NIST SP 800-37r1dF Front Matter

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NIST Special Publication 800-37 Guide for Applying the Risk
Revision 1 Management Framework to
Federal Information Systems
A Security Life Cycle Approach
Computer Security Division
Information Technology Laboratory
National Institute of Standards and Technology
Gaithersburg, MD 20899-8930
November 2009
U.S. Department of Commerce
Gary Locke, Secretary
National Institute of Standards and Technology
Patrick D. Gallagher, Director

Reports on Computer Systems Technology

The Information Technology Laboratory (ITL) at the National Institute of Standards and Technology (NIST) promotes the U.S. economy and public welfare by providing technical leadership for the nation's measurement and standards infrastructure. ITL develops tests, test methods, reference data, proof of concept implementations, and technical analyses to advance the development and productive use of information technology. ITL's responsibilities include the development of management, administrative, technical, and physical standards and guidelines for the cost-effective security and privacy of other than national security-related information in federal information systems. The Special Publication 800-series reports on ITL's research, guidelines, and outreach efforts in information system security, and its collaborative activities with industry, government, and academic organizations.


This publication has been developed by NIST to further its statutory responsibilities under the Federal Information Security Management Act (FISMA), Public Law (P.L.) 107-347. NIST is responsible for developing information security standards and guidelines, including minimum requirements for federal information systems, but such standards and guidelines shall not apply to national security systems without the express approval of appropriate federal officials exercising policy authority over such systems. This guideline is consistent with the requirements of the Office of Management and Budget (OMB) Circular A-130, Section 8b(3), Securing Agency Information Systems, as analyzed in Circular A-130, Appendix IV: Analysis of Key Sections. Supplemental information is provided in Circular A-130, Appendix III.

Nothing in this publication should be taken to contradict the standards and guidelines made mandatory and binding on federal agencies by the Secretary of Commerce under statutory authority. Nor should these guidelines be interpreted as altering or superseding the existing authorities of the Secretary of Commerce, Director of the OMB, or any other federal official. This publication may be used by nongovernmental organizations on a voluntary basis and is not subject to copyright in the United States. Attribution would, however, be appreciated by NIST.

NIST Special Publication 800-37, Revision 1, 88 pages
(November 2009)

Certain commercial entities, equipment, or materials may be identified in this document in order to describe an experimental procedure or concept adequately. Such identification is not intended to imply recommendation or endorsement by NIST, nor is it intended to imply that the entities, materials, or equipment are necessarily the best available for the purpose.

There may be references in this publication to other publications currently under development by NIST in accordance with its assigned statutory responsibilities. The information in this publication, including concepts and methodologies, may be used by federal agencies even before the completion of such companion publications. Thus, until each publication is completed, current requirements, guidelines, and procedures, where they exist, remain operative. For planning and transition purposes, federal agencies may wish to closely follow the development of these new publications by NIST. Organizations are encouraged to review all draft publications during public comment periods and provide feedback to NIST. All NIST publications, other than the ones noted above, are available at

Public comment period: November 17 through December 31, 2009
National Institute of Standards and Technology
Attn: Computer Security Division, Information Technology Laboratory
100 Bureau Drive (Mail Stop 8930) Gaithersburg, MD 20899-8930
Electronic mail:

Compliance with NIST Standards and Guidelines

In accordance with the provisions of FISMA,[1] the Secretary of Commerce shall, on the basis of standards and guidelines developed by NIST, prescribe standards and guidelines pertaining to federal information systems. The Secretary shall make standards compulsory and binding to the extent determined necessary by the Secretary to improve the efficiency of operation or security of federal information systems. Standards prescribed shall include information security standards that provide minimum information security requirements and are otherwise necessary to improve the security of federal information and information systems.

  • Federal Information Processing Standards (FIPS) are approved by the Secretary of Commerce and issued by NIST in accordance with FISMA. FIPS are compulsory and binding for federal agencies.[2] FISMA requires that federal agencies comply with these standards, and therefore, agencies may not waive their use.
  • Special Publications (SPs) are developed and issued by NIST as recommendations and guidance documents. For other than national security programs and systems, federal agencies must follow those NIST Special Publications mandated in a Federal Information Processing Standard. FIPS 200 mandates the use of Special Publication 800-53, as amended. In addition, OMB policies (including OMB Reporting Instructions for FISMA and Agency Privacy Management) state that for other than national security programs and systems, federal agencies must follow certain specific NIST Special Publications.[3]
  • Other security-related publications, including interagency reports (NISTIRs) and ITL Bulletins, provide technical and other information about NIST's activities. These publications are mandatory only when specified by OMB.
  • Compliance schedules for NIST security standards and guidelines are established by OMB.


This publication was developed by the Joint Task Force Transformation Initiative Interagency Working Group with representatives from the Civil, Defense, and Intelligence Communities in an ongoing effort to produce a unified information security framework for the federal government— including a consistent process for selecting and specifying safeguards and countermeasures (i.e., security controls) for federal information systems. The Project Leader, Ron Ross, from the National Institute of Standards and Technology, wishes to acknowledge and thank the senior leadership team from the U.S. Departments of Commerce and Defense, the Office of the Director of National Intelligence, the Committee on National Security Systems, and the members of the interagency working group whose dedicated efforts contributed significantly to the publication. The senior leadership team, working group members, and their organizational affiliations include:

U.S. Department of Defense Office of the Director of National Intelligence
Cheryl J. Roby

Assistant Secretary of Defense DOD Chief Information Officer (Acting)

Honorable Priscilla Guthrie

Intelligence Community Chief Information Officer

Gus Guissanie

Deputy Assistant Secretary of Defense for Cyber, Identity, and Information Assurance (Acting)

Sherrill Nicely

Deputy Intelligence Community Chief Information Officer

Dominic Cussatt

Senior Policy Advisor, ODASD (CIIA)

Mark J. Morrison

Deputy Associate Director of National Intelligence for IC Information Assurance

Don Jones

Senior Policy Advisor, ODASD (CIIA)

Roger Caslow

Lead, C&A Transformation

National Institute of Standards and Technology Committee on National Security Systems
Cita M.Furlani

Director, Information Technology Laboratory

Cheryl J.Roby

Chairman, Committee on National Security Systems (Acting)

William C. Barker

Chief, Computer Security Division

Eustace D. King

CNSS Subcommittee Co-Chairman (DOD)

Ron Ross

FISMA Implementation Project Leader

William Hunteman

CNSS Subcommittee Co-Chairman (DOE)

Joint Task Force Transformation Initiative Interagency Working Group
Ron Ross Gary Stoneburner Dominic Cussatt Kelley Dempsey
NIST, JTF Leader Johns Hopkins APL Department of Defense NIST
Marianne Swanson Jennifer Fabius Greene Dorian Pappas Arnold Johnson
NIST MITRE Corporation National Security Agency NIST
Stuart Katzke Glenda Turner Peter Gouldmann Christian Enloe
Booz Allen Hamilton MITRE Corporation Department of State NIST
Peter Williams George Rogers
Booz Allen Hamilton BAE Systems, Inc

In addition to the above acknowledgments, a special note of thanks goes to Peggy Himes and Elizabeth Lennon for their superb technical editing and administrative support. The authors also wish to recognize Marshall Abrams, Richard Graubart, Esten Porter, Karen Quigg, John Gilligan, John Streufert, and Beckie Bolten for their exceptional contributions in helping to improve the content of the publication. And finally, the authors gratefully acknowledge and appreciate the significant contributions from individuals and organizations in the public and private sectors, both nationally and internationally, whose thoughtful and constructive comments improved the overall quality and usefulness of this publication.


In developing standards and guidelines required by FISMA, NIST consults with other federal agencies and offices as well as the private sector to improve information security, avoid unnecessary and costly duplication of effort, and ensure that NIST publications are complementary with the standards and guidelines employed for the protection of national security systems. In addition to its comprehensive public review and vetting process, NIST is collaborating with the Office of the Director of National Intelligence (ODNI), the Department of Defense (DOD), and the Committee on National Security Systems (CNSS) to establish a common foundation for information security across the federal government. A common foundation for information security will provide the Intelligence, Defense, and Civil sectors of the federal government and their support contractors, more uniform and consistent ways to manage the risk to organizational operations and assets, individuals, other organizations, and the Nation that results from the operation and use of information systems. A common foundation for information security will also provide a strong basis for reciprocal acceptance of security authorization decisions and facilitate information sharing. NIST is also working with public and private sector entities to establish specific mappings and relationships between the security standards and guidelines developed by NIST and the International Organization for Standardization and International Electrotechnical Commission (ISO/IEC) 27001, Information Security Management System (ISMS).

Notes to Reviewers

NIST Special Publication 800-37, Revision 1, represents the second in a series of publications being developed by the Joint Task Force Transformation Initiative. For the past three years, NIST has been working in partnership with the Office of the Director of National Intelligence (ODNI), the Department of Defense (DOD), and the Committee on National Security Systems (CNSS) to develop a common information security framework for the federal government and its support contractors. The initial publication produced by the task force, NIST Special Publication 800-53, Revision 3, was historic in nature—in that it created a unified security control catalog reflecting the information security requirements of both the national security community and the nonnational security community. NIST Special Publication 800-37, Revision 1, continues the transformation by significantly changing the traditional process employed by the federal government to certify and accredit federal information systems. The revised process provides greater emphasis on: (i) building information security capabilities into information systems through the application of state-of-the-practice management, operational, and technical security controls; (ii) maintaining awareness of the security state of information systems on an ongoing basis though enhanced monitoring processes; and (iii) understanding and accepting the risk to organizational operations and assets, individuals, other organizations, and the Nation arising from the use of information systems.

The most significant change in the Final Public Draft of Special Publication 800-37, Revision 1, is the full transformation of the Certification and Accreditation (C&A) process into the six-step Risk Management Framework (RMF). The revised RMF-based process has the following characteristics:

  • Integrates information security more closely into the enterprise architecture and system development life cycle;
  • Provides equal emphasis on the selection, implementation, assessment, and monitoring of security controls, and the authorization of information systems;
  • Establishes responsibility and accountability for security controls deployed within organizational information systems and inherited by those systems (i.e., common controls);
  • Links risk management processes at the information system level to risk management processes at the organization-level through a risk executive (function);
  • Promotes the concept of near real-time risk management and ongoing information system authorization through the implementation of robust continuous monitoring processes; and
  • Encourages the use of automation and automated support tools to provide senior leaders the necessary information to take credible, risk-based decisions with regard to the organizational information systems supporting their core missions and business functions.

The risk management process described in this publication changes the traditional focus from the stovepipe, organization-centric, static-based approaches to C&A and provides the capability to more effectively manage information system-related security risks in highly dynamic environments of complex and sophisticated cyber threats, ever increasing system vulnerabilities, and rapidly changing missions.

We have worked diligently to review and adjudicate the over five hundred comments received during the initial public review process. Your feedback to us, as always, is important. We appreciate each and every contribution from our reviewers. The very insightful comments from both the public and private sectors continue to help shape our publications and ensure that they meet the needs of our customers.




  1. The E-Government Act (P.L. 107-347) recognizes the importance of information security to the economic and national security interests of the United States. Title III of the E-Government Act, entitled the Federal Information Security Management Act (FISMA), emphasizes the need for organizations to develop, document, and implement an organization-wide program to provide security for the information systems that support its operations and assets.
  2. The term agency is used in this publication in lieu of the more general term organization only in those circumstances where its usage is directly related to other source documents such as federal legislation or policy.
  3. While federal agencies are required to follow certain specific NIST Special Publications in accordance with OMB policy, there is flexibility in how agencies apply the guidance. Federal agencies should apply the security concepts and principles articulated in the NIST Special Publications in accordance with and in the context of the agency's missions, business functions, and environment of operation. Consequently, the application of NIST guidance by federal agencies can result in different security solutions that are equally acceptable, compliant with the guidance, and meet the OMB definition of adequate security for federal information systems. When assessing federal agency compliance with NIST Special Publications, Inspectors General, evaluators, auditors, and assessors should consider the intent of the security concepts and principles articulated within the specific guidance document and how the agency applied the guidance in the context of its mission/business responsibilities, operational environment, and unique organizational conditions.