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IRO-24: Cryptographic Incident Response (Emergency Algorithm Transition)

IRO 7 — High Protect

Mechanisms exist to establish the capability to respond to the compromise and/or disallowance of a Post-Quantum Cryptography (PQC) or classical algorithm on a compressed timeline, including: (1) Pre-identified algorithm alternates; (2) Tested rollback and roll-forward procedures; (3) Customer and/or counterparty communication templates; and (4) Incident response rehearsals against defined scenarios.

Control Question: Does the organization establish the capability to respond to the compromise or disallowance of a Post-Quantum Cryptography (PQC) or classical algorithm on a compressed timeline, including: (1) Pre-identified algorithm alternates; (2) Tested rollback and roll-forward procedures; (3) Customer and/or counterparty communication templates; and (4) Incident response rehearsals against defined scenarios?

APAC (1)
Framework Mapping Values
APAC Malaysia RMiT 2025 10.20(e)

Capability Maturity Model

Level 0 — Not Performed

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Level 1 — Performed Informally

SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.

Level 2 — Planned & Tracked

SCR-CMM Level 2 criteria definitions are not available for this control: ▪ A reasonable person would conclude a well-defined and standardized process is required. ▪ At this level of maturity, the “requirements-driven” nature of performing the control is focused on a localized and/or regionalized implementation, not uniform and consistent across the organization. ▪ Requirements are narrowly scoped for applicability and are primarily derived from compliance obligations (e.g., laws, regulations and contracts).

Level 3 — Well Defined

Incident Response (IRO) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery. ▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management software). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with IRO domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to establish the capability to respond to the compromise or disallowance of a Post-Quantum Cryptography (PQC) or classical algorithm on a compressed timeline, including: (1) Pre-identified algorithm alternates; (2) Tested rollback and roll-forward procedures; (3) Customer and/or counterparty communication templates; and (4) Incident response rehearsals against defined scenarios.

Level 4 — Quantitatively Controlled

Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.

Level 5 — Continuously Improving

Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.

Assessment Objectives

  1. IRO-24_A01 capability exists to respond to the compromise or disallowance of a Post-Quantum Cryptography (PQC) or classical algorithm on a compressed timeline.
  2. IRO-24_A02 pre-identified algorithm alternates are established.
  3. IRO-24_A03 tested rollback and roll-forward procedures are established.
  4. IRO-24_A04 customer and/or counterparty communication templates are established.
  5. IRO-24_A05 incident response rehearsals against defined scenarios are conducted.

Evidence Requirements

E-QTS-12 Cryptographic Incident Playbooks

Documented evidence of incident playbooks and exercise records for cryptographic scenarios.

Quantum Security

Technology Recommendations

Micro/Small

  • Know how to contact certificate authority and key vendors; document steps to replace compromised certificates/keys

Small

  • Maintain vendor and CA contacts for certificate revocation emergencies
  • Basic plan for replacing compromised certificates

Medium

  • Emergency certificate replacement procedures
  • Pre-identified algorithm alternates in security runbook
  • Integration with incident response plan

Large

  • Formal cryptographic incident response plan
  • Pre-identified algorithm alternates with tested rollback procedures
  • Customer/counterparty communication templates
  • Integration with enterprise incident response

Enterprise

  • Enterprise cryptographic incident response program
  • Tested emergency algorithm transition procedures
  • 24/7 incident response capability for cryptographic emergencies
  • Regular cryptographic incident response exercises

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