RMF vs CSF 2.0: Understanding Authorizing Officials, ATOs, and Tiered Cybersecurity Roles
The Risk Management Framework ( RMF ), as defined in NIST SP 800-37 Rev. 2 , provides a structured approach for managing security and privacy risks across federal information systems . A key distinction within this framework is the role of the Authorizing Official (AO), particularly in the context of issuing an Authority to Operate (ATO). This post clarifies the federal AO’s responsibilities and contrasts them with internal company roles, especially within CSF 2.0 tiered structures . Understanding RMF per NIST SP 800-37 Rev. 2 The RMF is a lifecycle-based methodology used by federal agencies and contractors to ensure that information systems are secure and compliant. It consists of seven core steps: Prepare – Establish context, assign roles, and define risk tolerance. Categorize – Classify the system based on impact levels (low, moderate, high). Select – Choose appropriate security controls from NIST SP 800-53. Implement – Deploy the selected controls within the s...