SA-24: Design For Cyber Resiliency

SA-24: Design for Cyber Resiliency requires you to build resiliency into system design decisions (not retrofit it later) so systems can anticipate, withstand, recover from, and adapt to adverse cyber conditions. Operationalize it by defining resiliency design objectives, embedding them into architecture and engineering workflows, and retaining repeatable evidence that those objectives are implemented and tested. ¹

Key takeaways:

• Treat SA-24 as an engineering requirement: resiliency objectives must show up in architecture, backlog items, and acceptance criteria.
• Map SA-24 to a control owner, a standard procedure, and recurring evidence artifacts to stay assessment-ready. ¹
• Your fastest audit win is a traceable chain from “resiliency goal” → “design pattern” → “implemented controls” → “test results.”

The sa-24: design for cyber resiliency requirement is one of the easiest controls to “say yes to” and one of the hardest to prove under assessment pressure. The requirement is not asking for a single tool or a one-time project. It expects your organization to intentionally design systems, components, and services so they can operate through disruptive cyber conditions, degrade safely, and recover predictably. ²

For a Compliance Officer, CCO, or GRC lead, the practical challenge is translating “design for resiliency” into artifacts engineers already produce: reference architectures, threat models, system security plans, design reviews, change tickets, test evidence, and incident learnings. If you cannot point to where resiliency requirements are defined, who approves deviations, and how you verify that design choices work in real failure scenarios, assessors will treat SA-24 as aspirational.

This page gives requirement-level implementation guidance you can implement quickly: who must be involved, what to change in the SDLC, what evidence to retain, and how to pass the most common audit questions without turning SA-24 into a paperwork exercise. ¹

Regulatory text

NIST SP 800-53 Rev. 5 (SA-24) excerpt: “Design organizational systems, system components, or system services to achieve cyber resiliency by:” ¹

What the operator must do with this text

Because the excerpt is intentionally high-level, your job is to make it actionable in your environment by:

1. Defining what “cyber resiliency” means for your systems (measurable design objectives tied to mission/business impact).
2. Converting objectives into design requirements and patterns (architecture decisions engineers must follow).
3. Embedding those requirements into delivery workflows (design reviews, change management, release gates).
4. Proving the design works under stress (test evidence tied to realistic failure and attack conditions).
5. Retaining evidence that shows the above is repeatable and governed, not ad hoc. ²

Plain-English interpretation (what SA-24 expects)

SA-24 expects that resiliency is a first-class design constraint. A resilient system:

• keeps critical functions running (even at reduced capacity),
• fails in controlled ways,
• contains blast radius,
• restores service predictably,
• and improves based on real incidents.

In audit terms, assessors look for intentional design choices (segmentation, redundancy, safe defaults, isolation, immutable infrastructure patterns, dependency management) and governance (who approves exceptions; how you validate resiliency claims). ²

Who it applies to (entity and operational context)

SA-24 applies wherever you build, integrate, or operate systems subject to NIST SP 800-53 Rev. 5 expectations, especially:

• Federal information systems (agency-operated environments). ¹
• Contractor systems handling federal data (including cloud services, managed services, and integrators supporting federal missions). ¹

Operationally, it applies across:

• new system builds and major upgrades,
• shared services and platforms (IAM, logging, CI/CD, container platforms),
• externally provided system services and critical third parties whose services affect your availability and recovery outcomes.

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

Step 1: Assign ownership and define scope

Create a simple SA-24 control record that answers:

• Control owner: usually Head of Architecture, Engineering, or Security Engineering; GRC coordinates evidence.
• In-scope systems: start with mission-critical services, regulated systems, and shared platforms.
• Design touchpoints: architecture review board (ARB), security design review, change advisory board, SDLC gates.

Minimum expectation to operationalize quickly: map SA-24 to an owner, an implementation procedure, and recurring evidence artifacts. ¹

Step 2: Define cyber resiliency design objectives per system tier

Write 5–10 objectives that fit your environment and can be tested. Examples:

• “Service continues degraded operation if a non-critical dependency fails.”
• “Compromise of a single workload cannot access secrets for other workloads.”
• “Recovery actions are executable with pre-approved runbooks.”

Keep them aligned to business impact analysis and incident response priorities. Store them in a system-level “Resiliency Requirements” section in the SSP (or equivalent system documentation). ²

Step 3: Convert objectives into approved design patterns and guardrails

For each objective, define:

• Approved patterns: e.g., multi-zone deployment pattern, queue-based load shedding, token scoping model, isolation boundaries, backup/restore pattern.
• Guardrails: policy-as-code rules, baseline configurations, reference Terraform modules, golden images.
• Exception process: who can approve deviating designs, required compensating controls, and expiration of exceptions.

This is where SA-24 becomes enforceable: engineers should be able to choose from patterns, not interpret the control from scratch.

Step 4: Embed SA-24 into engineering workflows (make it hard to skip)

Add SA-24 checkpoints to existing rituals:

• Architecture/design review: require a short resiliency appendix (dependencies, failure modes, isolation boundaries, recovery strategy).
• Threat modeling: include “resiliency-abuse cases” (e.g., dependency exhaustion, token theft, ransomware-style data impact).
• Change management: require verification that changes do not reduce resiliency objectives, or document the exception.
• Release readiness: require evidence of resiliency testing or validation for material changes.

Practical tip: if you already have SDLC security gates, add SA-24 questions to that same template so teams don’t treat it as a separate compliance exercise.

Step 5: Test and validate resiliency claims

Assessors will ask how you know the design works. Maintain a program of:

• Scenario-based tests: dependency outage, region/zone loss, credential compromise, log pipeline failure, key rotation failure.
• Tabletop exercises: focused on recovery decisions and comms.
• Post-incident learning loop: feed incidents into updated design patterns and requirements.

Your goal is not perfect uptime. Your goal is predictable behavior under stress and evidence that you verify it.

Step 6: Vendor/third-party alignment (where it matters)

If critical services are provided by a third party (cloud, SaaS, managed service, data provider), capture:

• shared responsibility boundaries that affect recovery and isolation,
• third-party SLAs and support escalation paths,
• dependency mapping so you know which third-party failures break which resiliency objectives.

SA-24 is still your requirement even if a third party hosts the service. Treat this as third-party design due diligence, not a checkbox.

Step 7: Evidence packaging for audits (make it reusable)

Build an SA-24 evidence folder per system (or per platform) with a consistent index. Daydream can help here by standardizing the control-to-evidence mapping so you do not reassemble the same proof every audit cycle. ¹

Required evidence and artifacts to retain

Maintain artifacts that show intent, implementation, and validation:

Governance and intent

• SA-24 control statement (owner, scope, procedure, evidence cadence). ¹
• Resiliency requirements per system tier (SSP section, engineering standard, or architecture policy).

Design and implementation

• Reference architectures and diagrams showing isolation boundaries and dependencies.
• Architecture review records (tickets, minutes, approvals) including resiliency decisions.
• Exception register with approvals, compensating controls, and review dates.
• Configuration baselines / infrastructure-as-code modules supporting resiliency patterns.

Validation

• Test plans and results for failure scenarios (screenshots, reports, pipeline logs).
• Tabletop exercise notes and corrective actions.
• Incident postmortems with tracked remediation items tied back to design patterns.

Common exam/audit questions and hangups

Expect these questions:

1. “Show me where cyber resiliency is defined as a requirement.”
   Hangup: teams point to DR docs only. Fix: maintain system-level resiliency objectives and design requirements tied to engineering artifacts. ²

2. “How do you ensure new designs comply?”
   Hangup: reliance on informal tribal knowledge. Fix: ARB/security design review templates with required resiliency fields and a documented exception path.

3. “Prove it works.”
   Hangup: aspirational diagrams without tests. Fix: scenario test evidence and post-change validation.

4. “What about third-party dependencies?”
   Hangup: unclear shared responsibility. Fix: dependency map plus third-party support and recovery assumptions documented.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Treating resiliency as backups only.
  Avoidance: include containment, safe failure, dependency failure handling, and recovery automation in requirements, not just restore capability.

• Mistake: One generic policy for all systems.
  Avoidance: tier systems and set different objectives for critical vs. non-critical services.

• Mistake: No exception discipline.
  Avoidance: formal exception register with compensating controls and re-approval triggers.

• Mistake: Evidence lives in people’s heads.
  Avoidance: pre-defined evidence list and recurring collection cadence; map SA-24 to artifacts early. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the available source catalog for this requirement, so you should treat SA-24 primarily as an assessment and authorization risk: failing SA-24 typically shows up as control weaknesses, POA&Ms, delayed ATO decisions, and elevated operational risk after real incidents. ²

Practical 30/60/90-day execution plan

First 30 days (establish control and scope)

• Name SA-24 control owner and backups; document RACI.
• Identify in-scope systems and “critical services” list.
• Publish a one-page SA-24 procedure: where requirements live, review gates, evidence list. ¹
• Add a resiliency section to your architecture review template.

Days 31–60 (standardize patterns and evidence)

• Define resiliency objectives for each system tier; pilot on one critical system.
• Create 3–5 approved resiliency design patterns with diagrams and implementation notes.
• Stand up an exception register and approval workflow.
• Build the SA-24 evidence index and populate it for the pilot system.

Days 61–90 (validate and scale)

• Run scenario-based resiliency tests for the pilot system; retain results.
• Add SA-24 checks to change/release processes for material changes.
• Expand to additional systems; prioritize shared platforms and high-dependency services.
• Operationalize recurring evidence collection (quarterly or per-release, based on how your org ships changes).

Frequently Asked Questions

Does SA-24 require specific technologies (multi-region, active-active, chaos engineering)?

SA-24 requires designing for cyber resiliency, not adopting specific tools. Choose patterns that meet your resiliency objectives and prove they work with test evidence. ²

How do I “prove” a design control in an audit?

Provide a traceable chain: documented resiliency objectives, design review records showing decisions, implemented configurations or code, and validation results from scenario tests. Assessors want repeatability, not one-off heroics. ²

Who should own SA-24: Security, Engineering, or GRC?

Engineering or Architecture should own implementation because SA-24 is a design requirement; Security provides standards and review; GRC coordinates governance and evidence. Document the split explicitly to avoid gaps. ¹

We use many third parties. How far does SA-24 extend?

It extends to system services you depend on for critical functions and recovery assumptions. Document shared responsibility boundaries and integrate third-party failure scenarios into your dependency map and tests.

What’s the smallest viable implementation that still passes an assessment?

A defined owner, a documented procedure, a set of resiliency objectives for at least one critical system, evidence of design review enforcement, and at least one round of resiliency validation evidence. ¹

How can Daydream help with SA-24 operationalization?

Daydream is most valuable for control-to-evidence mapping and audit-ready packaging: assign ownership, standardize procedures, and keep recurring artifacts tied to SA-24 so you do not rebuild evidence every cycle. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5