An Overview of the Department of War's Cybersecurity Risk Management Construct
There’s little technically new in the Department of War’s (DoW/DoD) “CSRMC” announcement. It packages well-known, modern risk management ideas (continuous monitoring, automation, critical controls, DevSecOps, Reusability, survivability/resilience) into a five-phase lifecycle and ten tenets. The document is useful as strategic direction, but it does not yet provide the practical, implementable policy, mappings, control sets, telemetry requirements, metrics, or enforcement mechanisms operators and contractors need to actually change behavior or prove compliance.
Below I summarize what is genuinely incremental vs. what is restatement, compare CSRMC to NIST/CMMC/RMF, and give pragmatic, actionable updates you can propose (including specific mappings and deliverables the DoD should publish next).
What’s actually new (mostly packaging)
The CSRMC frames a lifecycle of Design → Build → Test → Onboard → Operations and pairs that with ten strategic tenets (automation, critical controls, CONMON (continuous monitoring), DevSecOps, cyber survivability, reciprocity, etc.). Packaging a lifecycle around continuous monitoring and operational survivability is a messaging shift that prioritizes operational speed and mission continuity.
Stronger emphasis on automation, threat-informed testing, and “real-time dashboards” as outputs of the RMF life cycle (i.e., operational risk visibility rather than episodic checklists.) That emphasis is more noticeable here than in previous releases.
What is not new (and why it matters)
Core concepts: continuous monitoring, critical controls, reciprocity, DevSecOps, and training are long established in NIST SP 800-37/53 (RMF), the NIST Cybersecurity Framework (CSF), and the DoD’s CMMC effort. CSRMC’s tenets largely echo those documents.
No prescriptive control set or control mapping: The announcement does not publish a canonical list (e.g., a mapped subset of NIST SP 800-53 or CIS Controls) that would tell implementers which controls are the CSRMC “critical controls.” Without that, “critical controls” is aspirational.
No telemetry/continuous monitoring data model or schema.: Continuous monitoring only scales if the DoD specifies expected telemetry (event types, retention, formats, tagging, canonical timestamps, identity context), or publishes a minimal continuous monitoring data model. None is in the release.
No measurable success criteria or enforcement model: There’s no discussion of required certification, contract clauses, timelines, or how CSRMC ties to CMMC enforcement for vendors. That leaves implementers unsure how to prioritize spend.
Comparison with NIST CSF, RMF, and CMMC
NIST RMF (SP 800-37): RMF is a lifecycle process for categorization, control selection, assessment, authorization, and continuous monitoring. CSRMC’s five phases map closely to RMF phases (Prepare/Categorize/Select → Implement → Assess → Authorize → Monitor) but CSRMC reframes them with stronger programmatic language around automation and operational survivability. In short: CSRMC ≈ RMF re-labeled + stronger emphasis on automation and mission resilience.
NIST CSF: CSF provides outcomes and a taxonomy (Identify/Protect/Detect/Respond/Recover). CSRMC’s tenets and lifecycle are compatible with CSF outcomes; CSF remains the higher-level taxonomy CSRMC should map to. CSRMC does not supplant CSF; it should be implemented by mapping CSRMC tenets to CSF functions and to specific controls/practices.
CMMC: CMMC is an acquisition/compliance program for contractors with levels mapped to NIST requirements. CSRMC reads like an enterprise operational construct for DoD systems (not a contractor certification program). Where it matters: CSRMC needs explicit mapping to CMMC expectations so contractors know how to demonstrate reciprocity / continuous monitoring for DoD onboards. Without that mapping, contractors face uncertainty.
Key gaps that prevent CSRMC being “usable” in practice
No control catalog / minimal required controls: Which NIST SP 800-53 controls or CIS Controls are required to satisfy “critical controls”? (Operators need a versioned list and it should map to something existing, not be a new set of controls)
No telemetry / continuous monitoring schema / exchange standard: How should data flow from sensors to continuous monitoring platforms? Are STIX/TAXII, CEF, or a DoD schema required? This is an opportunity for the DoD to align with commercial schema like OCSF.
No measurable KPIs / SLAs: What constitutes “real-time”? What are latency, fidelity, and coverage expectations for detection and remediation? ‘Real time’ requirements is another blog post for another day. It’s an idealistic expectation that can never be met and must be defined.
No reciprocity rules: What evidence, artifact format, and attestation levels are acceptable for reciprocity? How will mutually-accepted assessments be validated?
No contractor / acquisition implication: How does CSRMC change contract language, CMMC levels, or Source Selection criteria?
Recommendations
CSRMC → NIST CSF / SP 800-53 mapping matrix
A published matrix mapping each CSRMC tenet and lifecycle phase to (a) CSF function/subcategory, (b) SP 800-53 controls, and (c) suggested control baselines per system criticality. This removes ambiguity about “which controls matter.”
“Critical Controls” short list (v1)
A minimum, prioritized list (10–20) of controls required for initial onboarding (e.g., identity MFA, endpoint telemetry EDR/XDR, privileged access management, network segmentation, patching & vuln mgmt automation, logging to SIEM/ISCM). Preferably mapped to CIS Critical Controls and SP 800-53. Operators get a target set to implement now.
Example: Audit Logging and Monitoring
NIST SP 800-53 Control: AU-6 (Audit Review, Analysis, and Reporting)
NIST CSF Function/Subcategory: Detect (DE.AE-3): Event data are collected and correlated from multiple sources and sensors.
CSRMC Tenet: Continuous Monitoring and Authorization
Critical? Yes. Continuous audit review directly supports CSRMC’s emphasis on automation, real-time dashboards, and operational resilience.
Minimal continuous monitoring data model & telemetry spec
Define required event types, schemas, and a canonical JSON schema (or required fields) for telemetry that must be ingested (identity context, system ID, mission tag, UTC timestamp, event type, severity, hash). Require a supported transport (STIX/TAXII or DoD-standard) and retention windows.
Example
Required Event Types (not exhaustive):
Authentication/Identity Events (logon success/failure, MFA status, privilege escalation)
System/Asset State Events (startup/shutdown, configuration change, patch/update status)
Network/Traffic Events (connections, flows, anomalies, blocked attempts)
Malware/Threat Events (detections, quarantines, EDR/XDR telemetry)
Audit/Change Events (admin actions, policy updates, control disablement)
Required Fields (canonical, schema-based):
event_time_utc(ISO 8601 UTC timestamp)event_type(standardized value OCSF category/subcategory, e.g.,identity/authentication)severity(OCSF severity scale or DoD-mapped scale: informational, low, medium, high, critical)system_id(unique asset ID hostname, GUID, or DoD asset tag)identity_context(user ID, role, authentication method)mission_tag(mission/business system identifier)action(performed activity: allow, deny, alert, update, delete, etc.)hash(where applicable: file or object hash, SHA-256 preferred)source_ip/destination_ip(if network-related)artifact_reference(pointer to supporting logs, packet captures, or binaries if retained elsewhere)
OCSF/JSON schema example
{
"event_time_utc": "2025-09-25T14:05:23Z",
"event_type": "identity.authentication",
"severity": "high",
"system_id": "servername",
"identity_context": {
"user_id": "uid",
"role": "sysadmin",
"auth_method": "ouath"
},
"mission_tag": "finance",
"action": "failed_login",
"source_ip": "x.x.x.x",
"destination_ip": "y.y.y.y",
"hash": null,
"artifact_reference": "https://example-bucket.s3.us-west-1.amazonaws.com/2025/09/25/system-abc123"
}Transport & Retention Requirements Example
Transport: STIX/TAXII 2.1 or DoD-standard secure message. OCSF JSON events encapsulated in TAXII collections or published via message queue.
Retention: Minimum 90 days online, 1 year cold storage.
Security: All telemetry signed to ensure integrity.
Reciprocity artifact standard & attestation levels
Define artifact formats (signed SBOMs, signed test reports, vulnerability posture statements, control status evidence), acceptance criteria, and a maturity/assurance score. Define how external certificates (CMMC level) feed into reciprocity.
Operational KPIs, KRIs, & SLAs Example
Example KPIs: mean time to detect (MTTD) target, mean time to respond (MTTR) target for critical events, percentage of mission-critical assets instrumented, telemetry completeness percentage, and automated patch cadence. Make them tiered by system criticality.
Pilot & acquisition timeline
A 6–12 month pilot program across 3 program offices that publishes lessons learned, a playbook, and contract clause templates (PWS/SOW and DFARS snippets) for requiring CSRMC readiness in vendors.
Include open feedback and joint collaboration with commercial experts
Open reference implementations / tool recommendations
Publish open reference implementations for ingestion (example SIEMconnectors), dashboard examples, and scripts for assessing “critical control” posture. This accelerates adoption and avoids bespoke toolchains per PEO.
Example YAML detection rule:
title: Multiple Failed Login Attempts
id: 123e4567-e89b-12d3-a456-426614174000
status: experimental
description: Detects multiple failed login attempts from a single user or IP within a short time window.
references:
- https://attack.mitre.org/techniques/T1110/ # Brute Force technique
author: CSRMC Example
date: 2025/09/25
logsource:
product: windows
service: security
detection:
selection:
EventID: 4625 # Windows Failed Logon event
timeframe: 5m
condition: selection | count(UserName, IpAddress) by 5
fields:
- EventTime
- UserName
- IpAddress
- LogonType
falsepositives:
- User mistyping password
- Service accounts with expired passwords
level: high
tags:
- csrmc.tenet: "Continuous Monitoring and Authorization"
- nist.csf: "DE.AE-3"
- nist.800-53: "AU-6"
- csrmc.critical_control: true
Bottom line
CSRMC is a strategic rebrand/clarification of how the DoD wants to operate: lifecycle thinking, automation, real-time monitoring, and survivability. That’s useful and aligned to NIST and CMMC trends but it is not yet an implementable standard or really anything earth shattering or new. To make CSRMC operational, DoD must publish mappings, telemetry specs, artifact/reciprocity requirements, KPIs, and acquisition language otherwise the announcement risks being a restatement without teeth.
References
DoW/DoD CSRMC press release and CSRMC PDF U.S. Department of War
DoD CSRMC — Strategic Tenets PDF U.S Department of War
NIST SP 800-37 Rev. 2, Risk Management Framework. NIST Computer Security Resource Center
NIST Cybersecurity Framework (CSF 2.0). NIST Publications
CMMC program materials (DoD/CMMC overview). CMMC Overview