Effective incident response is no longer just a best practice—it’s a critical business function. As cyber threats grow more complex, organizations must ensure their incident response plans are aligned with the latest standards. In April 2025, the National Institute of Standards and Technology (NIST) officially withdrew Special Publication 800-61 Revision 2 and released Revision 3: Incident Response Recommendations and Considerations for Cybersecurity Risk Management. This new guidance aligns with the NIST Cybersecurity Framework (CSF) 2.0 and provides a more flexible, outcome-driven model for managing security incidents.
NIST 800-61 Revision 3 vs Revision 2: Why the Shift?
NIST SP 800-61 Revision 2 introduced a four-phase incident response lifecycle: Preparation, Detection & Analysis, Containment/Eradication/Recovery, and Post-Incident Activity. While effective, this structure didn’t always integrate well with broader enterprise risk management strategies. Revision 3 eliminates the rigid lifecycle model in favor of mapping incident response activities to CSF 2.0’s five core functions: Identify, Protect, Detect, Respond, and Recover. This change encourages a more holistic and business-aligned approach to incident management.
Understanding NIST CSF 2.0’s Five Core Functions
The NIST Cybersecurity Framework (CSF) 2.0 is built around five high-level functions:
- Identify: Understand your environment, risks, and assets.
- Protect: Deploy safeguards to limit the impact of a cybersecurity event.
- Detect: Monitor and identify cybersecurity events.
- Respond: Take action to contain and mitigate incidents.
- Recover: Restore capabilities and improve future resilience.
NIST SP 800-61 Revision 3 uses these functions as the foundation for its incident response recommendations, creating consistency across planning, execution, and reporting.
Mapping NIST SP 800-61 Incident Response to CSF Functions
Understanding how incident response activities align with each CSF function helps organizations build more integrated and effective security programs.
- Identify: Before an incident occurs, organizations should develop governance structures, identify incident types relevant to their operations, and establish communication protocols. This includes asset inventories, risk assessments, and identification of legal or regulatory obligations.
- Protect: Implement technical and procedural safeguards such as training, endpoint protections, and access control to reduce incident likelihood and scope.
- Detect: Use logging, monitoring, intrusion detection systems, and threat intelligence to quickly spot signs of compromise. Detection should be timely and actionable.
- Respond: Execute predefined response plans tailored to incident types. This includes containment strategies, eradication procedures, and stakeholder communications. This phase also encompasses evidence gathering and forensics.
- Recover: Focus on restoring systems and services, communicating with internal and external stakeholders, and performing post-incident reviews. Continuous improvement and updated playbooks fall into this phase.
NIST 800-61 Revision 3 Impact on CMMC and Compliance
For organizations subject to regulatory or contractual frameworks, such as CMMC, DFARS, or NIST SP 800-171, NIST SP 800-61 Revision 3 represents an important evolution. While the control language in these standards hasn’t changed, how organizations demonstrate maturity has. Under CMMC Level 2, for example, controls like 3.6.1 (incident response policy), 3.6.2 (incident reporting), and 3.6.3 (incident handling) now benefit from clear mapping to CSF functions. This enhances auditability and operational clarity.
Best Practices for Adopting NIST SP 800-61 Revision 3
Successfully transitioning to Revision 3 requires a structured approach that addresses policy updates, team training, and operational improvements.
- Update your incident response policy to align with CSF 2.0 structure and terminology.
- Train your response team on the revised NIST framework and their roles within it.
- Develop or revise playbooks based on incident categories (e.g., ransomware, insider threat, credential compromise).
- Perform tabletop exercises that simulate the full CSF lifecycle.
- Track performance metrics like Mean Time to Detect (MTTD), Mean Time to Respond (MTTR), and total cost of incidents.
- Participate in information-sharing communities such as ISACs to gain early warnings about sector-specific threats.
NIST SP 800-61 Revision 3 Frequently Asked Questions
These common questions address the most pressing concerns organizations have when transitioning from Revision 2 to the new framework.
What Happened to the 4-phase Lifecycle from Revision 2?
It was retired in favor of the CSF 2.0 model. Organizations are now encouraged to use the Identify-Protect-Detect-Respond-Recover structure.
Do I Need to Rewrite My IR Plan?
If your existing plan closely follows Revision 2’s lifecycle, it should be reviewed and updated to match Revision 3 and CSF terminology.
Is Revision 3 Required for CMMC or NIST 800-171?
Not yet explicitly, but aligning with the latest NIST guidance shows maturity and proactive compliance.
Is Revision 2 Still Valid?
No. NIST formally withdrew it in April 2025. Only Revision 3 should be used moving forward.
Next Steps: Implementing NIST 800-61 Incident Response Updates
Taking these actionable steps can help to align your incident response program with NIST SP 800-61 Revision 3 and strengthen your compliance posture.
- Review your existing IR documentation – Identify references to Revision 2 and replace with Revision 3 principles.
- Assess your program maturity – Use CSF 2.0 to benchmark your IR process across the five functions.
- Engage leadership – Ensure your C-suite understands how incident response ties to business continuity and reputational risk.
- Audit readiness – Make sure evidence of implementation (logs, reports, policies) supports your compliance framework, especially for CMMC Level 2 or DFARS.
- Seek expert support – Engage a qualified partner to assist in updating documentation and preparing for assessments.
Get Expert Help with NIST SP 800-61 Compliance
At Linford & Company LLP, we help organizations align their cybersecurity programs with leading frameworks such as NIST SP 800-61, NIST SP 800-171, and CMMC. Our team conducts detailed reviews of incident response plans and performs readiness assessments to prepare clients for a wide range of compliance audits, including SOC 2, PCI DSS, HITRUST, ISO 27001, and NIST-based frameworks like 800-53, 800-61, and 800-171. Whether you’re preparing for certification or strengthening internal controls, we provide the expertise to help you succeed. Contact us to learn more.
Mark Larson started working in the technology industry in 1998 where he worked in a number of different roles prior to transitioning to the public accounting world in 2004 with Ernst & Young (EY). During his 6 years at EY, Mark provided both assurance and advisory services that spanned multiple industries for both public and private companies. After leaving EY, Mark filled leadership roles within Internal Audit, Technology, and Security functions for several companies. Mark specializes in SOC examinations and enjoys helping clients establish, formalize, and report on effective control environments while strengthening their security risk profile.