Why the DoD’s New Cybersecurity Risk Management Construct Won’t Eliminate Security Controls from Assessments

In the ever-evolving battlefield of cybersecurity, the U.S. Department of Defense (DoD)—affectionately dubbed the “Department of War” in some circles—dropped a bombshell this week with the release of its Cybersecurity Risk Management Construct (CSRMC). Published on September 24, 2025, this five-phase framework promises to overhaul how the DoD handles cyber risks, shifting from the clunky Risk Management Framework (RMF) to a sleeker, more agile model aligned with DevSecOps and continuous monitoring. It’s designed to make risk assessment faster, less bureaucratic, and laser-focused on mission-critical threats, ensuring operational commanders get real-time intel on cyber vulnerabilities.

But here’s the hard truth: despite all the hype around automation and dynamic processes, the CSRMC isn’t waving goodbye to security controls in cybersecurity assessments. Far from it. This construct builds on the foundation of controls, refining them into “critical” essentials rather than scrapping the concept altogether. Let’s break down why security controls—those trusty checklists we’ve relied on for years—aren’t going anywhere, and why that’s a strategic win for defenders.

The CSRMC’s Evolution, Not Revolution, of Controls

At its core, the CSRMC reimagines risk management through five phases: Design, Build (Initial Operational Capability), Test (Full Operational Capability), Onboard, and Operations. It aligns loosely with RMF’s steps but amps up the speed with automated dashboards, penetration testing, and continuous monitoring via the DoD Information Network (DODIN) Automation. Sounds revolutionary? Sure. But peel back the layers, and you’ll see security controls woven into every fiber.

Take the Test phase, for instance, where assessments truly ramp up. Here, systems undergo rigorous evaluation, including vulnerability remediation and automated reporting— all grounded in validating critical controls. The Onboard phase doubles down, requiring risk management validation of these mandatory artifacts before granting a continuous Authorization to Operate (cATO). Even in Operations, real-time alerts and playbooks hinge on monitoring those same controls. The document explicitly calls out “DODIN Automation Critical Controls,” signaling a streamlined subset of controls, not their obsolescence.

Critics might argue this push toward automation spells the end for manual checklists, but that’s a misread. Automation doesn’t replace controls; it enforces them at scale. Without a baseline of security controls—think access management, encryption, and incident response protocols—the entire construct crumbles. The CSRMC isn’t anti-checklist; it’s anti-redundancy, targeting the RMF’s “overly burdensome” elements while retaining controls as the unbreakable backbone. In a threat landscape where adversaries like nation-state actors exploit even the tiniest gaps, ditching controls entirely would be strategic suicide.

Moreover, the framework’s emphasis on “assess and remediate” loops explicitly incorporates control-based evaluations. Penetration tests? They’re control validations in disguise. Continuous monitoring? It’s control compliance on steroids. The DoD isn’t reinventing the wheel—it’s turbocharging it. Security controls provide the verifiable, repeatable structure that automation needs to function, ensuring assessments remain thorough without devolving into chaotic guesswork.

Three Undeniable Benefits of Security Controls Checklists in Assessments

Even as the CSRMC ushers in a new era, security controls checklists remain indispensable tools for cybersecurity assessments. Here’s why they deliver value that no amount of fancy dashboards can replicate:

1. Standardization and Consistency Across Teams: Checklists enforce a uniform baseline, ensuring every assessor—whether a junior analyst or a grizzled CSSP officer—evaluates the same critical elements. This reduces variability in risk scoring and fosters trust in the results, much like how the CSRMC’s critical controls provide a shared language for DoD-wide operations.

2. Comprehensive Coverage of Known Threats: They systematically map out controls against established standards (e.g., NIST or DoD-specific overlays), catching blind spots that ad-hoc assessments might miss. In the CSRMC’s Test phase, this translates to faster remediation, as checklists guide penetration testing toward high-impact vulnerabilities without reinventing protocols from scratch.

3. Simplified Compliance and Audit Trails: Checklists create clear, auditable records of control implementation and gaps, streamlining reporting for cATO approvals and regulatory scrutiny. This is gold in the Onboard phase, where mandatory artifacts must be validated—turning what could be a paperwork nightmare into a defensible, evidence-based process.

The Bottom Line: Controls Are Here to Stay

The CSRMC is a bold step forward, no doubt—one that promises to harden U.S. defenses against sophisticated cyber foes. But eliminating security controls from assessments? That’s not on the menu. These controls aren’t relics; they’re the tactical edge that keeps dynamic risk management grounded in reality. As the DoD rolls this out, expect checklists to evolve—smarter, automated, and more integrated—but never obsolete.

Cybersecurity pros, take note: Embrace the change, but hold tight to your checklists. In the war for digital supremacy, they’re the weapons you can’t afford to lose. What’s your take on the CSRMC? Drop a comment below—let’s dissect this beast together.

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