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KSI-AFR-ICPIncident Communications Procedures

LOW
MODERATE

Formerly KSI-AFR-10

>Control Description

Integrate FedRAMP's Incident Communications Procedures (ICP) into incident response procedures and persistently address all related requirements and recommendations.
Defined terms:
Incident
Persistently
Vulnerability Response

>FRMR Requirements
12

Normative requirements from the FedRAMP Requirements and Recommendations document — 8 mandatory, 3 recommended, 1 optional.

Mandatory8
MUST

Incident Reporting to FedRAMP

Providers MUST responsibly report incidents to FedRAMP within 1 hour of identification by sending an email to fedramp_security@fedramp.gov or fedramp_security@gsa.gov.

ICP-CSX-IRF
Providers
MUST

Incident Reporting to Agencies

Providers MUST responsibly report incidents to all agency customers within 1 hour of identification using the incident communications points of contact provided by each agency customer.

ICP-CSX-IRA
Providers
MUST

Incident Reporting to CISA

Providers MUST responsibly report incidents to CISA within 1 hour of identification if the incident is confirmed or suspected to be the result of an attack vector listed at https://www.cisa.gov/federal-incident-notification-guidelines#attack-vectors-taxonomy, following the CISA Federal Incident Notification Guidelines at https://www.cisa.gov/federal-incident-notification-guidelines, by using the CISA Incident Reporting System at https://myservices.cisa.gov/irf.

ICP-CSX-IRC
Providers
MUST

Incident Updates

Providers MUST update all necessary parties, including at least FedRAMP, CISA (if applicable), and all agency customers, at least once per calendar day until the incident is resolved and recovery is complete.

ICP-CSX-ICU
Providers
MUST

Incident Report Availability

Providers MUST make incident report information available in their secure FedRAMP repository (such as USDA Connect) or trust center.

ICP-CSX-RPT
Providers
MUST

Final Incident Report

Providers MUST provide a final report once the incident is resolved and recovery is complete that describes at least:

ICP-CSX-FIR
Providers
  • What occurred
  • Root cause
  • Response
  • Lessons learned
  • Changes needed
MUST NOT

Responsible Disclosure

Providers MUST NOT irresponsibly disclose specific sensitive information about incidents that would likely increase the impact of the incident, but MUST disclose sufficient information for informed risk-based decision-making to all necessary parties.

ICP-CSX-RSD
Providers
MUST

Implementation Summaries

Providers MUST maintain simple high-level summaries of at least the following for each Key Security Indicator:

KSI-CSX-SUM
Providers
  • Goals for how it will be implemented and validated, including clear pass/fail criteria and traceability
  • The consolidated _information resources_ that will be validated (this should include consolidated summaries such as "all employees with privileged access that are members of the Admin group")
  • The machine-based processes for _validation_ and the _persistent_ cycle on which they will be performed (or an explanation of why this doesn't apply)
  • The non-machine-based processes for _validation_ and the _persistent_ cycle on which they will be performed (or an explanation of why this doesn't apply)
  • Current implementation status
  • Any clarifications or responses to the assessment summary
Recommended3
SHOULD

Automated Reporting

Providers SHOULD use automated mechanisms for reporting incidents and providing updates to all necessary parties (including CISA).

ICP-CSX-AUR
Providers
SHOULD

Human and Machine-Readable

Providers SHOULD make incident report information available in consistent human-readable and machine-readable formats.

ICP-CSX-HRM
Providers
SHOULD

Application within MAS

Providers SHOULD apply ALL Key Security Indicators to ALL aspects of their cloud service offering that are within the FedRAMP Minimum Assessment Scope.

KSI-CSX-MAS
Providers
1 optional guidance (MAY)
Optional Guidance1
MAY

AFR Order of Criticality

Providers MAY use the following order of criticality for approaching Authorization by FedRAMP Key Security Indicators for an initial authorization package:

KSI-CSX-ORD
Providers
  • Minimum Assessment Scope (MAS)
  • Authorization Data Sharing (ADS)
  • Using Cryptographic Modules (UCM)
  • Vulnerability Detection and Response (VDR)
  • Significant Change Notifications (SCN)
  • Persistent Validation and Assessment (PVA)
  • Secure Configuration Guide (RSC)
  • Collaborative Continuous Monitoring (CCM)
  • FedRAMP Security Inbox (FSI)
  • Incident Communications Procedures (ICP)

>Trust Center Components
4

Ways to express your implementation of this indicator — approaches vary by organization size, complexity, and data sensitivity.

From the field: Mature implementations express incident communication through automated status pages with structured timelines, webhook-driven agency notifications, and machine-readable incident feeds. Every notification is timestamped and logged, creating an immutable communication trail that proves when agencies were informed — not just that a process exists.

Incident Status Page

Dashboards

Dashboard expressing incident status with structured communication timelines — agencies see when each notification was sent and the incident lifecycle in full

Automated: Monitor status page API for update frequency and incident lifecycle completeness

Incident Communication Procedures

Processes & Procedures

How customers and agencies are notified during security incidents — including automated notification triggers and escalation paths

Incident Communication SLA

Policies

Human-readable SLAs for incident notification timelines (e.g., US-CERT 1-hour reporting)

Post-Incident Report Template

Documents & Reports

Sample post-incident report showing communication timeline and root cause analysis

>Programmatic Queries

Beta
GRC

CLI Commands

List recent incidents
pd incident list --since "30 days ago" --output json | jq '.[] | {id,title,status,urgency,created_at}'
Get incident timeline
pd incident log --id <incident-id> --output json | jq '.[] | {type,created_at,summary}'

>20x Assessment Focus Areas

Aligned with FedRAMP 20x Phase Two assessment methodology

Completeness & Coverage:

  • Does your incident response plan explicitly address every FedRAMP ICP requirement (initial notification, updates, final report), and where are gaps documented?
  • Are all incident severity levels mapped to specific ICP notification timelines, including edge cases like near-misses or suspected but unconfirmed incidents?
  • How do you ensure incident communications cover all leveraging agencies, not just the ones that reported or were directly affected?
  • What happens when an incident spans multiple CSO components or involves a shared responsibility boundary — how do you ensure nothing falls through the cracks?

Automation & Validation:

  • What automated severity classification triggers FedRAMP notification workflows, and what happens if the classification engine miscategorizes an incident?
  • How do you automatically track and enforce ICP notification deadlines (e.g., 1-hour, 24-hour), and what fires when a deadline is about to be missed?
  • What automated tests or tabletop simulations validate your incident communication pipeline end-to-end?
  • If your notification system (email, ticketing, SOAR) goes down during an active incident, what failover procedure ensures communications still go out on time?

Inventory & Integration:

  • How does your SIEM or SOAR platform integrate with the ICP notification workflow to automatically trigger communications based on detection rules?
  • How do you maintain a current, verified contact list for FedRAMP, CISA, and all leveraging agency security teams, and how often is it validated?
  • What tools track the full lifecycle of incident communications (initial alert through final report) to ensure no required communication is dropped?
  • How are secure communication channels (encrypted email, portal) integrated into your incident response toolchain?

Continuous Evidence & Schedules:

  • How do you prove that ICP notification timelines were met for every reportable incident over the past year?
  • Is incident communication history available via API or structured data export, or only as email threads and PDFs?
  • How do you demonstrate that ICP procedures remain effective between incidents — through drills, audits, or automated checks?
  • What evidence shows follow-up communications and final incident reports were delivered on the required schedule?

Update History

2026-02-04Removed italics and changed the ID as part of new standardization in v0.9.0-beta; no material changes.

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