NIST RMF in Action: A Breakdown of the 7 Key Steps
Explore how the NIST RMF framework helps organizations manage risks effectively with a breakdown of its 7 essential steps.
Published March 2, 2025.
The Risk Management Framework (RMF) integrates security, privacy, and cyber supply chain risk management activities into the system development life cycle. The latest version was released on July 24, 2024 and offers a comprehensive, flexible, repeatable, and measurable 7-step process that organizations can use to manage information security and privacy risk.
The RMF is linked to a suite of National Institute of Standards and Technology (NIST) standards and guidelines to support the implementation of risk management programs, ensuring compliance with the Federal Information Security Modernization Act (FISMA). This blog will give a breakdown of the 7 key steps in the NIST RMF process.
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The 5 Core Objectives of the NIST Risk Management Framework
- It’s a risk-based approach
- Flexible and can be tailored to suit the needs of an organization’s risk
- Accommodates continuous monitoring
- Can be integrated with the system development life cycle
- Gives room for improved communication and accountability
NIST CSF vs. ISO 27001 vs. COBIT
| Criteria | NIST CSF | ISO 27001 | COBIT |
|---|---|---|---|
| Focus Area | Manages cybersecurity risks by identifying, protecting, detecting, responding to, and recovering from threats | Establishes controls and procedures to protect sensitive data | Aligns IT strategies with business goals while managing risks |
| Flexibility | Highly flexible, allowing organizations to tailor the framework to their specific needs and risk profile | More prescriptive, with detailed requirements that need to be followed for certification | Moderately flexible, providing structured governance while allowing customization for business needs |
| Implementation | Primarily a risk-based approach, focusing on identifying and prioritizing cybersecurity risks | Requires a structured implementation of security controls, often leading to third-party audits for certification | Framework-driven, guiding IT governance, risk management, and compliance efforts |
| Scope | Primarily focused on cybersecurity risks across the organization | Focuses specifically on information security controls within an organization | Covers a broader IT governance landscape, including risk management, performance measurement, and aligning IT with business objectives |
» Learn more: NIST vs. ISO 27001
The 7 Key Steps of NIST RMF
1. Prepare
At this stage, it is essential to have a clear understanding of the project scope, objectives, internal and external environment, processes, and all relevant stakeholders involved.
Required Documentation and Records
- Standard operating procedure across the various processes
- Compliance records
- Internal control frameworks
- Key performance indicators
- Organization’s strategic plan
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Key Activities and Tasks to Complete
- Understand the mission and purpose of the organization to align risk management strategies with its core objectives
- Consider the organization's values and leadership style to ensure that risk management aligns with its culture and decision-making processes
- Assess the organization's risk tolerance level to determine the acceptable level of risk in relation to its goals
- Evaluate the communication channels in use to ensure that risk-related information is effectively shared across the organization
- Examine the type and capability of human resources to ensure that the necessary skills and expertise are available for managing risks
- Assess the external environment and consider both internal and external stakeholders to ensure that all relevant parties are accounted for in the risk management process
Challenges and Solutions
| Challenge | Solution |
|---|---|
| Lack of access to critical information | Organizations should centralize data records and ensure appropriate access permissions are granted to key personnel |
| Resistance to change from employees | To overcome resistance, it is essential to foster open communication and actively involve employees in the process |
| Lack of dedicated resources to conduct analysis | Organizations should allocate resources wisely, provide necessary training, and seek external expertise if required |
If not properly implemented, this could lead to overall project failure and resource wastage due to misalignment, poor decision-making, and misallocation of resources.
2. Categorize
This step involves systematically uncovering risks from various sources and documenting their characteristics.
Required Documentation and Records
- Risk management framework in use/intended to be used/adopted
- Risk identification checklist
- Responses to interviews and questionnaires used to gather information
- Historical risk data and lessons learnt from them
- List of risk categories and their sources
Key Activities and Tasks to Complete
- Brainstorm with all project team members and stakeholders to gather diverse insights and identify potential risks
- Update the risk register checklist to ensure that all possible risks are accounted for
- Derive patterns from lessons learned through historical data to inform future risk assessments
- Reconfirm all risk sources and categories for both internal and external sources to ensure no potential threats are overlooked
» Here are the steps in the risk assessment process and what you should know before hiring a risk assessment provider
Challenges and Solutions
| Challenge | Solution |
|---|---|
| Obsolete risk register | Involving risk experts can help update and maintain the risk register to ensure it accurately reflects the current risk landscape |
| Lack of involvement of all stakeholders in the analysis of the risk report | Involving all stakeholders is crucial for a seamless and successful project implementation, as it ensures comprehensive input and alignment from all relevant parties |
| Unavailability of key process owners to provide input | Assigning a specific risk owner to each process ensures that accountability is maintained and that the necessary input is provided in a timely manner |
| Insufficient historical data for insights and patterns | Establishing open communication channels allows stakeholders to share insights and patterns, improving data accessibility and decision-making |
If this step is not implemented properly, unidentified risks may be exploited, and failing to identify risks fully could lead to compounded threats, financial loss, and reputational damage.
3. Select
This stage assesses the potential impacts and likelihood of each risk, allowing a risk rating or risk score to be assigned depending on severity.
Required Documentation and Records
- Risk register
- Risk management plan
- Risk assessment methodology
- Risk assessment finding
- Compliance documentation
- Communication plan
Key Activities and Tasks to Complete
- Ensure that the list of risks on the risk register is up to date
- Structure a plan that effectively mitigates the risks for the organization
- Follow the selected risk methodology, whether using the qualitative approach, quantitative approach, or a combination of both
- Put in place the compliance documentation (procedures to address the risks)
Challenges and Solutions
| Challenge | Solution |
|---|---|
| Choosing an incorrect risk assessment methodology | Ensure the risk assessment methodology is suitable for the organization's goals and context |
| Lack of expertise in the topic of risk | Engage a risk expert to bring in the necessary knowledge and guidance for conducting a risk assessment |
| People's resistance to change | Provide necessary training and workshops to process owners to address any lack of risk-related knowledge and reduce resistance |
If this step is not properly implemented, it can lead to analyzing the wrong risks, wasting resources by applying controls to the wrong areas, and ultimately increasing the risk of project failure.
4. Implement
This step involves comparing the results of your analysis with predefined risk criteria to determine the significance of each risk and decide on appropriate responses.
Required Documentation and Records
- Detailed risk assessment sheet
- Risk register updates
- Risk evaluation criteria
- Risk scoring and ranking
- Stakeholders review records and approval
- Historical data comparison results
- Risk assessment matrix
Key Activities and Tasks to Complete
- Ensure that the risk evaluation criteria is in sync with the risk acceptance criteria
- Assess the likelihood and potential severity of risks
- Prioritize which risks require further mitigation strategies
Challenges and Solutions
| Challenge | Solution |
|---|---|
| Neglecting stakeholder review reports | Providing adequate resources ensures that all stakeholders can review and contribute to reports effectively |
| Partially implementing agreed-upon controls | Bridging communication gaps helps ensure that all controls are fully implemented as agreed upon |
| Inadequate risk assessment tools | Ensuring that all material risks are considered, whether internal or external, helps in selecting the right assessment tool |
| Resource constraints | Allocating sufficient resources ahead of time is essential to overcome limitations and ensure effective risk management |
If this step is not properly implemented, it could lead to unexpected issues, operational disputes, reputational damage, and unidentified risks.
5. Assess
This step involves developing and implementing strategies to address identified risks.
Risk can be treated using any of the 4 approaches:
- Mitigation approach: A control is implemented to reduce the impact of the risk—this could be preventive, detective, or corrective in nature.
- Acceptance approach: In this approach, no control is implemented and the negative effect is accepted by the organization should it happen. Although not recommended, some risks might not necessarily have a dramatic effect.
- Avoidance approach: In this approach, the activity that will lead to the emergence of the risk is avoided as much as possible.
- Transfer approach: In this approach, the risk is transferred to a third party like an insurance company.
Required Documentation and Records
- Risk treatment plan
- Risk register updates
- Action plan
- Communication records
- Incident reports
- Training records
- Change management records
Key Activities and Tasks to Complete
- Ensure the risk treatment plan is followed to effectively mitigate identified risks
- Keep the risk register updated with newly discovered risks to maintain an accurate risk management process
- Implement the action plan based on the risk treatment plan to address risks efficiently and promptly
- Maintain communication records to ensure all stakeholders are informed and involved in the process
- Analyze past incident reports to identify patterns and improve future response strategies
- Keep records of training conducted to ensure stakeholders and incident responders are equipped to handle incidents when needed
- Document any changes made in response to identified risks to ensure continuous improvement across people, processes, and technology
Challenges and Solutions
| Challenge | Solution |
|---|---|
| Unavailability of a comprehensive risk treatment plan | Conduct a thorough risk assessment to develop a comprehensive plan |
| Non-adherence to the action plan | Regularly monitor and review risks and employees to ensure adherence to the action plan |
| Insufficient records of past incidents | Foster a culture of continuous improvement by keeping detailed records of past incidents |
If this step is not properly implemented, it could lead to reputational damage, financial loss, operational disruption, loss of competitive advantage, and health and safety concerns.
6. Authorize
This step involves the continuous process of overseeing and evaluating both internal and external environments to ensure that risk management activities remain effective, relevant, and aligned with the organization's objectives.
Required Documentation and Records
- Logs of incidents
- Performance metrics
- Minutes of review meetings
- Audit report
- Continuous improvement logs
- Risk assessment updates
- Training record of training conducted regarding persons responsible for risk monitoring
Key Activities and Tasks to Complete
- Review the logs of various incidents
- Ensure that recommendations from management review meetings have been implemented and owned
- Update the risk assessment sheet regularly
- Conduct training for the people in charge of monitoring and review
Challenges and Solutions
| Challenge | Solution |
|---|---|
| Inadequate logs of incidents | Ensure timely capture of incident logs to provide accurate data |
| Poor performance metrics in use | Use relevant performance metrics to assess risk management |
| Inadequate human resources | Choose a cost-effective approach to risk treatment while meeting objectives |
If this step is not properly implemented, it could cause resource wastage, increased attack surfaces, financial loss, reputational damage, operational disruptions, and legal issues.
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7. Monitor
In this step effective communication and consultation are vital to the success of the risk management process.
Required Documentation and Records
- Risk communication plan: This outlines the objectives, strategies, target audience, key messages, channels, and timeline for communicating risk information. It serves as a roadmap for effective communication throughout the risk management process
- Stakeholder register: This lists all stakeholders involved in the risk management process, including their roles, responsibilities, contact information, and level of interest and influence. It helps identify who needs to be consulted and informed.
- Agenda and minutes of meetings: Documents the agenda for each meeting held, the topics discussed, decisions made, action items, and assigned responsibilities. This ensures that all participants are aware of what was discussed and agreed.
- Risk assessment reports: These reports summarize the results of the risk assessments, including the methodologies used, findings, and recommendations. They provide a comprehensive view of the risks and their potential impact on the organization.
- Communication reports: These reports log all communications with stakeholders, including emails, phone calls, meetings, and presentations. This ensures that there is a clear record of what information was shared, with whom, and when.
Key Activities and Tasks to Complete
- Develop an effective communication plan
- Identify and analyze stakeholders
- Prepare the communication materials
- Ensure effective communication with stakeholders
- Report and review the communication process
Challenges and Solutions
| Challenge | Solution |
|---|---|
| Communication barriers | Involve stakeholders early enough to avoid misunderstandings and delays |
| Lack of engagement of stakeholders | Clearly communicate objectives and ensure active participation from all |
| Lack of transparency about risks | Maintain open, honest communication regarding all identified risks |
If this step is not properly implemented, it could result in misunderstandings, inadequate risk response, operational disruption, missed opportunities for improvement, and financial losses.
Real-World Examples of Successful RMF Alignment
U.S. Department of Defense (DoD)
- Alignment: The DoD has adopted the NIST RMF to manage cybersecurity risks across its vast network of systems and operations.
- Positive impact: This alignment has led to improved security measures, better risk management practices, and enhanced protection of sensitive information.
General Services Administration (GSA)
- Alignment: The GSA has integrated the NIST RMF into its IT security programs to ensure consistent and effective risk management.
- Positive impact: By aligning with the NIST RMF, the GSA has been able to achieve a more robust security posture, streamlined risk management processes, and enhanced collaboration across different departments.
State of California Department of Technology (CDT)
- Alignment: The CDT has implemented the NIST RMF to manage cybersecurity risks within state agencies.
- Positive impact: This alignment has led to improved risk identification and mitigation, better resource allocation, and enhanced security awareness among employees.
Healthcare Sector
- Alignment: Healthcare organizations like Mayo Clinic have adopted the NIST RMF to protect patient data and ensure the security of their IT systems.
- Positive impact: By aligning with the NIST RMF, Mayo Clinic has enhanced its cybersecurity measures, improved patient data protection, and ensured compliance with healthcare regulations such as HIPAA.
Strengthen Security With NIST
GRSee Consulting can help you implement the NIST RMF to strengthen security and ensure compliance.
» Read more: Top cybersecurity risks and problems in healthcare
How GRSee Consulting Can Help Optimize NIST RMF Implementation
GRSee Consulting helps organizations implement and optimize the key steps of NIST RMF by following best practices and tailoring solutions to meet each client’s unique cyberservice needs. The NIST RMF is adaptable to all types of organizations, and GRSee ensures its effective integration to address security risks and align with organizational goals.
GRSee Consulting offers expert support to strengthen your risk management process and ensure continuous compliance, driving long-term success.
» Ready to take control of your risk management? Contact us to get started
