What evidence do auditors commonly ask for on CP-9 System Backup?

SSP CP-9 statement stating daily incremental and weekly full backup frequency, the data sets covered and backup encryption; Backup job reports for a sample period and restore test results for user, system and documentation data; Alternate processing site contract and capacity attestation; Restoration test logs with success criteria signed off; Business impact analysis identifying critical systems; Contingency plan with recovery time and recovery point objectives.

What is the most common gap auditors find on CP-9?

Alternate site capacity not validated against current load

FedRAMP High (NIST SP 800-53 Rev 5 baseline) · CP - Contingency Planning

`CP-9` System Backup

Conduct backups of user-level, system-level, and security-related documentation; FedRAMP-defined frequency (daily incremental, weekly full).

Source: FedRAMP High (NIST SP 800-53 Rev 5 baseline), CP-9. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open FedRAMP High (NIST SP 800-53 Rev 5 baseline) in the compliance library.

A FedRAMP baseline is a subset of NIST SP 800-53 Rev 5, enhancements included.

artefacts

held by a system

at each review

moderate

to go live

Backup / DR tooling

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

Backup job reports for a sample period and restore test results for user, system and documentation data · Backup / DR tooling
Restoration test logs with success criteria signed off · Backup / DR tooling
Backup schedule, retention, and offsite or immutable copy evidence · Backup / DR tooling

periodic reviewEvidence produced at each review

Alternate processing site contract and capacity attestation · Vendor register / contract repository

governing documentDocuments that govern the control

SSP CP-9 statement stating daily incremental and weekly full backup frequency, the data sets covered and backup encryption · Policy repository / GRC workspace
Business impact analysis identifying critical systems · Document repository
Contingency plan with recovery time and recovery point objectives · Policy repository / GRC workspace

First move

Start with the 3 of 7 artefacts that already live in a system (Backup / DR tooling); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Alternate site capacity not validated against current load
Plan not updated after major architecture changes
Backups taken but restore tests never performed end to end
RTO and RPO targets undefined for tier two systems

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

CP-8(4) Provider Contingency Plan · CP-9(1) Testing for Reliability and Integrity