What RA-2 security categorization requires under NIST SP 800-53
RA-2 asks the organization to decide how much harm a loss of confidentiality, integrity or availability would cause, and to write that decision down. An audit, contract or authorization request that asks for a categorization is asking for two things: the system and the information it processes, stores and transmits must each be assigned an impact level, and the result plus the reasoning behind it must be recorded in the system security plan. The control then requires the authorizing official, or a designated representative, to review and approve the categorization. Until that approval exists, the categorization is a working draft, not a decision an assessor will accept. The control does not prescribe a method, so the reader should confirm which impact scale and documentation template their authorizing body expects before drafting.
The categorization matters more than any other single RA-2 output because it selects the SP 800-53B baseline. A system categorized at moderate impact inherits the moderate control set, and a change to the level changes the number of controls in scope, the assessment procedures, and often the evidence a reader must produce. Teams that begin control work before settling the level frequently rebuild their plans afterward. Three problems cause most delays. First, stakeholders disagree on impact levels, usually because business owners and security staff weigh confidentiality, integrity and availability differently. Second, information types were never inventoried, so the categorization covers the application but not the data sets, logs or backups it touches. Third, the categorization was approved for an earlier architecture and never revisited after a new integration, hosting move or data type was added.
A practical first step is to list every information type the system handles, record the impact level for each under each security objective, and then trace how the system-level level follows from them. Ask the authorizing official's office which categorization method and approval record they require, and confirm who holds the designated representative role. Recheck the categorization whenever the system boundary, data types or hosting changes, and file the approved version in the system security plan so an assessor can trace each control back to the baseline it came from.
Which systems, information types and teams the categorization covers
A security categorization under RA-2 covers the system and the information it handles as one decision. The scoping choices below determine what gets categorized, and each one carries into the baseline selection and every control that follows.
Draw the system boundary
Decide which components, interfaces, data stores and administrative paths belong to the system being categorized. A boundary that leaves out a logging pipeline, a backup store or an admin console produces a categorization that does not describe what an assessor will test. Document the boundary in the system security plan and check it against the current asset inventory before the impact analysis begins.
List every information type
Identify each information type the system processes, stores or transmits, such as patient records, cardholder data, employee records or operational telemetry. Each type receives its own confidentiality, integrity and availability impact rating, and the system categorization must reflect the highest rating across all of them. Missing one information type can lower the baseline for the whole system.
Assign shared and inherited services
Decide which services the system relies on that another team or provider operates, such as identity, DNS, logging or hosting. Record whether each service is inherited, shared or system-specific, and whether its impact level bounds the system's own rating. An inherited service with a higher categorization than the system can change the result, so confirm it in writing with the owning team.
Name the data classification owner
Identify the person or office that owns data classification for each information type, and confirm whether their classification labels match the FIPS 199 impact levels. Labels such as internal or restricted do not map to impact levels automatically. Where classification and categorization disagree, the reasoning belongs in the RA-2 rationale, not in an unexplained override.
Assign business impact owners
Confirm who can state the consequences of loss of confidentiality, integrity or availability for the mission or business functions the system supports. These owners provide the impact evidence that the categorization rests on. Their sign-off should be recorded alongside the authorizing official's approval, since an impact estimate without an accountable owner is hard to defend in an assessment.
Confirm the authorizing official
Identify the authorizing official or designated representative who reviews and approves the categorization. Confirm their authority over the system before analysis starts, because a categorization approved by someone without that authority must be redone. Agree on the approval record and where it will be stored so that assessors can find it during RA-2 testing.
How the impact level selects the SP 800-53B baseline
SP 800-53B matches a control baseline to the impact level recorded in the security categorization. Once the organization has assigned low, moderate or high impact to the system under RA-2, that level points to one of three baselines. The baseline is a starting set of controls, not the finished control set. The organization still tailors it, adds overlays where they apply and documents every departure in the system security and privacy plan. Because RA-2 comes first, an error in the categorization carries forward into every other baseline decision.
- Impact level drives selection: The categorization result is the input. A system categorized as low uses the low baseline, moderate uses the moderate baseline and high uses the high baseline.
- Tailoring follows selection: Organizations can add or remove controls from the chosen baseline. Each change needs a documented reason tied to the system's risk.
- Overlays can change the set: Where an overlay applies, its controls may replace or extend baseline content for that system.
- Review the categorization first: Confirm the impact level and its rationale before pulling a baseline, since a later change in level changes the whole control set.
Before relying on a baseline, confirm the impact level with the authorizing official and check the current SP 800-53B profiles against the release your assessor uses.
Each impact level selects a different portion of the SP 800-53 catalog. Counting base controls and enhancements together, NIST's OSCAL profiles for SP 800-53B Release 5.2.0 select 149 items for the low baseline, 287 for moderate and 370 for high. The difference reflects how much additional assurance NIST expects as potential impact on the organization grows. The counts describe scope only. They do not show how much effort each level requires, which depends on the system, its existing controls and the evidence already available.
- Low baseline, 149 items: The smallest set. It covers the foundational controls that apply to nearly every system, including RA-2.
- Moderate baseline, 287 items: Roughly double the low set in item count, adding controls for stronger access, monitoring, testing and incident handling.
- High baseline, 370 items: The largest set, with additional enhancements for stronger assurance and resilience.
- Shared core: Many controls appear at every level, so a team that builds the low baseline well has a foundation for higher levels.
- Confirm the profile version: Check which OSCAL profile matches your release before counting or mapping items.
Ask your assessor which baseline and release they will test against, and whether any overlay or tailoring is expected in the assessment scope.
The privacy baseline is separate from the three impact-based baselines. It applies to systems that process personally identifiable information regardless of the impact level assigned for security. A system categorized as low for security can still fall under the privacy baseline if it handles PII. NIST's OSCAL profiles select 96 items for the privacy baseline, counting base controls and enhancements together. This number is smaller than the low security baseline, but its controls address a different set of obligations, mainly around authority, purpose, notice and privacy risk.
- Applies independently of impact: The privacy baseline is triggered by PII processing, not by the security impact rating.
- Different control families: Its controls draw on privacy-focused families, such as PII processing and transparency and privacy risk assessment.
- Separate categorization question: RA-2 covers security categorization. Confirm separately whether the system processes PII and whether privacy categorization is needed.
- Overlap is possible: Some controls appear in both security and privacy baselines, so one control can serve both purposes when documented once and cross-referenced.
- Do not treat it as optional: Where PII is processed, leaving out the privacy baseline is a scoping gap that assessors will raise.
Ask your privacy office whether the system is in scope for the privacy baseline before finalizing the control set.
NIST publishes the baseline profiles as OSCAL content, which lets teams load the selected controls into a compliance tool, track them and generate documentation from the same source. Using the profile rather than a manually copied list reduces transcription errors and makes release changes easier to trace. The OSCAL content is published in the usnistgov/oscal-content repository, and the profiles should be pulled from the same release as the catalog and the SP 800-53A procedures your assessment uses.
- Start from the published profile: Load the low, moderate, high or privacy profile for the release in use rather than retyping control lists.
- Record the selection in the plan: Document the chosen baseline, the impact level it follows from and any tailoring in the system security and privacy plan.
- Track release changes: Compare the profile against the release notes when NIST updates the content, since a new release can change item counts.
- Keep the profile under version control: Store the profile file and its tailoring decisions together so an assessor can see what was selected and why.
- Match the assessment procedures: Pair the profile with the matching SP 800-53A procedures for the same release.
Confirm with your assessor which release and profile they accept, since the authorizing body or contract may fix the version.
How an assessor tests RA-2 under SP 800-53A
This table walks through how an assessor approaches RA-2 under SP 800-53A Release 5.2.0, using the examine, interview and test methods, the assessment objects and the evidence each step expects. Use it to prepare categorization records before an assessment, and confirm the exact method for each determination statement in the SP 800-53A procedure. The main takeaway: an impact level without a traceable rationale and documented approval is the most common gap.
| Assessment element | What the assessor checks | Evidence requested | Common finding |
|---|---|---|---|
| Examine: categorization record | Impact levels for confidentiality, integrity and availability are stated for the system and each information type | FIPS 199 categorization worksheet, information types inventory, SSP categorization section | Only one overall label exists, with no per-information-type breakdown |
| Examine: rationale | The reasoning from information types and mission impact to each impact level is written and traceable | Written rationale, data flow diagrams, mission or business impact notes | Rationale is missing or reused from a template that does not describe this system |
| Examine: authorizing official approval | The authorizing official or designated representative reviewed and approved the categorization, with a date | Signed approval record, authorization package cover, dated acceptance | No approval on file, or approval predates the current system boundary |
| Interview: system owner and ISSO | Who performed the categorization, what inputs they used, and how the result was reached | Named roles, workshop notes, decision log | Staff cannot explain how the impact level was reached |
| Test: baseline consistency (where the procedure calls for it) | The impact level matches the baseline selected and the controls implemented in the SSP | Baseline selection record, SSP control set, tailoring decisions | Categorization says moderate but the SSP implements low baseline controls |
| Interview: review triggers | Whether categorization is revisited after changes to the system, data or mission | Trigger list, review records, change requests linked to the system | Categorization is treated as one-time paperwork after authorization |
| Examine: dependent controls | Downstream controls such as RA-3, RA-7 and PL-2 rely on an impact level the categorization supports | Risk assessment report, risk response decisions, SSP | Downstream documents cite an impact level the categorization does not support |
How to categorize a system step by step
This sequence turns a system and its information into a documented impact level under FIPS 199 that the authorizing official has reviewed and approved, and that then selects the SP 800-53B baseline for the rest of the control set.
Define the system boundary
The system owner, with the security officer and key engineering staff, writes down what is inside the system: hardware, software, services, interconnections, data stores and the users and administrators who operate them. Components that are shared or inherited from another system are named as such. The output is a boundary description and a system inventory that the rest of the categorization relies on. You know this step is done when every component in the inventory is either inside the boundary or listed as an external dependency with a named owner.
Inventory the information types
Identify every category of information the system processes, stores and transmits, and the mission or business function each one supports. Work from data flows, data dictionaries, records of processing and the business owners of each dataset, not from memory. Personal data, regulated data and operational data are listed separately because each may drive a different impact level. The output is an information type inventory with a short description and owner for each entry, which the assessor will later ask to see.
Assign provisional impact levels for each objective
For each information type and for the system as a whole, assess the potential impact of a loss of confidentiality, a loss of integrity and a loss of availability. The categorization uses the low, moderate and high impact levels defined in FIPS 199. Write the reasoning next to each rating, naming the harm to the organization, individuals or the mission that the rating assumes. Ratings made without written reasoning are the most common weakness assessors raise. The output is a provisional impact table for each information type across the three objectives.
Reconcile the ratings into a system level
Combine the provisional ratings into one categorization for the system. Under FIPS 199, the system is rated at the highest impact level assigned to any objective or information type it contains, so a single high rating on confidentiality raises the whole system. Where the team considers a lower system rating justified, the reasoning must address each high rating explicitly. The output is the proposed system categorization, expressed as confidentiality, integrity and availability levels with the overall high-water level stated. Confirm this reconciliation with your own FIPS 199 reading and your authorizing official's expectations before you rely on it.
Document the rationale in the system security plan
Record the boundary, the information type inventory, the provisional ratings, the reconciliation and the final categorization in the system security plan. The plan should state the assumptions behind each rating and the impact of each harm considered. The selected baseline (low, moderate or high under SP 800-53B) follows from this record, so the plan must make the link explicit. The output is a categorization section in the system security plan that another engineer could reproduce from the written reasoning alone.
Route the categorization to the authorizing official
Submit the proposed categorization, the supporting inventory and the rationale to the authorizing official or a designated representative. The reviewer checks whether the impact levels reflect the organization's risk appetite and mission, asks for changes where they do not, and decides whether the categorization is acceptable. Expect questions about the high-water reconciliation and about any information type rated lower than its neighbors. The output is a review record with questions, responses and the reviewer's decision.
Record the approval and set the baseline
Once the authorizing official approves the categorization, record the approval date, the approver's name and role, and the selected SP 800-53B baseline in the system security plan and in the governance repository. Use this approved record as the input to every other control selection, including RA-3 risk assessments and the tailoring decisions. The output is a signed or otherwise attributable approval record that an assessor can trace from the baseline back to the categorization.
Revisit the categorization after significant change
Review the categorization when the system changes in a way that could alter the information it holds, the harm a compromise would cause, or its mission role. Typical triggers include new data types, new interconnections, a change in users or regulatory scope, and a change in the business function the system supports. Re-run the steps above for the affected parts, update the system security plan and obtain approval again where the impact level changes. The output is a dated change entry showing whether the categorization was confirmed or revised.
Which evidence passes an RA-2 assessment
An assessor testing RA-2 examines a small set of documents and checks that they agree with each other. The cards below cover the artifacts that carry the categorization decision, what an examiner looks for in each, and how to keep them current between assessments.
Security categorization document
This is the core record that assigns a FIPS 199 impact level to the system and to each information type it handles, for confidentiality, integrity and availability. An assessor checks that every information type is covered, that the overall system level follows from the individual ratings, and that the document is dated and versioned. Keep it in the configuration repository alongside the system boundary so that changes to scope trigger a review.
Information type inventory
This inventory lists each category of data the system processes, stores or transmits, with its owner and the source of its impact rating. Assessors use it to confirm that the categorization covers the real data flows rather than only the system's intended purpose. Reconcile it against data flow diagrams and the asset inventory, and record new data types before they reach production.
Impact rationale
The rationale explains why each rating is what it is, citing the business, mission or legal consequence of a loss of confidentiality, integrity or availability. A rating without a stated reason is the most common gap an examiner finds. Ask the data owners to sign off on their rationale, and revisit it when a regulation, contract or service dependency changes the consequence of a failure.
System security plan entry
The system security plan must record the categorization result and its rationale, and the entry should match the categorization document word for word on impact levels. Assessors compare the two documents first. Confirm that the plan names the baseline selected from the categorization, so that the control set in the plan follows directly from the impact level.
Authorizing official approval
A signed approval from the authorizing official, or a designated representative, shows that someone with authority accepted the categorization. Assessors check the date, the named signatory and whether the approval covers the same version of the document they reviewed. The approval must be re-obtained after material changes, so keep the signing record with the plan rather than in a separate email thread.
Categorization change record
A change record shows when the categorization was last reviewed, what triggered the review and what changed. Assessors use it to test whether the categorization stayed accurate between assessments, especially after new data types, new integrations or new hosting locations. Set a review trigger in the change management process, so that a new information type cannot enter production without a categorization update.
What a security categorization costs in staff time and tooling
This table breaks the effort of an RA-2 security categorization into its cost components, showing who is paid for each, whether it is one-time or recurring, and what pushes it up or down. No supplied source gives a price or duration, so use the rows to structure a written quote and to ask the authorizing official's office for review timelines. Open-source tooling mainly removes license spend, not the staff time.
| Cost component | Who is paid or who spends time | One-time or recurring | What drives it up and how to keep it down |
|---|---|---|---|
| System owner and data owner time | Internal staff, or consultant hours if an implementation partner drafts the analysis | One-time at initial categorization, recurring at each review | Up: many systems, many information types, unclear boundaries. Down: define the system boundary and information inventory before workshops |
| Workshop facilitation | Internal facilitator or an implementation partner under a fixed-scope agreement | One-time per workshop series | Up: several business units with divergent impact views. Down: pre-read a draft impact table and limit each session to one system |
| Authorizing official review | AO or designated representative, sometimes through a formal review board | One-time approval, recurring on significant change | Up: unclear rationale or late submission. Down: agree the review path and submission format in advance and ask the AO's office for its internal review timeline |
| Tooling for inventory and records | Internal staff to configure and maintain; no license fee for self-hosted open-source inventory | Setup is one-time, upkeep is recurring | Up: manual spreadsheets across many systems. Down: GLPI Assets or Wazuh Syscollector can feed asset records, though the categorization decision itself stays a human judgment |
| Documentation and SSP entry | Compliance lead or system security engineer | One-time, then recurring when the system changes | Up: categorization stored in several documents. Down: keep one source record and reference it from the system security plan |
| Assessor time when categorization is sampled | Independent assessor, paid under the assessment engagement | Recurring with each assessment cycle | Up: missing rationale or inconsistent impact levels. Down: retain workshop notes and approval records as examine evidence |
| Software licensing | Open-source projects carry no license fee; any paid support is a separate decision | Recurring only if paid support is chosen | Up: commercial tools bundled into the program. Down: confirm license terms for each self-hosted tool with its vendor or project |
Which open-source tools hold categorization inputs and records
Security categorization depends on knowing what the system is, what information it holds and where its boundary sits. The three tools below can hold parts of that picture, but each one informs the categorization without making it. The authorizing official still reviews and approves the result, and the rationale must be written down in the system security plan.
GLPI assets as the boundary inventory
GLPI's Assets module records computers, monitors, software, network equipment, peripherals, printers, phones and racks. Entries can be typed in by hand or pushed automatically by the GLPI Agent through native inventory, which has been built into GLPI since version 10. For RA-2, this inventory is the starting list that tells you which components belong inside the categorized system. Check that the list covers every component that stores, processes or transmits the information, not only the devices the IT team already manages.
Wazuh Syscollector for endpoint evidence
The Wazuh Syscollector module collects hardware, operating system, installed software, network interfaces, open ports, running processes, services, users and groups, and Windows updates from each endpoint. It stores this data in the Wazuh indexer, where the dashboard shows inventory views and reports. These records help confirm what is actually running inside the boundary and what data-bearing services are exposed, which supports the impact reasoning behind the categorization. Verify that agent coverage matches the boundary you define, since a missing endpoint means a missing input.
CISO Assistant for categorization records
CISO Assistant is licensed under AGPL-3.0-only. It ships with more than 200 frameworks, including NIST CSF, and runs assessments against them. It can be used to hold the categorization decision, its rationale and the approval record alongside the other compliance evidence for the system. Confirm with the vendor whether the tool models SP 800-53 security categorization directly, including the low, moderate and high impact values for confidentiality, integrity and availability, before you rely on it for that purpose.
Keeping the decision with people
Each tool above produces data, but none of them decides the impact level. The organization owns the categorization, the authorizing official or designated representative approves it, and the reasoning must appear in the system security plan. Treat tool output as an input to a documented review. Record who reviewed each inventory export, when it was taken and which items were excluded from the boundary, so an assessor can trace the decision back to its sources.
Who categorizes the system and who reviews it
The organization owns RA-2 from start to finish. The system owner and the data owners know what the system does, which information it holds and which missions or services depend on it. The security lead turns that knowledge into impact levels for confidentiality, integrity and availability under FIPS 199 and records the rationale in the system security plan. The authorizing official, or a designated representative, reviews the result and approves it, and that approval is what makes the categorization binding for the authorization.
- System owner: describes the system's purpose, boundaries, users and dependent services so the impact reasoning reflects real operations.
- Data owner: identifies each information type processed, stored or transmitted and states the consequences of loss of confidentiality, integrity or availability.
- Security lead: assigns provisional impact levels, documents the rationale and keeps the categorization current when the system changes.
- Authorizing official: reviews the categorization and accepts or returns it, because that decision sets the baseline the authorization is built on.
- Governance owner: confirms the categorization follows the organization's risk management process and that the approval is recorded where assessors can find it.
Before any outside party is engaged, confirm internally who holds each role, who can delegate approval in writing, and where the signed decision will be kept.
An implementation partner such as DeployOpen can support the groundwork for RA-2 in the organization's own environment. Typical work includes building the asset and information inventory that the categorization depends on, drafting the impact rationale for the security lead to review, organizing the review meeting with the authorizing official and preparing the documentation package. Where the platforms run on self-hosted open-source tooling, the partner can also show how inventory data is collected from the environment so the categorization reflects what is actually deployed.
- Inventory preparation: compiles the list of components, data stores and interfaces so the boundary and information types are accurate before scoring begins.
- Draft rationale: writes a first version of the impact analysis for the organization to challenge, correct and adopt.
- Review coordination: schedules the review with the authorizing official and records the questions and decisions raised.
- Document handling: keeps the system security plan references, version history and approval record consistent.
- Technical evidence: exports inventory data from the systems in scope so the categorization can point to verifiable facts.
The partner does not decide the impact levels, sign the approval or certify the result. Confirm in the written scope which of these tasks are included and who signs each deliverable.
The independent assessor tests whether RA-2 is met. Using the SP 800-53A procedure for RA-2, the assessor examines the categorization documentation, interviews the people who made and approved the decision, and may test whether the documented categories match the system described in the inventory and boundary records. Only the independent assessor issues assessment findings. That role must sit outside the team that built the categorization, so the organization and its partner supply evidence but do not grade their own work.
- Examine: reviews the categorization record, the rationale, the signed approval and the system security plan entries that repeat the categories.
- Interview: asks the system owner, data owner and authorizing official how the impact levels were reached and whether the system has changed since.
- Test: compares the stated information types and boundary with the actual inventory and sampled configuration records.
- Findings: the assessor records the result in the assessment report, which the organization owns and uses for its authorization decision.
- Independence: the assessor should not be the same firm that drafted the rationale, unless the engagement rules and the authorizing body explicitly allow it.
Before engaging an assessor, ask which assessment methods they will use, what evidence they expect to sample and how they handle the independence question in writing.
Where security categorizations fail review and how to close each gap
Most categorizations fail at the same few points: missing information types, undocumented reasoning, the wrong approver, stale decisions and unreflected inherited services. Each gap below carries a practical fix that a reviewer can check against the system security plan and the categorization record.
Categorize information types, not just the system
A single system-level impact rating often hides that the system processes several information types with different confidentiality, integrity and availability needs. Build an inventory of every information type the system processes, stores and transmits, assign provisional impact levels to each, and then derive the system impact from the highest level in each security objective. Reviewers look for this inventory first, because a missing information type can understate the baseline for the whole system.
Write the rationale for every impact level
A rating such as moderate for integrity is not a categorization on its own. For each information type and objective, record the adverse effect that a loss would cause, who would bear it, and the reasoning that supports the level chosen. Reviewers and assessors use this rationale to test whether the decision was deliberate, so a bare table of ratings is usually the first finding they raise.
Route approval to the authorizing official
RA-2 expects the authorizing official or a designated representative to review and approve the categorization. A system owner, project manager or security lead who signs without written delegation creates an approval gap. Confirm who holds the authorizing official role for each system, check any delegation letter for scope and date, and keep the signed approval with the categorization record.
Re-categorize after major changes
A categorization made for an earlier design can stop matching the system after it takes on new data, new users or a new mission function. Define the triggers that force a review, such as a new information type, a change in user population or a change in connections to other systems. Record each review, even when the result is unchanged, so the file shows the decision was revisited.
Reflect inherited services in the categorization
A system that relies on a cloud platform, a hosting provider or a shared service may inherit controls from it, but the categorization still has to account for the information that flows through those services. Map each inherited service, state which information types it touches, and confirm that the provider's own authorization covers the impact level assigned to your data. Gaps appear when a team assumes the provider's rating applies to its workloads without checking.
Link the categorization to the baseline in the SSP
The categorization selects the baseline, so the system security plan should state the resulting impact level, the baseline chosen from SP 800-53B, and any tailoring decisions that follow. Check that the plan's control list matches the baseline for the stated level and that any deviation has a documented reason. When this link is missing, an assessor cannot tell whether the controls selected match the risk the categorization describes.
What buyers ask about RA-2 cost, effort and outside help
How long does a security categorization take?
No supplied source gives a duration for RA-2, and NIST leaves federal implementation timelines to OMB Circular A-130. The effort depends on how many systems are in scope, how many information types each one handles, how complete the data inventory is, and how quickly system and data owners respond to review requests. A single system with a current inventory can move through analysis, review and approval quickly, while a large environment with undocumented data flows takes longer because the inventory has to be built first. Ask any provider for a schedule tied to a written list of systems and information types, and confirm the approval date with your authorizing official before work starts.
What does a security categorization cost, and what is included?
NIST does not estimate compliance or certification costs, so no published figure applies to RA-2. The total has three parts: internal time from system owners, data owners, privacy and legal staff, and the authorizing official; outside preparation work, if you hire a partner, priced from a written scope; and any independent review an assessor performs later. The initial categorization is largely a one-time cost, while effort recurs when systems change or the categorization is revisited. Ask for a quote that lists the systems in scope, the information types covered, the deliverables (the categorization document and the matching system security plan content), and the review meetings included. DeployOpen does not publish a price list. A quote follows from the written scope.
Can we complete RA-2 in-house without a consultant?
Yes, in most organizations the organization owns RA-2 and can perform it internally, because the control requires the organization to categorize its own systems and have the authorizing official approve the result. The work goes well when the team understands FIPS 199 impact levels, can read the data inventory, and writes rationale that an assessor can follow without asking questions. Outside help is most useful when many systems are in scope, data flows are unclear, or no one has time to run structured review sessions. An implementation partner can prepare worksheets, draft documentation and evidence, but the impact decisions and the approval remain with the organization.
What do system and data owners need to provide for RA-2?
System and data owners supply the facts that drive the impact levels, so their input is the main dependency for the work. Expect to provide:
- An inventory of the information types the system processes, stores and transmits, with the business purpose of each
- A description of the mission or business functions the system supports and what happens if they stop
- Their judgment of the potential impact on confidentiality, integrity and availability, with reasons
- Dependencies on other systems, shared services and external providers that could change the impact
- Time to attend the review, challenge the proposed levels and sign off the final record
The categorization and its rationale are recorded in the system security plan, so owners should expect to confirm the wording as well as the levels.
Will an auditor accept a categorization that a partner prepared?
An auditor or assessor does not certify a categorization. Under SP 800-53A, RA-2 is assessed through examine, interview and test methods, and security categorization documentation is one of the examine objects. An assessor checks that the categorization exists, that the authorizing official or a designated representative reviewed and approved it, and that the rationale supports the levels chosen. A partner-prepared document is acceptable when the organization owns the decision and the approval is genuine, and the people interviewed can explain the reasoning. Confirm the assessor's expectations before work starts, particularly for FedRAMP, which requires RA-2 at Classes B, C and D. Only independent assessors issue reports or authorizations.
How often does the security categorization need to be revisited?
The supplied facts do not set a fixed review interval for RA-2, so confirm the expected cycle in your own governance documents and in the control text in the OSCAL catalog. In practice, teams revisit the categorization when the system's purpose changes, when new information types are added, when the hosting environment or data sources change materially, and before reauthorization. Contracts and assessors may set their own triggers, and the RA-1 policy should state who decides whether a change justifies a new categorization. Keep the review dated and approved in the same way as the original decision, so the record shows the baseline still fits the system.
Who has to approve the security categorization?
The authorizing official or a designated representative must review and approve the categorization, according to the RA-2 requirement in SP 800-53 Rev. 5. The approval matters because the impact levels select the SP 800-53B baseline for every other control, so a weak or unapproved decision affects the whole authorization. Name the approver and any delegate in writing, record the date and version of the approval, and keep the signed record with the system security plan. Partners can prepare the package for that decision, but they cannot approve it on the organization's behalf.
How DeployOpen prepares the categorization for your review
DeployOpen helps organizations prepare the RA-2 security categorization inputs, including system boundary, information types and supporting evidence, so the authorizing official can review a complete record. The organization owns the impact decision and its approval, and DeployOpen does not issue audit reports, attestations or certifications.
How we scope
- We agree a written scope listing the systems, information types and boundaries to be categorized before work starts.
- We confirm which party owns each impact decision, including the authorizing official or designated representative who approves it.
- We set out deliverables and timelines in the written scope, with engagements agreed as fixed-scope and quoted from that scope.
How we build
- We document the information types the system processes, stores and transmits, with the data owners who confirm them.
- We draft the impact rationale for confidentiality, integrity and availability so each level traces to a stated reason.
- We record the resulting baseline selection and rationale in a draft that feeds the system security and privacy plan.
How we hand over
- We deliver the categorization package, including the examined documentation an assessor would review for RA-2.
- We walk the organization's reviewers through the rationale so the approver can question each impact level before sign-off.
- We hand over the documents in editable form so the organization keeps ownership of the record after the engagement ends.
How we support
- Ongoing support is available as a retainer for reviewing changes to the system boundary or information types.
- We can update the categorization record when a significant change alters the impact level or the selected baseline.
- Independent assessors and certification bodies remain responsible for testing RA-2 and issuing any report or certificate.
