PM-31: Continuous Monitoring Strategy

Quick-reference card

What this control requires

PM-31 requires your organization to build and maintain an organization-wide continuous monitoring strategy that defines which security and privacy metrics you track, how often you assess control effectiveness, and who receives status reports. This control moves monitoring from a system-by-system exercise to a coordinated program that gives leadership consistent, timely visibility into risk posture across the enterprise.

In practice, this means establishing the specific metrics your organization monitors, setting both monitoring and assessment frequencies for those metrics, and defining how your team correlates findings from control assessments with ongoing monitoring data. You also need a documented process for acting on what the analysis reveals and a reporting cadence that keeps defined personnel informed of the organization’s security and privacy status. The NIST SP 800-53 framework treats PM-31 as the strategic backbone that coordinates how other monitoring controls operate at the system level.

Where most organizations fall short isn’t in collecting data but in connecting it. Without a formal strategy, monitoring happens in silos. Individual teams run assessments, generate logs, and produce dashboards that never feed into a unified risk picture.

PM-31 exists to close that gap by requiring a deliberate, organization-wide approach to continuous monitoring that ties metrics, analysis, response actions, and reporting into a single programmatic lifecycle. The control also requires that response actions aren’t left to ad hoc judgment. When correlation and analysis reveal a problem, the strategy must define what happens next and who owns the response.

Why it matters

Most organizations that fail audits on continuous monitoring don’t lack tools. They lack a documented strategy that connects what they measure to how they respond. PM-31 sits at the governance layer, and gaps here cascade across the entire control environment. When your monitoring strategy is absent or incomplete, assessors have no basis for evaluating whether your organization’s monitoring activities are purposeful, consistent, or sufficient to support ongoing authorization decisions.

The audit risk is direct. Frameworks that map to NIST SP 800-53 expect organizations to demonstrate that monitoring frequencies, metrics, and reporting structures exist in written form before any system-level evidence matters. Without PM-31 compliance, authorization to operate decisions lose their evidentiary foundation. Assessors will flag the absence of a continuous monitoring strategy as a systemic deficiency rather than an isolated finding.

Beyond compliance, the operational cost of a missing strategy compounds over time. Security teams generate monitoring data without a framework for prioritization. Executives receive reports that vary in scope, format, and frequency across business units. Risk response actions happen reactively rather than as part of a defined workflow tied to monitoring outputs.

The distinction between having monitoring tools and having a monitoring strategy is worth emphasizing. Organizations routinely deploy vulnerability scanners, SIEM platforms, and compliance dashboards without defining the organizational metrics those tools should feed, the frequencies at which data should be reviewed, or the personnel who should receive consolidated status reports. That gap between tooling and strategy is exactly what PM-31 addresses.

What attackers exploit

• Inconsistent monitoring frequencies that leave gaps between assessments, allowing persistent threats to operate undetected for extended periods
• Disconnected monitoring data across organizational units, preventing correlation of low-severity signals that together indicate a coordinated attack
• Absence of defined response actions tied to monitoring findings, which means detected anomalies go unaddressed while teams debate ownership
• Stale or unmaintained metrics that no longer reflect the organization’s actual threat landscape, creating blind spots in coverage
• Irregular reporting cadence that delays leadership awareness of deteriorating security posture, slowing risk-based decisions

How to implement

For your organization

The most common failure mode with PM-31 is treating the continuous monitoring strategy as a checkbox document rather than an operational program. Organizations write a strategy, file it, and then run monitoring activities that bear little relationship to what the document describes. Start by building the strategy around your actual monitoring capabilities and expanding from there.

Begin with metric definition. Identify the organization-wide security and privacy metrics you’ll track. These should map directly to your risk management priorities and include both technical indicators (vulnerability scan coverage rates, mean time to remediate critical findings, percentage of systems with current authorization) and governance indicators (assessment completion rates, policy exception counts, training compliance rates). Avoid vague metrics like “security posture score” unless you can document exactly how it’s calculated and what thresholds trigger action.

Next, establish your monitoring and assessment frequencies. The NIST guidance makes clear that “continuous” doesn’t mean real-time for every metric. Different control types require different cadences. Vulnerability scanning might run daily, while policy reviews happen quarterly. Document the rationale for each frequency based on the volatility of the metric and the risk tolerance of your organization. This frequency justification becomes critical assessment evidence.

Build a correlation and analysis process that connects your control assessment results with your ongoing monitoring data. In practice, this often means designating an individual or team responsible for reviewing outputs from compliance monitoring tools, assessment reports, and automated dashboards on a defined schedule and producing integrated analysis rather than forwarding raw data to leadership.

Define specific response actions tied to monitoring thresholds. When a metric crosses a defined boundary, your strategy should prescribe who is notified, what actions are initiated, and how resolution is tracked. Without predefined response workflows, monitoring findings accumulate without driving remediation.

Finally, establish reporting structures. Define exactly which personnel or roles receive security and privacy status reports, what those reports contain, and how frequently they’re delivered. Most organizations use a tiered model where operational teams see weekly dashboards, management receives monthly summaries, and senior leadership gets quarterly risk posture briefings. Document these reporting requirements in the strategy and produce evidence that reports are delivered on schedule.

Common mistakes include setting monitoring frequencies that your team can’t actually sustain, defining metrics without establishing baselines, and producing reports that no defined recipient reviews or acts upon. Another frequent gap is failing to update the strategy when the organization’s risk environment changes. Mergers, new product deployments, or regulatory shifts should all trigger a strategy review to confirm that metrics, frequencies, and reporting structures still reflect the actual operating environment.

You should also plan for how your continuous monitoring strategy integrates with your supply chain risk management plan and broader risk management strategy. PM-31 doesn’t operate in isolation. The metrics you select and the frequencies you assign should align with the risk tolerances documented in those companion plans, creating a consistent governance layer across the organization’s risk programs.

Evidence examples

Cross-framework mapping

Related controls

• AC-02 — Account Management: PM-31’s monitoring strategy must define how account lifecycle events are tracked and reported as part of ongoing organizational metrics.
• AC-06 — Least Privilege: Continuous monitoring of privilege assignments ensures least privilege controls remain effective as roles and access requirements change.
• AC-17 — Remote Access: Remote access configurations represent a high-volatility metric that continuous monitoring strategies typically prioritize for more frequent assessment.
• AT-04 — Training Records: Training completion rates serve as a governance metric within the continuous monitoring strategy, tracking workforce awareness over time.
• AU-06 — Audit Record Review, Analysis, and Reporting: The audit review and analysis process feeds directly into PM-31’s requirement for correlating monitoring data and reporting findings to designated personnel.
• AU-13 — Monitoring for Information Disclosure: Information disclosure monitoring generates signals that the continuous monitoring strategy must incorporate into its correlation and analysis process.
• CA-02 — Control Assessments: Control assessment results are a primary input to PM-31, providing the periodic effectiveness data that the monitoring strategy correlates with ongoing metrics.
• CA-05 — Plan of Action and Milestones: Response actions identified through continuous monitoring analysis produce plan of action and milestones entries that track remediation to completion.
• CA-06 — Authorization: PM-31’s continuous monitoring outputs directly support ongoing authorization decisions by providing the evidentiary basis for maintaining system authorizations in dynamic environments.
• CA-07 — Continuous Monitoring: Where PM-31 defines the organization-wide strategy, CA-07 implements continuous monitoring at the system level. PM-31 sets the metrics, frequencies, and reporting structures that CA-07 executes against individual systems. You can review the UpGuard CA-07 Continuous Monitoring control page for more detail on system-level implementation.

Frequently asked questions

What is NIST SP 800-53 PM-31

PM-31 is the NIST SP 800-53 control that requires organizations to establish and maintain a continuous monitoring strategy defining organization-wide metrics, monitoring and assessment frequencies, and reporting structures. The strategy must document how your organization correlates control assessment results with ongoing monitoring data and prescribe specific response actions when analysis reveals deficiencies. It applies at the organizational level and supports ongoing authorization decisions by ensuring leadership has timely, consistent visibility into security and privacy posture.

What happens if PM-31 is not implemented

Without a documented continuous monitoring strategy, your organization loses the programmatic foundation that coordinates security and privacy monitoring across all systems and business units. Assessors will flag the absence of defined monitoring frequencies and organization-wide metrics as a systemic gap rather than an isolated control failure. The practical consequence is that monitoring activities happen without consistent purpose, risk response actions lack defined triggers and ownership, and security and privacy status reports either don’t exist or vary so widely in scope that leadership can’t make informed risk decisions. Over time, the absence of a strategy also undermines ongoing authorization, because there’s no evidentiary basis for confirming that controls remain effective between formal assessments.

How do you audit PM-31

Auditing PM-31 starts with reviewing the continuous monitoring strategy document to confirm it defines specific metrics, monitoring frequencies, assessment frequencies, correlation procedures, response actions, and reporting requirements. Assessors then verify that monitoring program artifacts, such as dashboards, scan reports, and metric tracking records, demonstrate ongoing collection at the frequencies the strategy prescribes. They also examine security and privacy status reports to confirm they’re delivered to the defined personnel on schedule and that risk response documentation shows the organization acts on analysis findings rather than letting them accumulate.

What is the difference between PM-31 and CA-7

PM-31 defines the organization-wide continuous monitoring strategy, while CA-7 implements continuous monitoring at the individual system level. PM-31 establishes which organization-wide metrics to track, sets monitoring and assessment frequencies, and defines reporting structures for security and privacy status reports delivered to designated personnel. CA-7 then executes those strategic decisions against specific systems, collecting system-level data, analyzing it, and reporting results upward into the organizational monitoring program that PM-31 governs. In short, PM-31 is the “what and why” of continuous monitoring at the enterprise level, and CA-7 is the “how” at the system level.