Third Party Risk Register Template

Your vendor ecosystem generates hundreds of risk data points across DDQs, security questionnaires, and compliance certificates. Without a centralized risk register, critical vulnerabilities hide in spreadsheet silos while your team wastes hours generating executive reports.

A properly structured third-party risk register transforms scattered vendor data into risk intelligence. It connects vendor criticality ratings with actual control deficiencies, tracks remediation progress, and flags concentration risks before they trigger regulatory scrutiny.

For TPRM managers juggling 50+ vendors, the register becomes your single source of truth. It answers the board's questions about supply chain resilience, satisfies auditor requests for vendor oversight documentation, and identifies which vendors need immediate attention versus annual reviews.

The difference between teams drowning in assessments and those running efficient TPRM programs? A risk register that actually reflects how vendors impact your business operations, not just checkbox compliance.

Core Components of a Third-Party Risk Register

Vendor Profile Data

Start with foundational vendor information that drives risk tiering decisions:

Business Context

• Service category (SaaS, professional services, infrastructure)
• Data classification level (PII, PHI, financial records, IP)
• Geographic locations and data residency
• Contract value and term length
• Business owner and relationship manager

Criticality Scoring Assign numerical scores (1-5) based on:

• Revenue impact if vendor fails
• Number of critical processes supported
• Data volume and sensitivity
• Substitutability (sole source vs. multiple options)
• Recovery time objective (RTO) requirements

Risk Assessment Tracking

Your register must capture assessment lifecycle data:

Assessment Status

• Initial assessment date
• Latest review date
• Next scheduled review
• Assessment type (full DDQ, focused review, continuous monitoring)
• Completion percentage
• Outstanding evidence requests

Risk Scoring Matrix

Risk Domain	Inherent Risk	Control Effectiveness	Residual Risk
Information Security	High (4)	Moderate (3)	Moderate (2)
Privacy/GDPR	Critical (5)	Strong (4)	Low (1)
Business Continuity	Moderate (3)	Weak (2)	High (4)
Financial Viability	Low (2)	Strong (4)	Low (1)
Compliance	High (4)	Moderate (3)	Moderate (2)

Control Mapping Framework

Map vendor controls to your regulatory requirements:

SOC 2 Trust Service Criteria

• Security: Access controls, encryption, vulnerability management
• Availability: SLA performance, incident response, backup procedures
• Processing Integrity: Data validation, error handling
• Confidentiality: Data classification, retention, disposal
• Privacy: Consent management, data subject rights, breach notification

ISO 27001 Control Families Track vendor alignment with Annex A controls:

• A.15: Supplier relationships
• A.13: Communications security
• A.12: Operations security
• A.18: Compliance

Evidence Collection Repository

Document control validation:

Evidence Types

• SOC 2 Type II reports (annual)
• ISO 27001 certificates (3-year cycle)
• Penetration test summaries (annual)
• Business continuity test results (semi-annual)
• Insurance certificates (annual)
• Financial statements (annual/quarterly for critical vendors)

Evidence Metadata

• Document type and title
• Coverage period
• Expiration date
• Exceptions noted
• Review status
• Storage location/link

Industry-Specific Applications

Financial Services Risk Register Requirements

FFIEC guidance mandates specific elements:

Concentration Risk Tracking

• Percentage of critical operations per vendor
• Geographic concentration metrics
• Technology stack dependencies
• Fourth-party reliance indicators

Regulatory Mapping

• GLBA Safeguards Rule compliance
• NYDFS Cybersecurity Regulation (23 NYCRR 500)
• OCC Bulletin 2013-29 requirements
• PCI DSS for payment processors

Healthcare Vendor Risk Elements

HIPAA-covered entities need additional fields:

Business Associate Tracking

• BAA execution date
• PHI access level
• Encryption standards verification
• Breach notification procedures
• HITECH compliance attestation

Medical Device Vendors

• FDA cybersecurity compliance
• Software bill of materials (SBOM)
• Patch management SLAs
• Clinical risk assessment scores

Technology Sector Considerations

SaaS and technology companies focus on:

API Security

• Authentication methods
• Rate limiting controls
• API versioning strategy
• Webhook security

Development Security

• SAST/DAST evidence
• Secure SDLC documentation
• Open source vulnerability management
• Container security practices

Implementation Best Practices

Risk Tiering Methodology

Implement consistent tiering logic:

Tier 1: Critical Vendors

• Access to production data
• Single points of failure
• Regulatory reporting dependencies
• Revenue impact > $1M annually

Tier 2: High-Risk Vendors

• Limited production access
• Replaceable with effort
• Compliance attestation required
• Revenue impact $100K-$1M

Tier 3: Medium/Low Risk

• No production access
• Standard services
• Minimal compliance requirements
• Revenue impact < $100K

Assessment Frequency Guidelines

Vendor Tier	Full Assessment	Focused Review	Continuous Monitoring
Critical	Annual	Quarterly	Real-time alerts
High	18 months	Semi-annual	Weekly scans
Medium	24 months	Annual	Monthly checks
Low	36 months	As needed	Quarterly updates

Automation Opportunities

Reduce manual effort through:

Data Integration Points

• Contract management systems for renewal dates
• GRC platforms for control testing results
• Vulnerability scanners for security findings
• Financial data providers for viability scores

Workflow Automation

• Assessment scheduling based on risk tiers
• Evidence expiration notifications
• Escalation rules for overdue items
• Report generation for stakeholder reviews

Common Implementation Mistakes

Over-Engineering the Register

Teams often create 50+ fields per vendor. Start with 15-20 core fields and expand based on actual usage. Track which columns get referenced in decisions and reports.

Static Risk Scoring

Risk profiles change. A vendor's bankruptcy filing or security breach should trigger immediate re-scoring. Build triggers for major events rather than waiting for scheduled reviews.

Siloed Ownership

Risk registers fail when only TPRM owns them. Procurement needs access for vendor selection. Security teams need visibility for incident response. Legal requires it for contract negotiations.

Compliance-Only Focus

Limiting your register to compliance checkboxes misses operational risks. Track SLA performance, support ticket trends, and relationship health indicators alongside regulatory requirements.

Poor Evidence Management

Storing a SOC 2 report isn't enough. Extract specific control failures, map them to your requirements, and track remediation commitments with deadlines.

Frequently Asked Questions

How many fields should our risk register template include?

Start with 15-20 essential fields covering vendor basics, risk scores, assessment status, and evidence tracking. Add fields only when they drive specific decisions or reporting needs.

Should we track fourth-party risks in the same register?

Create a separate section or linked table for fourth parties. Track only critical fourth parties that could materially impact your operations, not every subcontractor.

How do we handle vendors that refuse to complete our full DDQ?

Document their refusal in the register and assign elevated inherent risk scores. Use alternative evidence like SOC 2 reports or create risk acceptance documentation signed by business owners.

What's the best format for a risk register - spreadsheet or database?

Spreadsheets work for under 50 vendors. Beyond that, you need a database or GRC platform to handle relationships, versioning, and workflow automation effectively.

How often should risk scores be recalculated?

Critical vendors need quarterly score updates. High-risk vendors require semi-annual recalculation. Low-risk vendors can use annual updates unless trigger events occur.

Should we include contract terms in the risk register?

Include only risk-relevant terms: liability caps, indemnification, termination rights, and SLAs. Link to full contracts rather than duplicating all terms.

How do we prioritize remediation efforts across vendors?

Multiply residual risk scores by vendor criticality ratings. Address high-risk critical vendors first, then high-risk non-critical, then medium-risk critical vendors.