About NIST 800-37

NIST Special Publication 800-37 establishes the Risk Management Framework (RMF), providing a structured process for integrating security and risk management activities into the system development lifecycle. This seven-step framework guides organizations through categorizing information systems, selecting and implementing security controls, assessing their effectiveness, authorizing system operation, and continuously monitoring security controls.

The RMF transforms security from a static compliance exercise to a dynamic, ongoing process that responds to evolving threats and vulnerabilities. By emphasizing a risk-based approach to security, NIST 800-37 helps federal agencies and private organizations make informed decisions about security resource allocation while maintaining appropriate security posture throughout the information system lifecycle.

NIST 800-37 compliance steps

NIST Special Publication 800-37 establishes the Risk Management Framework (RMF), which consists of six primary steps to integrate security and risk management into the system development lifecycle.

Step 1 - Categorize: Classify information systems based on mission impact and determine the security category using FIPS 199 standards to establish appropriate security controls.

Step 2 - Select: Identify the baseline security controls based on the categorization and apply tailoring guidance to adjust controls according to specific organizational needs and risk factors.

Step 3 - Implement: Deploy the selected security controls within the information system and document how the controls are implemented or planned for implementation.

Step 4 - Assess: Evaluate security controls to determine if they are implemented correctly, operating as intended, and meeting security requirements through appropriate assessment procedures.

Step 5 - Authorize: Senior organizational officials make risk-based decisions to authorize system operation based on the security status and determination that risk is acceptable.

Step 6 - Monitor: Continuously track changes to the information system and its environment, assess security control effectiveness, and report the security posture to appropriate officials.

Throughout all steps, maintain appropriate documentation of decisions, approvals, and evidence to demonstrate due diligence and compliance with applicable regulations and policies.

Compliance requires establishing clear roles and responsibilities, with designated individuals accountable for security activities including system owners, authorizing officials, security officers, and assessors.

The framework emphasizes continuous monitoring rather than periodic reassessment, allowing organizations to maintain ongoing awareness of information security vulnerabilities and threats.

Organizations often struggle to implement NIST 800-37 standards due to the comprehensive nature of the Risk Management Framework. The categorization step requires deep understanding of information value and mission impact, which many organizations lack. Without proper categorization, subsequent security decisions rest on a flawed foundation, potentially leaving critical systems underprotected while wasting resources securing less important assets.

Selecting appropriate security controls presents another challenge, as organizations must navigate hundreds of potential controls while correctly tailoring them to their specific environment. Many organizations either apply controls too broadly, creating unnecessary operational friction, or too narrowly, creating security gaps. Implementation further complicates matters, requiring specialized expertise and coordination across multiple departments with competing priorities and limited resources.

The assessment phase demands rigorous, objective evaluation—something difficult to achieve when those responsible for implementation are also tasked with assessment. This conflict of interest can lead to perfunctory reviews that fail to identify critical vulnerabilities. Authorization decisions often become rubber-stamp exercises rather than meaningful risk evaluations when senior officials lack necessary security context or face pressure to keep systems operational despite unresolved issues.

Perhaps most challenging is establishing effective continuous monitoring. Organizations frequently underestimate the resources required, resulting in sporadic rather than continuous oversight. Documentation requirements across all phases create substantial administrative burden that many view as bureaucratic overhead rather than valuable security governance.

The consequences of inadequate implementation are severe. Organizations face increased vulnerability to cyber attacks, with potential data breaches leading to financial losses, regulatory penalties, and reputational damage. When security incidents occur, organizations without proper RMF implementation often lack the documentation to demonstrate due diligence, compounding legal and regulatory exposure. Moreover, reactive security approaches inevitably cost more than proactive risk management, creating budget pressures while simultaneously reducing operational effectiveness and organizational resilience.

Simplifying NIST 800-37 Risk Management Framework (RMF) controls with an Enterprise Browser

Users access a growing number of tools through the browser, requiring RMF controls to ensure a reduction of risk. With the Island Enterprise Browser, the browser becomes a control point, giving better visibility, risk reduction, and compliance to RMF designers in the organization. By using Island, the RMF benefits by requiring fewer controls and solutions, and lower cost to ensure reduced risk for users accessing web, cloud, SaaS, RDP, and SSH.