Risk Response is a net-new requirement in R3 that formalizes the step between finding a problem and planning to fix it. It requires responding to findings from security assessments, monitoring, and audits. Risk Response (03.11.04) is the deliberate decision about what to do with a finding, which may be to mitigate it immediately, accept the risk, or plan a remediation. Per the NIST discussion, this requirement addresses the need to determine an appropriate response to risk before generating a Plan of Action and Milestones (POAM) entry, since it may be possible to mitigate the risk immediately so that a POAM entry is not needed, while a POAM entry is generated when the mitigation cannot be completed immediately.
A common difficulty with this requirement is jumping straight from a finding to a POAM entry without a decision in between, or worse, letting findings pile up with no response at all. This requirement is new, so most organizations have no explicit risk-response step. It sits between the controls that produce findings, such as Vulnerability Monitoring and Scanning (03.11.02) and Control Assessments, and the Plan of Action and Milestones (03.12.02) that tracks remediation.
Where things stand for companies facing the transition from NIST 800-171 R2 to R3:
The following is reproduced verbatim from NIST 800-171 R3, requirement 03.11.04 Risk Response. Only the formatting has been adjusted for readability. This is a single statement with no lettered parts:
The source control is RA-07 from NIST 800-53. There are no Organization-Defined Parameters (ODPs). Per the NIST discussion, this requirement addresses determining an appropriate risk response before generating a POAM entry, and a POAM entry is generated when the risk response is to mitigate and the mitigation cannot be completed immediately. You can read the requirement directly at NIST 800-171 R3, 03.11.04 (p. 55).
None (0). Requirement 03.11.04 contains no bracketed assignment, so there is no organization-defined value to select and nothing for the DoD to specify. The requirement applies as written.
Your System Security Plan (SSP) narrative for 03.11.04 therefore records how the requirement is implemented rather than a parameter you chose.
NIST 800-171A R3 breaks 03.11.04 into three (3) determination statements, and it has no Organization-Defined Parameters (ODPs). These AOs are:
The single statement expands into a response objective for each source of findings: assessments, monitoring, and audits. An assessor checks all three. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.11.04 (p. 71).
Examine: risk assessment policy; assessment reports; system audit records; event logs; system security plan.
Interview: personnel with assessment and auditing responsibilities; system administrators; personnel with security responsibilities.
Test: processes for assessments and audits; mechanisms and tools supporting or implementing assessments and auditing.
03.11.04 is net new for R3 and has no corresponding requirement in NIST 800-171 R2:
Mapped against the three (3) AOs, all three (3) are net new (significant effort), with none direct, indirect, or unmapped. The source control, RA-07, is new to the framework, so there is no transition path. Even organizations with mature assessment and monitoring should add an explicit, documented risk-response step rather than treating remediation planning as the response.
Source Control in NIST 800-53 R5:
Secure Controls Framework (SCF) Crosswalk
Organizations running a single control set across multiple frameworks can satisfy 03.11.04 through the following SCF controls:
The crosswalks from NIST 800-171 R3 and NIST 800-171A R3 to the SCF are available at no cost through the SCF Set Theory Relationship Mapping (STRM): https://securecontrolsframework.com/start-here/set-theory-relationship-mapping-strm. The STRM also carries the relationship type for each mapping (Equal, Subset Of, Intersects With), which tells you whether an SCF control fully satisfies the requirement or only part of it. Mapping above taken from SCF 2026.3.
The pitfalls for this net-new requirement are about the response decision and its sources, each of which needs documented evidence of due diligence and due care such as policies, standards, procedures, and configuration screenshots:
Reasonable objective evidence for an assessment is often subjective. The following examples of evidence to address NIST 800-171 R3 03.11.04 are sourced from the SCF Evidence Request List (ERL), available at https://securecontrolsframework.com/free-content/scf-download. These ERL artifacts are mapped to NIST 800-171 R3 03.11.04 through SCF controls. They establish a starting point for discussions on what an organization needs to have for evidence of due diligence and due care to withstand external scrutiny by an assessor or regulator.
Alongside these, keep the System Security Plan (SSP) narrative for 03.11.04.
With all three (3) AOs net new, plan to add an explicit risk-response step to your process. A realistic sequence:
How many assessment objectives does NIST 800-171 R3 03.11.04 have? NIST 800-171A R3 breaks 03.11.04 into three (3) assessment objectives. An assessor works through each one separately, so each needs its own evidence.
Which NIST 800-53 R5 control does NIST 800-171 R3 03.11.04 come from? RA-07.
How many Organization-Defined Parameters (ODPs) does NIST 800-171 R3 03.11.04 have? None (0). The requirement contains no bracketed assignment, so there is no organization-defined value and nothing for the DoD to specify.
Where does NIST 800-171 R3 03.11.04 sit in the NIST 800-171 R3 Kill Chain? Phase 4a, Risk Management Practices. The Kill Chain is a phased model for sequencing R3 implementation, and it assigns this requirement to that phase.
03.11.04 Risk Response responds to findings from security assessments, monitoring, and audits. It is net new for R3 with no R2 predecessor, so all three (3) objectives are new work. The recurring problem is going straight to a POAM without a documented decision, or letting findings sit unaddressed. Add an explicit risk-response step that decides what to do with each finding from every source, then route planned remediations into your Plan of Action and Milestones.
Authoritative sources:
Authoritative sources:
This guide reproduces U.S. Government text from NIST 800-171 R3 and NIST 800-171A R3. It is educational, not legal or assessment advice. Last reviewed: 2026-09-22.
