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Third-party risk management (TPRM) is the ongoing process of understanding and managing the risks an organization takes on when it relies on outside providers. To assess a vendor, first define what the relationship involves and what could go wrong; then scale evidence gathering, approval, contract safeguards, and monitoring to the service’s importance and potential impact. A supplier’s questionnaire is one input—not the assessment itself.
What third-party risk management covers
Third parties can include suppliers, service providers, contractors, and other outside entities that support an organization. The relevant risks depend on the relationship: a provider might handle sensitive data, connect to internal systems, perform a critical business function, or depend on upstream suppliers. A disruption, compromise, or failure can therefore affect operations, customers, compliance, or data in different ways.
TPRM is a lifecycle, not a one-time security review. The banking agencies’ 2023 guidance describes five stages for banking organizations: planning; due diligence and selection; contract negotiation; ongoing monitoring; and termination. Its examples are intended to be tailored to the relationship’s facts and risk profile. Organizations outside banking can use that sequence as a practical framework, but it is not a universal legal mandate. See the agencies’ final guidance announcement.
Cybersecurity supply-chain risk management (C-SCRM) is a focused lens within this broader work. NIST SP 800-161 Rev. 1, Update 1 describes integrating C-SCRM into risk-management activities for systems and organizations, including strategy, policy, plans, and risk assessments for products and services. The update is dated November 1, 2024. Managing a supplier can reduce exposure, but it does not transfer the organization’s own accountability for its decisions and operations.
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How organizations assess vendors
Use a documented, risk-based process. There is no single tier model or fixed review interval that fits every organization: NIST says prioritization can shape the timing, order, scope, and frequency of assessment according to criticality and potential impact. The following sequence turns that principle into practical steps.
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Define the relationship and its context
Record the product or service, business owner, delivery model, data handled, system connections, access privileges, relevant locations and subcontracting, and the organization’s dependence on the service. Then consider plausible consequences if the provider or service is compromised, unavailable, or unable to meet its obligations. These details identify which risks matter and what evidence is proportionate.
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Set inherent risk and assessment depth
Prioritize relationships according to their potential business or customer impact and the context in which the service will operate. Decide how early and deeply to assess the provider, what issues need specialist review, and how often to revisit the relationship. A critical service with sensitive data or privileged access may warrant more scrutiny than a low-impact purchase; the assessment should explain why its chosen depth fits the use case rather than rely on an unexplained label.
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Gather and test evidence
Use the provider’s responses and artifacts as one source, not as proof by themselves. Combine relationship-specific context with relevant supplier information and independent, public, or commercially available information where appropriate. Check material assertions, consider how current and independent the evidence is, and record gaps or uncertainty. A certificate or completed questionnaire may inform a decision, but neither necessarily establishes that every risk in this particular relationship is controlled.
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Make and document the decision
Record the evidence reviewed, material risks, assumptions, unresolved questions, accountable risk owner, decision, and any conditions or remediation milestones. Practical outcomes might include approval, approval subject to conditions, deferral while material gaps are addressed, or rejection when residual risk exceeds the organization’s tolerance. These are useful disposition examples, not a universal set of required labels.
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Put suitable protections in the contract
Translate the organization’s requirements into responsibilities and protections appropriate to the service and its risks. Contract negotiation is an explicit stage in the banking agencies’ lifecycle. Regulated arrangements may require qualified legal and compliance review; the applicable obligations depend on the organization, jurisdiction, sector, and relationship.
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Monitor the relationship and plan its end
Reassess at intervals appropriate to the risk and when meaningful changes occur—for example, a change in service, ownership, access, an incident, or an important upstream dependency. Track remediation and whether evidence remains current. Plan termination and transition, including continuity and the handling or return of data where applicable.
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NIST’s SP 800-161 Rev. 1, Update 1 full text discusses assessment inputs and risk-based prioritization. Its approach supports tailoring scope and review frequency rather than applying an identical questionnaire or calendar to every supplier.
What to examine for ICT suppliers
For information and communications technology (ICT) supplier diligence, NIST’s July 2026 SP 1326, Cybersecurity Supply Chain Risk Management: Due Diligence Assessment Quick-Start Guide, names five dimensions to consider:
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- Foreign ownership, control, or influence (FOCI): ownership and control considerations relevant to the service and its threat context.
- Provenance: where and how the product, service, and important components originate, and how they are developed or integrated.
- Resilience: the provider’s ability to sustain or recover delivery during disruption.
- Foundational cyber practices: the supplier’s baseline cybersecurity practices and supporting evidence.
- Supply-chain tiers: important upstream dependencies beyond the direct provider.
SP 1326 is scoped to ICT suppliers; it is not a universal checklist for every kind of third party or a detailed procedure for every industry. Its stated purpose is due-diligence research to inform decisions about new acquisitions or existing systems. Organizations should tailor these dimensions to the relationship and consult the full guide for procedures.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How to compare assessment approaches
When deciding how much diligence a relationship needs—or comparing two providers for the same service—use consistent questions while letting the answers reflect context. A useful practical comparison considers:
- Criticality and impact: how important the service is and the likely consequences of failure or compromise.
- Data and access: sensitivity of information handled and the scope of system privileges or connectivity.
- Dependencies and provenance: important upstream providers and what is known about the product or service’s origins and integration.
- Evidence quality: whether information is relevant, independent, sufficiently current, and supported for material claims.
- Resilience and substitutability: how delivery could continue or recover, and whether the organization can move to an alternative.
- Ongoing and exit needs: what monitoring, contractual protections, remediation, continuity, and transition arrangements the relationship requires.
This is a practical synthesis of risk-based tailoring, not a published standard scoring rubric. A numeric score is useful only if its criteria, assumptions, and effect on decisions are clear.
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Guidance, obligations, and useful resources
Requirements vary with jurisdiction, industry, data, and the nature of the relationship. The 2023 interagency guidance cited above applies to banking organizations; organizations in other sectors should check their own applicable obligations rather than assume the banking framework governs them.
OCC Bulletin 2026-46, dated September 11, 2026, reports proposed guidance coordinated with the Federal Reserve, FDIC, and NCUA to revise and replace existing third-party risk guidance. The cited bulletin describes a proposal, not a final rule or final guidance. Consult the OCC bulletin for its stated status.
For small and medium-sized businesses, CISA’s April 3, 2023 vendor and supplier assessment fact sheet points to an ICT vendor supply-chain risk template and a spreadsheet with questions and explanations. Those materials are a starting point for ICT supply-chain review, not a substitute for tailoring diligence to the organization’s actual relationships.
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