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AmaraW
AuditBoard Staff
AuditBoard Staff

NIST 800-53 is widely used as a cybersecurity framework, and many refer to its individual requirements as controls. However, adopting these requirements 1-to-1 as a common control set is not recommended. The NIST 800-53 framework is designed with very granular requirements, each covering specific aspects of security controls, often addressing only small portions of a broader control.

In practice, adopting these requirements individually can lead to an overly fragmented control environment, creating administrative burden and redundancy without significantly improving compliance outcomes. For organizations managing multiple frameworks, such as SOC 2 or ISO 27001, this can complicate efforts to align and streamline control activities.

Best Practices for Scoping and Simplifying NIST 800-53 Requirements

To create an efficient and comprehensive control environment, it’s critical to scope down the NIST 800-53 requirements in a way that aligns with your organization’s risk profile and compliance needs. Here’s how to effectively manage the complexity:

  • Tailor Scope Based on Risk:
    NIST 800-53 organizes requirements into three distinct levels—Low, Moderate, and High—based on the potential impact of a security breach. When tailoring scope, organizations should assess the risk associated with different systems and functions and choose controls that reflect their specific risk level. For example:
    • Low Impact Systems: Controls should focus on basic security hygiene and operational efficiency, such as enforcing strong passwords and basic access control measures.
    • Moderate Impact Systems: More stringent controls are necessary, such as encryption for sensitive data and multi-factor authentication.
    • High Impact Systems: These systems require the most robust controls, including real-time monitoring, advanced threat detection, and strict access controls.

By tailoring controls according to the impact levels, organizations can focus their efforts and resources where they are most needed, ensuring that critical assets are secured in proportion to the potential risk.

Leverage SCF Common Controls for Efficiency:
NIST 800-53 contains a high level of detail across its control families, but many of these requirements overlap or are complementary. Rather than managing each NIST 800-53 requirement as a standalone control, organizations often use common control sets, like those provided by the Secure Controls Framework (SCF), to map NIST 800-53 and other frameworks (such as SOC 2, ISO 27001, PCI DSS) into a unified control environment. SCF common controls are designed to consolidate multiple requirements from different frameworks into a single control. This reduces duplication, simplifies reporting, and allows you to "test once, comply with many" frameworks. Using SCF helps eliminate the redundancy caused by adopting NIST requirements individually and provides long-term scalability as you add more frameworks

Return to Best Practice Guide: Adopting a New Framework in CrossComply