RISK REGISTER TEMPLATES AND REPORTING

Register Schema · Exception Request · Scoring Examples · CISO Slice-and-Dice Reporting


Document ID CERG-TMPL-RM-001
Version 1.23
Status Approved
Classification Public
Owner Governance Pillar Leader (Risk Register)
Parent Procedure CERG-PRC-RM-001 - Risk Register and Exception Process
Supporting Documents CERG-GOV-CB-001 · CERG-GOV-MTR-001
Review Cycle Annual / On register tooling change
Frameworks NIST 800-30r1 · NIST 800-39 · ISO 31000
Regulations NERC-CIP · CMMC L2 · SOX ITGC
Environments All in-scope assets

Table of Contents

  1. Purpose and Scope
  2. Risk Statement Standard
  3. Risk Register Schema
  4. Worked Examples
  5. Exception Request Template
  6. Risk Scoring Guide
  7. CISO Slice-and-Dice Reporting Views
  8. Document Control

1. Purpose and Scope

CERG-PRC-RM-001 defines how risks and exceptions move through the program. This document is the executable package that makes that procedure operable: the register schema, the exception template, scoring examples, and the reporting views the CISO actually consumes. It is referenced from PRC-RM-001 and from CERG-GOV-CB-001 (control-to-evidence mapping).

Why Bind Risk Statements to Controls

A risk that does not map to at least one control is either a controls gap to add to the baseline or an over-broad risk to refine. A control that does not map to at least one risk is a control that nobody can defend. The register is the place those two libraries reconcile.


2. Risk Statement Standard

Every risk register entry has a single sentence, the Risk Statement, in this form:

Because of [threat / weakness], affecting [asset / scope], there is a possibility that [adverse event] occurs, resulting in [business impact].

The Risk Statement is derived from a control. The derivation pattern is:

Control State Implied Risk Statement Stem
Implemented “If the control fails or is bypassed…”
Partially Implemented “Because the control covers only [scope]…”
Planned “Until the control is implemented…”
Risk Accepted “While the exception is in force…”
Inherited “If the provider’s control or our inheritance prerequisites fail…”

If a risk does not map to a control in CERG-GOV-CB-001, one of three things happens: (1) the control is added to the baseline as a CERG-X control, (2) the risk is reframed against an existing control, or (3) the risk is rejected as out of scope.


3. Risk Register Schema

The schema below is the system-of-record contract regardless of tool (Excel, ServiceNow, Archer, RSA, custom).

Field Type Required Description
Risk ID R-YYYY-NNNN Yes Sequential per calendar year.
Risk Statement Free text - Section 2 form Yes One sentence.
Source Enum: VM · Pen Test · Vendor · Architecture Review · Audit · Threat Intel · Self-Identified · Incident Yes What surfaced the risk.
Linked Control(s) List of CERG-GOV-CB-001 IDs Yes At least one.
Control Evidence Link URI / artifact reference Yes Evidence that the linked control state or compensating control is implemented and independently verifiable.
Affected Asset(s) Asset inventory ID(s) Yes From the authoritative asset inventory.
Operating Unit Enum (OU list) Yes Drives CISO slice-and-dice.
Regulatory Scope Multi-select: CUI · BES · SOX · None Yes Drives overlay scoring.
Inherent Likelihood 1–5 Yes Before controls.
Inherent Impact 1–5 Yes Before controls.
Inherent Score Likelihood × Impact Auto -
Control Effectiveness Enum: Strong · Adequate · Weak · None Yes Reduces residual score per Section 6.
Residual Likelihood 1–5 Yes After controls.
Residual Impact 1–5 Yes After controls.
Residual Score Likelihood × Impact Auto Drives approval authority per PRC-RM-001 §8.
Treatment Enum: Mitigate · Transfer · Avoid · Accept Yes -
Treatment Plan Free text Yes Specific actions, owners, dates.
Residual Risk Owner / Business Owner Named role Yes Asset/process/business owner accountable for the residual consequence; security may coordinate but does not own business risk.
CERG Coordinator Named role Yes Pillar contact - keeps it moving.
Approver Named role Yes Per PRC-RM-001 §8 and RMF-001 §9.7 authority.
Decision Date Date If treatment is selected or changed Date the treatment decision was recorded.
Approval Date Date If accepted Date required approval was recorded.
Review Cadence Quarterly · Semi-Annual · Annual Yes Driven by residual score.
Last Validated Date Date Yes Last date the risk score, control/evidence state, owner, and treatment status were validated against operational reality.
Next Review Date Date Yes Next required review date; must align to cadence and shortest applicable regulatory/procedure clock.
Status Open · In Treatment · Accepted · Closed · Retired Yes -
Linked Exceptions Exception ID(s) If exception in force -
Linked Findings VM finding ID · Pen test finding ID · Audit finding ID Optional -
Linked POA&M POA&M ID If CUI scope -
Evidence Pointer URI / artifact reference Yes Where the complete evidence package lives; may duplicate Control Evidence Link when one artifact proves both control state and risk treatment.
Closure / Validation Evidence URI / artifact reference If closed, accepted, or score changed Evidence proving closure, treatment validation, score change, or accepted-residual-risk conditions.
Trend Indicator Improving · Steady · Worsening Yes (at review) Set at each review.
Free-Form Notes Free text Optional -

3.1 Computed Fields and Workflow States

  • Residual Score drives auto-routing to the approval queue per PRC-RM-001 §8.
  • Review Cadence is set by residual score: Critical/High = Quarterly, Medium = Semi-Annual, Low = Annual.
  • Last Validated Date is updated whenever the risk is reviewed, treatment status changes, control evidence is refreshed, closure is verified, or acceptance conditions are reapproved.
  • Status transitions: Open → In Treatment → (Closed | Accepted) → Retired. Retired risks are kept for audit history.

4. Worked Examples

4.1 Example A: Risk Derived From a Partially Implemented Control

Field Value
Risk ID R-2026-0048
Risk Statement Because phishing-resistant MFA (IA-2) is not enforced on all legacy interactive logons, affecting the on-prem AD-joined Tier 2 application estate (≈ 180 systems), there is a possibility that credential phishing of a privileged user leads to lateral movement, resulting in operational outage and recovery cost.
Source Self-Identified
Linked Control(s) IA-2
Operating Unit Generation Operations IT
Regulatory Scope SOX
Inherent Likelihood / Impact 4 / 4 → 16
Control Effectiveness Weak (legacy auth permitted)
Residual Likelihood / Impact 4 / 3 → 12 (High)
Treatment Mitigate
Treatment Plan Q3: enforce phishing-resistant MFA on Tier 2 high-blast-radius admin paths. Q4: extend to remainder. Exceptions tracked.
Risk Owner Gen Ops IT Director
Approver CISO
Review Cadence Quarterly

4.2 Example B: Risk Derived From a Risk-Accepted Exception

Field Value
Risk ID R-2026-0102
Risk Statement While exception EX-2026-0017 is in force permitting an unmanaged legacy SCADA HMI to remain in service through 2027, affecting a single substation, there is a possibility that an unpatched RCE is exploited via the local engineering jump server, resulting in localized loss-of-view and breach of CIP-007 R2.
Source Architecture Review
Linked Control(s) CM-2 / CM-6 / SI-2
Regulatory Scope BES
Inherent Likelihood / Impact 3 / 5 → 15
Control Effectiveness Adequate (compensating: isolated jump, monitored, no internet egress)
Residual Likelihood / Impact 2 / 4 → 8 (Medium)
Treatment Accept (until 2027 replacement)
Linked Exceptions EX-2026-0017
Review Cadence Quarterly

4.3 Example C: Risk Derived From an Inheritance Failure Mode

Field Value
Risk ID R-2026-0153
Risk Statement If the M365 inherited tenancy isolation control is misconfigured on the customer side (conditional access policy gap), affecting all M365-resident CUI workspaces, there is a possibility that unauthorized cross-tenant access leads to CUI exposure, resulting in CMMC L2 finding and DC3 notification.
Source Architecture Review
Linked Control(s) AC-3 / IA-2 / 800-171 3.1.1
Regulatory Scope CUI
Residual Likelihood / Impact 2 / 5 → 10 (High)
Treatment Mitigate
Linked POA&M POAM-CUI-2026-0019

5. Exception Request Template

The exception is a request to deviate from a baseline control. It is a risk register entry once approved.

EXCEPTION REQUEST - EX-YYYY-NNNN

Requestor              :
Business Sponsor       :
Date Submitted         :
Requested Effective    :
Requested Expiration   :   (per RMF §9.7 default durations; shortest applicable regulatory or procedural duration wins)

Affected Asset(s)      :   (inventory ID + name)
Operating Unit         :
Regulatory Scope       :   CUI / BES / SOX / None

Control Being Deviated :   ([CERG-GOV-CB-001](../governance/CERG-GOV-CB-001_Unified_Control_Baseline.md) control ID + family)
Subordinate Standard   :   (CERG-STD-* reference)
Standard Language      :   (quoted parameter that is being relaxed)
Proposed Deviation     :   (precise; not "we won't do X" but "we will do Y in place of X")

Business Driver        :   (why this is needed)
Compensating Controls  :   (specific, named, in place - not future tense)
Residual Risk Score    :   (per Section 6)
Risk Statement         :   (per Section 2)

Treatment Plan to      :
Close the Exception    :   (what makes this expire - usually a planned control)

Risk Owner             :
CERG Coordinator       :
Approver Required      :   (per PRC-RM-001 §8 - Engineering Mgr / CISO / Exec Sponsor)

Exception register fields mirror the risk register schema and add: Exception ID, Standard Reference, Deviation Text, Compensating Controls, Expiration Date, Renewal Allowed (Y/N), Renewal History.

Exceptions Are Not “Forever”

Every exception has an expiration date and a treatment plan that retires it. An exception renewed more than twice without movement on the treatment plan is escalated by the Risk Register Owner to the approver one level above the original.


6. Risk Scoring Guide

CERG scores risk on a 5×5 matrix, with control effectiveness as a step-down from inherent to residual.

6.1 Likelihood (1–5)

Rating Meaning Indicators
1 - Rare Unlikely in any 5-year window. No known precedent; requires sophisticated, targeted attack.
2 - Unlikely Possible in 5 years. Known but rare; requires specific conditions.
3 - Possible Plausible within 1 year. Industry has examples; ordinary skill required.
4 - Likely Expected within 1 year. Observed in peer organizations or commodity attack.
5 - Almost Certain Expected within 90 days or actively observed. Active campaign, exposed surface, telemetry indicates attempts.

6.2 Impact (1–5)

Impact is scored across Safety, Operational, Financial, Regulatory, and Reputational dimensions; the highest dimension wins.

Rating Safety Operational Financial Regulatory Reputational
1 None < 1 hr / 1 system < $100K None Internal only
2 Minor injury / near miss < 4 hr / single BU $100K–$1M Informal finding Localized awareness
3 Recordable injury < 24 hr / multi-BU $1M–$10M Audit finding Regional press
4 Serious injury 24–72 hr / multi-OU $10M–$50M Material finding / fine National press
5 Fatality / public safety > 72 hr / safety event > $50M License at risk / criminal exposure Sustained national / international

6.3 Control Effectiveness Step-Down

Effectiveness Likelihood Reduction Impact Reduction
Strong −2 −1
Adequate −1 −1
Weak 0 0
None 0 0

Residual cannot fall below 1. Step-downs are applied to inherent, never to residual.

6.4 Heat Map Bands

Residual Score Band Approval Authority (per RMF §9.7 / PRC-RM-001 §8)
20–25 Critical CISO + Executive Sponsor; Board notified
12–19 High CISO + Business Owner
6–11 Medium Business Owner + Pillar Leader or Governance Pillar Leader
2–5 Low Business Owner + Risk Register Owner
1 Informational Risk Register Owner tracks; no formal acceptance required

7. CISO Slice-and-Dice Reporting Views

The CISO will not consume the operational view. The CISO will consume views that compare and trend. The package below is what gets published, heat-maps, trend lines, and scorecards first; narrative memos in reserve for specific questions.

7.1 The Five Standing CISO Views

View Purpose Data Shape
OU Scorecard Compare operating units against each other on residual risk volume and trend. One row per OU. Columns: Critical / High / Medium / Low counts; Δ vs. prior month; Open SLA breaches; Open Exceptions; Trend arrow.
OU Heat Map Show where risk concentrates by OU × Family. Matrix: OU rows × Control Family columns (AC, AU, CM, CP, IA, RA, SC, SI, SR). Cell = count of High/Critical.
Trend Lines Are we getting better or worse? Monthly: total residual score (sum), Critical+High count, mean time to close, open exception count. 13-month rolling.
Top 10 Risks The set the board cares about. The ten highest residual-score open risks with risk statement, owner, treatment, next milestone.
Regulatory Posture Per-overlay summary. CUI / BES / SOX rows; columns: Practices Implemented %, Open POA&M items, Open Exceptions, Next Assessment Date.

7.2 Anti-Shallow-Metrics Guardrails

Don’t Reward Closing Easy Vulns While Criticals Sit

The reporting views above deliberately weight score sum and Critical+High count over raw counts. A view that rewards closing 200 Lows while 4 Criticals sit untouched is a view that lies to the CISO. CERG reports the residual-score weighted sum first; raw counts second.

Additional guardrails baked into the views:

  • OU Scorecard “Trend Arrow” is computed on residual-score weighted sum, never on count.
  • Top 10 Risks rows must include the age of the highest-impact unmitigated finding inside that risk, so a 6-month-old Critical does not hide behind a freshly closed Low.
  • OU Heat Map colors on Critical+High concentration, not on total count.
  • Regulatory Posture “Practices Implemented %” is computed on the in-scope practice set with Partially Implemented counted as 0.5, not as 1.

7.3 Cadence

View Refresh Audience
OU Scorecard Monthly CERG Leadership · OU Leadership
OU Heat Map Monthly CISO
Trend Lines Monthly CISO · Cyber Oversight Group
Top 10 Risks Monthly + ad hoc CISO · Cyber Oversight Group · Board (quarterly slice)
Regulatory Posture Quarterly CISO · Audit · Cyber Oversight Group

8. Document Control

Document ID CERG-TMPL-RM-001
Version 1.23
Approved By CISO
Next Review Annual / on tooling change
Change Log 1.23 - Added explicit Definition of Done fields for residual risk owner, control evidence, decision date, last validated date, next review date, and closure/validation evidence. 1.22 - Aligned scoring bands, approval authorities, and expiration guidance to RMF §9.7 / PRC-RM-001 §8. 1.0 - Initial publication. Schema, examples, exception template, scoring guide, CISO reporting views.

Source: templates/CERG-TMPL-RM-001_Risk_Register_Templates_and_Reporting.md · Download .md · View on GitHub