Category: Risk Assessment & Analysis

Risk Response

Also known as: Risk Response Strategy, Risk Response Planning

Simply put

Risk response is the set of actions an organization decides to take to deal with a risk it has identified. Common choices include accepting the risk, avoiding it, reducing it, or shifting some of it to another party. The goal is to bring the risk to a level the organization considers acceptable.

Formal definition

In the NIST risk management context, risk response refers to accepting, avoiding, mitigating, sharing, or transferring risk to organizational operations (including mission, functions, image, and reputation), organizational assets, individuals, other organizations, and the Nation. It represents a decision-making step within the broader risk management process in which an organization selects a course of action for identified risks based on its risk tolerance and priorities. Readers should note that the specific catalog of response options and the process for determining them may vary across the applicable NIST publication revision and any agency-specific tailoring, and the current authoritative text should be verified.

Why it matters

Risk response is the decision point where risk management moves from analysis to action. Identifying and assessing risks produces information, but that information only protects an organization's mission, assets, individuals, and reputation once a deliberate course of action is chosen and carried out. In the NIST risk management context, risk response is the step in which an organization commits to accepting, avoiding, mitigating, sharing, or transferring a given risk based on its risk tolerance and priorities. Without an explicit response decision, identified risks tend to persist unaddressed, and the organization has no defensible record of why it chose to live with, reduce, or shift a particular exposure.

For compliance officers, ISSMs, and authorizing officials, risk response decisions are also part of the evidence trail that supports authorization and continuous monitoring. An authorizing official who grants an Authority to Operate is effectively accepting residual risk, and that acceptance should be traceable to specific, documented response choices rather than treated as a one-time formality. It is worth remembering that a response decision is not permanent: because risk conditions, threats, and system configurations change, response choices should be revisited as part of ongoing risk management rather than set once and forgotten.

A common expert correction is that choosing to mitigate a risk is not the same as eliminating it, and that documenting a response is not the same as achieving security. Response options such as sharing or transferring may reduce financial or operational impact to the organization, but they do not necessarily reduce the underlying likelihood or technical exposure. Readers should treat the specific catalog of response options and the process for selecting them as subject to the applicable NIST publication revision and any agency-specific tailoring.

Who it's relevant to

Authorizing Officials

Authorizing officials make explicit risk acceptance decisions when granting authorization, so risk response is central to their role. Because an authorization reflects accepted residual risk and is time-bound and subject to continuous monitoring, the response decisions underpinning it should be documented, defensible, and revisited as conditions change.

Information System Security Managers (ISSMs)

ISSMs translate risk response decisions into implemented controls and operational actions. They are typically responsible for ensuring that mitigation choices are carried out, that residual risk is communicated accurately, and that response decisions are traceable within the risk management process.

Compliance Officers and Auditors

Compliance officers and auditors examine whether identified risks have documented response decisions consistent with the organization's stated risk tolerance. They should confirm that documenting a response is not treated as equivalent to eliminating the risk, and should verify decisions against the applicable NIST revision and any agency-specific tailoring.

Risk and Program Managers

Managers responsible for mission functions and programs select among response options, accept, avoid, mitigate, share, or transfer, based on organizational priorities. They must weigh the effect of each option on operations, assets, individuals, and other stakeholders, recognizing that sharing or transferring risk may limit impact without reducing the underlying exposure.

Inside Risk Response

Risk Acceptance

A response option in which the organization acknowledges an identified risk and chooses to tolerate it without further mitigation, typically documented through a formal decision by an authorizing official or comparable risk executive. In RMF contexts this is often recorded in a plan of action and milestones (POA&M) or an accepted-risk determination, and it generally remains subject to continuous monitoring and periodic reassessment.

Risk Mitigation

The application of security and privacy controls or other measures to reduce the likelihood or impact of a risk to an acceptable level. Under the NIST RMF and control catalogs such as NIST SP 800-53, mitigation is implemented through selected and tailored controls, and the residual risk that remains after mitigation informs the authorization decision.

Risk Avoidance

Eliminating a risk by not engaging in the activity, technology, or process that gives rise to it, for example decommissioning a system or forgoing a capability. This option removes the exposure entirely rather than reducing it.

Risk Transfer (or Sharing)

Shifting or distributing some portion of the risk to another party, such as through contractual arrangements, insurance, or use of a shared service. In cloud contexts the shared-responsibility model illustrates how certain risks are allocated between provider and customer; note that transferring a risk does not by itself satisfy a compliance obligation the organization retains.

Residual Risk

The risk that remains after a chosen response has been applied. Residual risk is a central input to authorization decisions, and its determination generally depends on the applicable control baseline, impact level, and any agency-specific tailoring in effect at the time of assessment.

Risk Response Decision Authority

The role responsible for selecting and approving a risk response. In DoD RMF implementations this is typically the authorizing official (AO), informed by the system owner, ISSM, and risk executive function; the specific authority and delegation may vary by organization and by whether the system is a federal civilian, defense, or national security system.

Common questions

Answers to the questions practitioners most commonly ask about Risk Response.

Does accepting a risk mean the organization has resolved or eliminated it?

No. Risk acceptance is a formal decision to tolerate a risk at its current level rather than a step that reduces or removes it. The vulnerability or threat condition generally remains present; what changes is that an appropriate official has determined the residual risk is within tolerance and has documented that decision. Acceptance should be time-bound and revisited, because conditions, threats, and system context change. Treating acceptance as a permanent resolution is a common mistake an authorizing official would insist on correcting.

Is choosing a risk response the same as being compliant or secure?

Not necessarily. Selecting and documenting a risk response is part of a risk management process, but compliance with a control baseline and actual security are distinct from the risk decision itself. An organization can document a defensible risk response and still carry meaningful residual risk, and compliance with a framework does not by itself demonstrate that a risk has been effectively addressed. Readers should treat risk response as a decision-making step within a broader process rather than as evidence of a secure or fully compliant state.

What are the commonly recognized categories of risk response?

Risk management guidance generally describes responses such as accepting, avoiding, mitigating, transferring, or sharing risk, though specific terminology and definitions can vary by framework and agency tailoring. The appropriate choice depends on the risk level, mission needs, and organizational risk tolerance. Because definitions and categories differ across the applicable publications and revisions, readers should confirm the exact terms and criteria used in their governing guidance.

Who typically decides on a risk response?

In most implementations, the official accountable for the system or mission function, such as an authorizing official in a Risk Management Framework context, makes or approves risk response decisions, informed by input from information system security personnel and risk assessors. The specific roles and delegation of authority depend on the organization's governance structure and applicable policy, so readers should verify decision authority against their own documented roles and responsibilities.

How should a risk response decision be documented?

Risk response decisions are generally recorded in artifacts such as risk assessments, security or authorization documentation, and tracking mechanisms like a plan of action and milestones where mitigation is deferred. Documentation typically captures the risk, the chosen response, the rationale, responsible parties, and applicable timeframes. Exact documentation formats and requirements vary by framework and agency, so confirm the required artifacts against current authoritative guidance.

How does risk response relate to continuous monitoring?

Risk response is not a one-time event. Because an authorization is time-bound and subject to continuous monitoring, previously selected responses, especially accepted or mitigated risks, should be reassessed as threats, vulnerabilities, and system conditions evolve. Continuous monitoring provides the ongoing information used to determine whether a prior response remains adequate or should be revisited. Specific monitoring frequencies and triggers depend on organizational policy and applicable guidance.

Common misconceptions

Accepting a risk is a permanent decision that closes the matter.

Risk acceptance is generally time-bound and conditional. Like an Authority to Operate, an accepted-risk determination is subject to continuous monitoring and periodic reassessment, and changes in threat, system configuration, or control effectiveness can require the response to be revisited.

Choosing an appropriate risk response means the system is secure and compliant.

Selecting a risk response is a risk-management activity, not proof of security or compliance. Mitigating or accepting a risk does not by itself demonstrate that controls are operating effectively, and compliance is a distinct determination that must be assessed against the applicable authoritative requirements. Compliance and security are not the same thing.

Transferring a risk to a third party or cloud provider removes the organization's responsibility for it.

Transferring or sharing a risk reallocates some exposure but generally does not relieve the organization of its underlying compliance and accountability obligations. Under shared-responsibility arrangements, the customer retains responsibility for the portions allocated to it, and a provider authorization does not automatically satisfy every requirement the organization must meet.

Best practices

Document each risk response decision, its rationale, and the approving authority, and record accepted risks in a tracking artifact such as a POA&M rather than treating acceptance as an informal or undocumented outcome.

Determine and record residual risk for each response so that authorizing officials have a clear basis for their decisions, verifying the calculation against the control baseline and impact level applicable to the system.

Treat risk acceptance as time-bound: set reassessment intervals and tie the acceptance to continuous monitoring so that changes in threat or system state trigger review.

Confirm the correct decision authority for each response according to your organization's delegation structure, recognizing that authority may differ between federal civilian, defense, and national security systems.

When transferring or sharing risk, define the allocation explicitly (for example through the shared-responsibility model or contractual terms) and verify which obligations the organization still retains against current authoritative requirements.

Do not equate an approved risk response with proven security or compliance; validate control effectiveness through assessment and keep responses aligned with the current applicable revision of the governing guidance.