Additional policies and procedures required for NIST 800-53 compliance

Beyond the core requirements outlined in NIST 800-53 control families, there are additional policies and procedures that organizations must implement based on their impact level. These documents cover critical areas like risk management, authorization processes, insider threat prevention, and data governance. Ensuring these policies and procedures are in place not only helps with compliance but also strengthens your overall security posture.

Below, we’ll outline which policies and procedures are required across all impact levels, which apply specifically to Moderate and High control baselines, and which are exclusive to High-impact systems.

Policies and procedures required across all impact levels (Low, Moderate, High)

Some policies and procedures are considered fundamental to security and privacy and are required regardless of whether your organization operates at a Low, Moderate, or High impact level. These documents focus on core security principles like establishing a security program, defining roles and responsibilities, managing cybersecurity risks, and enforcing security controls across all systems.

If you’re just starting out with NIST 800-53 compliance, these policies and procedures should be your first priority.

PL-1: Security and Privacy Policy and Procedures

The Security and Privacy Policy and Procedures are the foundation of your entire security and privacy program. It’s where your organization formally states its commitment to protecting systems and data.

These documents outline who is responsible for security and privacy, what frameworks you comply with, and how security measures are enforced. It also ensures that policies and procedures are reviewed regularly and updated as needed. Think of this as the rulebook that sets the tone for everything else in your security program.

PL-4: Rules of Behavior Policy and Procedures

The Rules of Behavior documents lay out what users can and can’t do when they access your organization’s systems. They include things like proper system use, restrictions on sharing sensitive information, and guidelines for handling data securely.

They also clarify what happens if someone violates the rules, whether that’s disciplinary action or revoking their access. Essentially, they ensure that everyone understands their responsibilities when using company systems, reducing the risk of accidental or intentional security breaches.

PM-1: Information Security Program Plan and Procedures

Your Information Security Program Plan and associated procedures are the big-picture documents that explains how security is managed across your organization. They describe your security objectives, how you assess risks, and the steps you take to mitigate them.

These documents also outline how you implement your set of controls and continuously monitor them. This plan is critical because it brings all your security efforts together into one structured framework, ensuring that security isn’t just an afterthought but a strategic part of your operations.

PM-9: Risk Management Strategy and Procedures

Every organization faces threats, whether it's cyberattacks, data breaches, or operational disruptions. The Risk Management Strategy and Procedures are all about how you identify, assess, and respond to those risks. They detail your risk assessment methodology, what level of risk your organization is willing to accept, and the steps you take to minimize or eliminate risks. Having a clear risk management strategy helps ensure you’re proactively addressing threats rather than just reacting when something goes wrong.

PM-10: Authorization Process Policy and Procedures

Your Authorization Process documents define how systems, applications, and users get approved for access. They explain the process of granting and reviewing system authorizations to ensure that access is based on business needs, and that periodic account management reviews are conducted to verify that authorizations are still appropriate. They’re a key part of preventing unauthorized access and making sure security remains strong over time.

PM-13: Security and Privacy Workforce Policy and Procedures

These documents focus on ensuring your organization has the right people with the right skills managing security and privacy. The Security and Privacy Workforce policy and procedures outline training requirements, certification needs, and ongoing education to keep security and privacy personnel up to date on evolving threats and regulations. They also help define roles and responsibilities so there’s no confusion about who’s accountable for what, ensuring that the people handling security and privacy are equipped to do their jobs effectively.

PM-16: Threat Awareness Program Policy and Procedures

A Threat Awareness Program is designed to keep employees informed about the latest security threats and how to recognize and respond to them. These documents cover regular security awareness training, phishing simulations, and real-world threat examples that employees might encounter. The idea is to build a security-conscious culture where everyone plays a role in keeping data and systems safe, not just IT. They also help prevent human error by making sure employees know what to watch for.

PM-17: Protecting Controlled Unclassified Information on External Systems

If your organization handles Controlled Unclassified Information (CUI) and needs to store or process it on external systems, like a cloud service or a third-party vendor’s platform, this policy and procedures ensure that proper safeguards are in place. They lay out requirements for encryption, access controls, and monitoring to prevent unauthorized access or exposure of CUI. Since external systems can introduce new risks, these documents ensure that security remains strong even when data isn’t stored in your internal environment.

PM-18: Privacy Program Plan and Procedures (if applicable)

If your organization handles Personally Identifiable Information (PII), you need a Privacy Program Plan to manage privacy risks and comply with regulations. These documents outline how PII is collected, stored, processed, and protected. They ensures compliance with privacy laws like GDPR or HIPAA and defines how privacy incidents are reported and handled. Essentially, these documents help build trust by demonstrating that your organization takes privacy seriously and has a structured approach to protecting personal data.

Required policies and procedures for Moderate and High baselines

Organizations operating in Moderate and High impact environments must meet additional policy and procedural requirements to account for the increased risk and potential consequences of security breaches. These documents cover areas like system security planning, threat awareness, continuous monitoring, and compliance tracking, ensuring that security measures are more structured and rigorously enforced.

If your organization handles sensitive but unclassified data, critical business functions, or government-related information, these policies and procedures will likely be required as part of your NIST 800-53 compliance efforts.

PL-2: System Security and Privacy Plans and Procedures

Think of the System Security and Privacy Plan and Procedures as the playbook for how each system is secured and protected. Every system in your organization needs a documented plan that explains its security controls, privacy considerations, and how risks are managed. 

These documents ensure that plans exist and are regularly reviewed and updated. They cover things like system boundaries, data flows, access controls, and encryption methods. Without them, it’s hard to know if a system is properly secured or if there are gaps that could expose sensitive information.

PL-8: Security and Privacy Architectures

Your Security and Privacy Architectures define the overall structure and design of your organization's security and privacy controls. These documents ensure that security and privacy are built into your systems from the ground up, not added as an afterthought. They provide a framework for how security and privacy should be integrated across networks, applications, and cloud environments. A well-defined architecture helps create a consistent approach to protecting data, making it easier to enforce security standards and ensure compliance.

PM-4: Plan of Action and Milestones (POA&M) Process

The POA&M (Plan of Action and Milestones) is where you document, track, and manage security issues. No system is ever 100% secure, so when vulnerabilities or compliance gaps are found, the POA&M ensures they are formally documented and addressed. These documents establish a process for identifying security weaknesses, assigning ownership, setting deadlines for fixes, and tracking progress.

PM-6: Measures of Performance

Security programs need to be measured to make sure they’re actually working. The Measures of Performance defines how your organization tracks the effectiveness of security and privacy controls. This could include things like the number of security incidents, the time it takes to patch vulnerabilities, or employee compliance with security training. By having clear performance metrics, you can identify weak areas and continuously improve your security posture.

PM-12: Insider Threat Program

Not all security threats come from outside hackers. The Insider Threat Program is designed to detect and prevent risks posed by employees, contractors, or other insiders who might misuse their access to sensitive systems.

This policy includes monitoring for suspicious behavior, implementing least-privilege access controls, and establishing a process for investigating potential insider threats. It’s a critical safeguard, especially for organizations handling sensitive data or intellectual property.

PM-14: Testing, Training, and Monitoring

Security isn’t just about technology, it’s about people, too. The Testing, Training, and Monitoring policy and procedures ensure that employees and IT staff receive ongoing security training and that systems are continuously monitored for threats. This includes things like phishing simulations, security awareness programs, and technical security testing like penetration testing and vulnerability scans. By regularly training employees and testing security controls, your organization can reduce human error and proactively address weaknesses before they become serious issues.

PM-22: Personally Identifiable Information (PII) Quality Management

If your organization collects Personally Identifiable Information (PII), you need to make sure that data is accurate, complete, and up to date. The PII Quality Management policy and procedures sets rules for verifying, updating, and correcting personal data. This is crucial for compliance with privacy laws like GDPR or HIPAA, where organizations are required to ensure the integrity of personal data. Poor-quality PII can lead to errors, identity fraud, or compliance violations, so this policy helps maintain trust and data accuracy.

PM-23: Data Governance Body

Data governance isn’t just an IT responsibility, it’s a business-wide effort. The Data Governance Body policy and procedures ensure that a formal group is responsible for overseeing how data is managed, protected, and used across the organization. This governance team sets data policies, approves security controls, and ensures compliance with legal and regulatory requirements. It also helps prevent data silos and inconsistencies, making sure that security and privacy are embedded into every aspect of the organization’s data strategy.

High baseline-only policies and procedures

For organizations that operate High-impact systems, security and privacy requirements are even more stringent. High-impact environments typically involve national security, critical infrastructure, or highly sensitive data, where a breach could result in severe financial, operational, or reputational damage.

The policies and procedures in this section are designed to provide extra layers of security, resilience, and oversight. If your organization is working toward High baseline compliance, these documents are essential to meet NIST 800-53 standards and safeguard mission-critical systems.

PM-8: Critical Infrastructure Plan

The Critical Infrastructure Plan is all about identifying and protecting the systems and assets that are essential to your organization's operations. If you rely on certain IT systems, cloud services, or physical infrastructure to keep things running, this policy ensures that they’re recognized as critical and have extra security protections in place.

It includes things like business continuity planning, disaster recovery strategies, and redundancy measures to keep essential services up and running even if there’s an outage, cyberattack, or other disruption. Without a solid plan in place, losing access to critical systems could cause major operational or financial damage.

PM-24: Data Integrity Board

Your Data Integrity Board is a governance body responsible for making sure that your organization’s data (especially sensitive or regulated data) is accurate, reliable, and properly managed. These documents ensure that there’s a formal group overseeing how data is collected, stored, and protected.

The board helps set policies on data integrity, approves security controls, and ensures compliance with regulations related to data protection. It also plays a key role in resolving data quality issues and preventing unauthorized modifications to critical datasets. This is especially important for organizations that handle financial records, federal government data, or any information that needs to remain trustworthy and tamper-proof.

PL-8(1): Defense in Depth Strategy

Instead of relying on a single security measure to protect your systems, this policy and procedures ensure that multiple overlapping security controls are in place at different levels. For example, if an attacker gets past a firewall, they should still have to deal with strong authentication, intrusion detection, and endpoint security measures before accessing sensitive data.

This strategy makes it much harder for threats to penetrate your defenses and helps minimize the damage if one layer is breached. It’s like having multiple locks on a door: each layer adds another hurdle for attackers.

PL-8(2): Supplier Diversity

The Supplier Diversity policy and procedures are about ensuring that your organization’s supply chain includes vendors and service providers from a variety of backgrounds and business types. This policy encourages working with small businesses, minority-owned companies, and other diverse suppliers to promote inclusivity and resilience in procurement.

But beyond just ethical or economic benefits, this policy and procedures also have a security angle: relying too heavily on a single supplier can create risks if they experience a disruption or security failure. By diversifying your supplier base, you reduce the likelihood that a single point of failure in your supply chain could impact your operations.

Downloadable NIST 800-53 policy templates

Having the right policies and procedures in place is a critical step toward securing your organization and meeting NIST 800-53 security requirements. By understanding requirements and tailoring them to your specific impact level, you can create a strategy that not only meets compliance needs but also strengthens your overall cybersecurity posture.

Whether you're building out your security documentation for the first time or refining existing policies and procedures, these templates will jumpstart your compliance efforts.

Best practices for creating and maintaining NIST 800-53 policies and documents

Your security policies and procedures define expectations, outline responsibilities, and serve as a roadmap for implementing security controls. But to be effective, they need to be well-structured, regularly updated, and easy to understand.

Below are some best practices to help you create policies and procedures that not only meet NIST 800-53 compliance requirements, but also support strong security and risk management practices over the long term.

Incorporate control enhancements for higher impact levels

If your organization operates at a Moderate or High impact level, your policies and procedures need to go beyond the baseline requirements. NIST 800-53 includes control enhancements that provide additional layers of security for organizations managing more sensitive data or critical systems. These enhancements help address stricter security requirements, ensuring that your policies are aligned with the level of risk your organization faces. Taking the time to incorporate these into your documentation will help ensure you're fully prepared for audits and ongoing compliance.

Implement a governance and review process

Your security policies and procedures aren’t static documents — they need to evolve alongside changing regulations, threats, and business needs. Establishing a structured governance and review process ensures that policies remain relevant and effective. This includes scheduling regular policy and procedure reviews, assigning ownership to security teams or compliance officers, and conducting internal audits to verify compliance.

Policies and procedures should also be updated to reflect changes in regulations, such as FIPS, new executive orders, or updates to services acquisition requirements. Keeping policies and procedures up to date not only helps with compliance but also ensures they remain a practical tool for guiding security efforts.

Provide training for personnel

Policies and procedures are only useful if people actually follow them. Training should cover key areas like acceptable use policies, incident response procedures, and data protection guidelines to ensure that employees know how to comply with security requirements in their day-to-day work.

Using an automation platform like Secureframe can make this process even easier by tracking which employees have reviewed and accepted policies. Automated reminders can help ensure full participation, speeding up time-to-compliance and eliminating the need for manual follow-ups.

Maintain clear documentation for audits and compliance

Well-organized documentation is key to streamlining audits and proving compliance. Your policy and procedure documents should be version-controlled, easy to access, and mapped directly to NIST 800-53 requirements. Auditors and regulators typically look for:

• A control catalog that shows how policies and procedures align with NIST 800-53 controls
• Proof of policy and procedure implementation, such as risk assessments, access control logs, or security training records
• Evidence of enforcement, like employee sign-offs and compliance monitoring reports

Having these documents readily available can significantly reduce audit preparation time and ensure your organization is always prepared for compliance reviews.

Apply policies and procedures across frameworks

Many organizations need to comply with multiple security frameworks, such as ISO 27001, SOC 2, FISMA, FedRAMP, or NIST CSF 2.0. Instead of managing separate policies and procedures for each framework, cross-mapping can reduce duplicate efforts and simplify compliance management. Aligning your NIST 800-53 policies and procedures with other frameworks ensures that security controls remain consistent across different regulatory requirements, saving time and effort when expanding your compliance program.

Automate policy and procedure management

Keeping policies and procedures up to date manually can be overwhelming, especially as regulations and frameworks evolve. Compliance automation tools can simplify policy management by providing a built-in policy and procedure library, tracking updates, and assigning version control to improve visibility.

Platforms like Secureframe go a step further by ensuring policies and procedures stay current with regulatory changes. Instead of manually revising documents when new frameworks are added, Secureframe automatically creates policy addendums to meet additional requirements. This allows you to quickly adjust policies and procedures without starting from scratch, allowing for seamless compliance as your organization grows.

A recent survey by UserEvidence found that 100% of Secureframe customers reduced their compliance workload, with 76% cutting compliance-related time by at least 51%. If you're looking for a way to streamline policy management and reduce manual effort, schedule a demo today to see how Secureframe can help.