): “Require the developer of the system, system component, or system service to provide, implement, and test an incident response plan.” ¹

What that means for an operator:

• Require the developer to provide a written incident response plan that covers the delivered system/component/service (not just the developer’s corporate IR policy). ¹
• Require implementation of that plan in the delivered environment. “Implemented” should translate to configured roles, communications paths, access, tooling, and runbooks that work in your operational reality. ¹
• Require testing of the plan and retain evidence. “Tested” must be demonstrable with artifacts that show scenario, execution, outcomes, and corrective actions. ¹

Plain-English interpretation

You are buying, commissioning, or accepting a system from a developer (internal dev team or external third party). SA-15(10) says: don’t accept the work unless the developer gives you an incident response plan for what they built, helps put it into practice, and proves it works by testing it. ¹

This requirement is easy to mis-scope. It is not limited to a generic “company IR plan.” It is about the specific thing being delivered: a system, a component, or a service. The plan has to be actionable for responders who will actually handle incidents involving that deliverable.

Who it applies to

Entities

• Federal information systems and programs adopting NIST SP 800-53 controls. ²
• Contractor systems handling federal data where NIST SP 800-53 requirements flow down through contracts or program requirements. ¹

Operational contexts where SA-15(10) shows up

• New system development or major enhancement releases where a development team hands off to operations.
• Acquisition of a system/service that includes development work (custom software, configured platforms, managed services with bespoke workflows).
• Integration-heavy components (identity, logging, payment processing, EHR modules) where incident response depends on vendor-side actions, logs, and escalation paths.

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

1) Set the control owner and scope boundary

1. Assign an accountable owner (often GRC with shared ownership across Security Operations and Procurement).
2. Define which “developers” fall under the requirement:
   • Internal product teams.
   • External third parties developing custom code.
   • Service providers delivering a configured system service.
3. Define what “system/component/service” means in your environment (tie it to your system inventory and authoritative architecture diagrams).

Operational tip: Put SA-15(10) into your intake workflow. If a purchase request or project charter includes build/configure/customize work, it triggers the SA-15(10) deliverables.

2) Convert the requirement into contract and acceptance language

Add explicit obligations to your contract/SOW/MSA exhibits and your system acceptance checklist. Your language should force three deliverables:

A. Provide: Developer must deliver an incident response plan specific to the deliverable.

• Minimum content you should require (practical, not academic):
  • Incident categories relevant to the deliverable (availability, integrity, unauthorized access, data spill).
  • Roles and responsibilities split between you and the developer/third party.
  • Escalation paths, contact methods, and decision authority (who can declare an incident; who approves customer notification drafts).
  • Forensics/log access expectations: what logs exist, retention assumptions, and how responders get access under time pressure.
  • Containment and recovery runbooks (how to isolate, rollback, rotate secrets, restore service).
  • Dependencies and upstream/downstream impacts (what breaks if you disable an integration).

B. Implement: Developer must assist in operationalizing the plan in the delivered environment.

• Examples of “implemented” items you can verify:
  • On-call rotation and escalation rules exist and are reachable.
  • Logging and alerting prerequisites for incident handling are configured.
  • Access paths for emergency response are set up (break-glass accounts, secure channels, ticketing queues).

C. Test: Developer must participate in at least one test and deliver test results and remediation actions.

• Specify that a “test” means a table-top exercise or technical simulation with documented outcomes and tracked corrective actions.

All three elements map directly to the regulatory verbs and make assessments straightforward. ¹

3) Align the developer’s plan with your enterprise incident response program

Do a short mapping exercise:

• Map the developer’s incident severity definitions to your enterprise severity scale.
• Align notification thresholds and timelines to your internal requirements (don’t create conflicting clocks).
• Ensure your Security Operations tools can support the plan (ticketing, paging, case management, evidence storage).

Common hangup: The developer supplies a plan that assumes they own the entire response. Your environment may require your SOC to triage first, then invoke the developer. Fix this by requiring a RACI-style split of responsibilities.

4) Run a test that produces defensible evidence

Pick a scenario tied to real failure modes of the delivered system. Examples:

• Compromised service account used by the component.
• Unauthorized change to infrastructure-as-code for the service.
• Data spill into a log sink or analytics platform.

Minimum test outputs you should require:

• Scenario narrative and objectives.
• Participant list (include the developer and your responders).
• Timeline of actions taken (who did what, when).
• Gaps found (missing logs, broken escalation path, unclear authority).
• Corrective action plan with owners and due dates.
• Retest or validation notes once fixes are complete.

This is the evidence auditors expect when they ask whether the plan was “tested.” ¹

5) Operationalize as a recurring control, not a one-time project

Tie SA-15(10) to:

• Release management: new major releases require confirming the plan is still accurate.
• Third-party reviews: renewals and major changes trigger re-validation.
• Incident postmortems: when the system has an incident, update the plan and record the change.

Where Daydream fits naturally: Daydream can track SA-15(10) as a requirement with a named control owner, embed the implementation procedure into your workflow, and schedule recurring evidence collection so you are not rebuilding the story at audit time. That aligns to the recommended best practice: map SA-15(10) to control owner, implementation procedure, and recurring evidence artifacts. ¹

Required evidence and artifacts to retain

Keep artifacts that prove each verb: provide, implement, test. ¹

Evidence checklist (audit-ready)

• Contract/SOW clauses requiring an incident response plan deliverable, implementation support, and testing participation.
• Developer incident response plan (versioned, system-specific).
• Implementation proof
  • Configuration screenshots/exports for paging/escalation rules.
  • Access provisioning records for responder roles.
  • Logging/alerting configuration baselines relevant to incident handling.
• Test package
  • Exercise plan and scenario.
  • Attendance and roles (including developer participation).
  • After-action report.
  • Corrective action tickets and closure evidence.
• Change control records showing plan updates after releases or incidents.

Common exam/audit questions and hangups

Auditors and assessors tend to ask:

• “Show me where the developer is required to provide the plan.” (They want contract language, not an email thread.)
• “How do you know the plan is implemented in the current environment?” (They want operational proof, not a PDF.)
• “When was the plan tested, and what changed because of the test?” (They want a real after-action report with remediation.)
• “Does the plan cover the component/service in scope, or is it generic corporate guidance?” (Scope mismatch is a frequent failure.)

Hangups to preempt:

• Missing developer participation: If the test was run without the developer, document why and require participation going forward.
• Plan exists but is stale: If the system changed materially, the plan must be updated and revalidated.
• No linkage to system boundary: Plans that do not reference the actual architecture, data flows, or dependencies look superficial.

Frequent implementation mistakes and how to avoid them

1. Accepting a generic “IR policy” instead of a system-specific plan.
   Fix: Require the plan to reference the deliverable’s architecture, logging sources, and escalation responsibilities.

2. Treating implementation as “we filed it in GRC.”
   Fix: Define implementation checks (contacts, access, tools, runbooks) and make them go-live gates.

3. Running an exercise that produces no corrective actions.
   Fix: Require an after-action report and ticketed remediation. If nothing changes, the test often wasn’t real.

4. Not retaining evidence in one place.
   Fix: Store artifacts in a single control record with clear naming (plan version, test date, closure status). Daydream-style evidence mapping makes this repeatable. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat SA-15(10) primarily as an assessment and contractual compliance risk, not a control with a specific enforcement history in this dataset.

Risk outcomes you should plan for:

• Slower containment and recovery because escalation paths and responsibilities are unclear between you and the developer.
• Inability to meet program or contract expectations during a federal assessment because you cannot prove the plan was implemented and tested. ¹
• Third-party dependency risk: if the developer controls critical logs or actions, your response will stall without pre-arranged access and tested procedures.

Practical 30/60/90-day execution plan

First 30 days (establish the requirement mechanics)

• Assign control owner and identify in-scope systems/components/services with active developers.
• Update contract templates/SOW exhibits to require provide/implement/test deliverables. ¹
• Create an acceptance checklist item: “SA-15(10) IR plan received, implemented evidence attached, test scheduled or completed.”

Days 31–60 (collect plans and make them real)

• Collect developer IR plans for highest-risk or most critical deliverables first.
• Run a working session with Security Ops + engineering + the developer to align severity, communications, and access.
• Produce an implementation evidence pack for each in-scope deliverable (contacts, access, logging/alerting prerequisites).

Days 61–90 (test, remediate, make it repeatable)

• Execute at least one evidence-backed test per priority deliverable (table-top or technical simulation).
• Track corrective actions to closure and update the plan version.
• Stand up a recurring evidence cadence in your GRC system (Daydream or equivalent): plan versioning, test schedule, and artifact retention mapped to SA-15(10). ¹

Frequently Asked Questions

Does SA-15(10) apply to internal development teams, or only external vendors?

It applies to “the developer,” which can be internal or a third party, as long as they are developing the system, component, or service in scope. Operationally, treat internal teams like suppliers with required deliverables and evidence. ¹

What counts as “tested” for the incident response plan?

A table-top exercise can count if it is documented and results in tracked corrective actions. A technical simulation can be stronger evidence if it validates logging, access, and containment steps in a realistic way. ¹

We have an enterprise incident response plan already. Why do we need a developer plan?

Your enterprise plan usually sets governance. SA-15(10) expects a system/component/service-specific plan that covers operational details the developer knows best, then proves it works through implementation and testing. ¹

What if the developer refuses to share details due to proprietary information?

Put boundaries in the contract: they can protect proprietary content while still providing actionable response steps, escalation contacts, and evidence access methods. If they cannot support incident response in practice, treat it as a material risk in procurement.

How do we show “implementation” without exposing sensitive security configurations to auditors?

Provide controlled evidence: redacted screenshots, configuration exports with secrets removed, and access control records showing responder roles exist. Pair that with a narrative that ties evidence to the plan sections.

Can we centralize this in GRC, or does it have to live in engineering tools?

Centralize the control record and evidence map in GRC, but keep operational runbooks where responders work (ticketing, on-call, repositories). The audit story is strongest when the GRC record points to immutable evidence and versioned operational artifacts.

Footnotes

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

2. NIST SP 800-53 Rev. 5