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An effective response plan for an AI-enabled infrastructure attack is an organization-specific operating procedure: it identifies what is in scope, who can make decisions, how responders investigate AI-related activity, and how they contain a threat without putting critical services or people at risk. It must cover more than the model. Include the data, identity systems, cloud and serving infrastructure, providers, and any connected operational technology (OT) or industrial control systems (ICS) that could be affected.
CISA’s National Cyber Incident Response Plan (NCIRP) is a strategic framework for national coordination, not a tactical incident plan for an individual organization. Use organizational procedures for decisions and actions on your own systems. CISA’s voluntary JCDC AI Cybersecurity Collaboration Playbook can inform external information sharing, but it does not replace applicable legal or regulatory obligations.
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1. Set the scope, authority, and activation rules
Start by deciding what the plan covers. “AI incident” is too vague to guide a response: an incorrect answer from a model, a compromised cloud account, manipulated retrieval data, and unsafe behavior in an AI-connected industrial process require different investigations and containment decisions. Define the systems and services that responders must consider, including dependencies that another team or supplier operates.
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For each use case, record the model or AI service, its owner, business purpose, hosting or provider arrangement, and the systems it can read from or act on. Include components that may not be described as AI but could be part of the attack path:
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- Models, model versions, training data, retrieval or reference data, and their pipelines.
- Model-serving infrastructure, application interfaces, APIs, cloud services, and network connections.
- Identity and access systems, service accounts, secrets, administrative consoles, and other control-plane components.
- Third-party AI providers, cloud providers, integrators, and managed service providers, with their support and incident contacts.
- Business applications, OT or ICS processes, and safety-critical functions that rely on model output or can be reached through the service.
Document system owners, relevant data and model lineage where available, and dependencies between systems. For infrastructure, show which business or safety function each dependency supports. A model that is not itself critical may still be an important link in a process that is.
Make activation and decision rights explicit
Set organization-specific activation criteria. For example, distinguish a service-quality issue that can be handled through normal operations from suspected unauthorized access, data or model manipulation, unexplained changes in behavior with possible security impact, and an incident affecting critical operations. These are planning categories, not universal severity definitions: tailor them to your systems, risk tolerance, and obligations.
Write down who can declare an incident, who leads it, and who can authorize each consequential action: disabling a model, blocking an API, revoking credentials, restoring a version, isolating a network segment, or returning a system to service. State how the incident lead reaches decision-makers outside business hours, how backups assume the role, and how the organization records decisions and their owners. Do not leave responders to infer whether a security lead or an operations lead has final authority over a safety-sensitive change.
Define when to involve executive leadership, legal and privacy teams, safety, communications, procurement or vendor management, business continuity, insurers, regulators, or law enforcement. The triggers and notification timelines depend on the organization’s facts, jurisdiction, sector, contracts, and applicable rules; assign counsel or compliance owners to verify them rather than writing a universal deadline into the plan.
2. Assign people and preserve operational context
A response can stall when security, AI engineering, infrastructure operations, and the business each hold only part of the picture. Name a primary and backup for each essential role, and make sure the response lead can convene them quickly.
Define roles before an incident
- Incident lead: coordinates the response, keeps a decision log, assigns actions, and escalates decisions beyond delegated authority.
- Security operations and investigation: assess alerts and evidence, investigate identities and access, and coordinate containment with system owners.
- AI engineering and model owners: explain model versions, data flows, deployment history, and expected behavior; assess whether a model or data change can be trusted.
- Infrastructure and OT operations: assess dependencies and operational consequences, advise on isolation or fallback, and carry out approved technical changes.
- Safety and business continuity: evaluate hazards, safe states, critical functions, and manual operating procedures.
- Legal, privacy, and compliance: assess preservation, privacy, contractual, regulatory, and external-notification issues.
- Communications, executives, and vendor management: handle approved internal or external messages, leadership decisions, and provider coordination.
One person may cover several roles in a smaller organization, but make each responsibility clear. For each external provider or partner, keep a primary and backup contact and record how to reach incident support if ordinary service channels are unavailable. A provider’s response process may not match your own incident timetable, so document what information you will need from it and who will request it.
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Keep responder-ready records
Maintain a current dependency map and a short service record for each in-scope system. Include the service owner, technical contacts, business or safety function, data sources, model and deployment identifiers where available, provider dependencies, relevant logging locations, and the approved fallback. Make records accessible to the response team during an outage, not only through the system or identity service that might be affected.
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3. Prepare to investigate AI-specific attack paths
CISA’s JCDC AI Cybersecurity Collaboration Playbook describes AI systems as relying on data-driven, non-deterministic models and identifies model poisoning, data manipulation, and adversarial inputs as examples of malicious activity. Those possibilities complicate triage: a surprising output may matter, but it does not by itself establish that a system was compromised. Responders should test competing explanations, including ordinary error, a changed dependency, unauthorized access, or manipulation of inputs or data.
Preserve evidence that can explain a change
Decide in advance what evidence the organization can and should preserve, who can access it, and how long it remains available. Depending on the system and applicable privacy rules, useful records may include:
- Relevant security, application, infrastructure, and identity logs, with timestamps and time-zone context.
- Model identifiers, versions, deployment and configuration changes, and the timing of updates or rollbacks.
- Training or retrieval data pipeline history and available records of data changes or provenance.
- API activity, access patterns, and relevant prompts or inputs where policy and privacy rules permit retention.
- Provider notifications, support exchanges, incident identifiers, and known service changes.
These are practical preservation considerations, not a mandatory evidence checklist established by the JCDC playbook. Tailor collection to the system and involve privacy and legal owners where data may contain personal, confidential, or regulated information. Preserve relevant material before routine log rotation or remediation removes it, when doing so is safe and authorized. Record what was collected, when, by whom, and from which system.
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For each alert or report, record what is confirmed, what remains a hypothesis, when the event was observed, and who owns the next decision. Ask in an orderly way:
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- What changed? Identify the observed behavior, alert, data change, access event, or operational effect, and establish when it began.
- Which layer could explain it? Consider the model, training or retrieval data, serving environment, API, identity or cloud control plane, provider dependency, and connected OT or ICS process.
- Is there evidence of malicious activity? Look for signs of unauthorized access, manipulation, suspicious configuration or deployment changes, or adversarial inputs. Separate those findings from an output that is simply incorrect or degraded.
- What else may be affected? Check whether activity or impact extends beyond the AI component to identities, data, applications, infrastructure, or operations that depend on it.
- What is the safest next action? Compare containment options with the system owner, operations, and safety personnel before changing a process that may affect critical services.
Keep an incident timeline and decision log throughout. A clear distinction between evidence and interpretation helps teams revise an early theory without losing track of the basis for earlier actions.
4. Contain the threat without creating a safety or continuity failure
Containment in an infrastructure environment is not simply a matter of disconnecting the suspected system. An AI service may support remote monitoring, automation, maintenance, or a safety-critical process. Removing it without understanding the process can create a separate operational hazard or leave operators without essential visibility.
CISA, the FBI, and the NSA advise organizations to identify IT/OT interdependencies, plan safe isolation and manual controls, and test contingency plans so safety-critical functions can continue. Put those decisions into the organization’s own runbooks. Operations and safety personnel should assess process impact, safe-state behavior, and what may be lost if remote monitoring or automation stops before responders isolate a connected system.
Choose containment options in advance
For each AI-enabled service, document which actions are available, who approves them, and what their operational consequences may be. Options may include disabling an AI feature, limiting an API or its permissions, revoking a compromised credential, reverting to a known configuration or model version, isolating a component, or switching to human-supervised or manual operation. The appropriate option depends on the incident and the process; none should be treated as a universal instruction to disconnect.
For each option, specify the conditions for using it, the person authorized to approve it, the team that performs it, and the fallback if the action fails. Record how operators will verify the system has reached the intended state and how they will maintain critical functions during containment. If an action could affect people, property, or the environment, route it through the organization’s applicable safety and operational procedures.
Make containment decisions operational
Use a short decision sequence: identify the suspected component and affected functions; consult the relevant system owner and operations and safety leads; assess whether the proposed action could interrupt monitoring, control, or safe operation; select an authorized containment action; document the rationale and expected result; and confirm the result with the people responsible for the process. If evidence is incomplete, the incident lead should state what is unknown and use the organization’s risk-based escalation path rather than assume that either isolation or continued operation is automatically safer.
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5. Coordinate with providers and external partners
Provider and partner coordination should be planned before an incident, because the organization may need information that it cannot collect directly. Identify which provider contacts can address suspected account compromise, service changes, model or data concerns, and evidence requests. Decide who is authorized to share information, what can be shared safely, and how to preserve a record of requests and responses.
CISA’s JCDC AI Cybersecurity Collaboration Playbook, dated January 14, 2025, offers voluntary processes for sharing AI-related cybersecurity incident and vulnerability information with CISA and partners. It is intended for AI providers, developers, adopters, and partners and describes information-sharing protections and actions CISA may take after receiving shared information. Its purpose is coordination, not a replacement for an organization’s incident procedure.
The accompanying fact sheet is explicit: “This playbook does not create policies, impose requirements, mandate actions, or override existing legal or regulatory obligations.” The playbook also says that safety issues involving people, property, or the environment are outside its intended scope; handle them under the organization’s applicable safety and incident procedures.
Build an external contact and decision path
- Keep current contacts for AI, cloud, infrastructure, and managed-service providers, including an escalation route when normal channels are unavailable.
- Identify the relevant sector-specific coordination path and the internal owner who can decide whether and what to share with CISA/JCDC or other partners.
- Have legal or compliance owners assess applicable regulator, law-enforcement, contractual, and other notification duties for the actual incident and jurisdiction.
- Use approved channels and sharing practices; distinguish confirmed facts from working hypotheses and identify sensitive or personal information before disclosure.
There is no universal notification deadline established here. Requirements differ by sector, location, contract, and incident facts. Keep the legal and compliance review in the plan, and verify applicable duties for the organization rather than relying on the voluntary JCDC process as a substitute.
6. Recover, validate, and learn from the incident
Restoring service is a controlled decision, not the automatic end of response. The plan should assign recovery authority and establish what must be trusted before a model, data pipeline, or connected service is returned to operation. Identify trusted backups and configurations, the people who validate them, and the business owner who accepts the operational risk of restoration.
Set restoration gates
Before reconnection or resumption, define checks appropriate to the affected component. They may include confirming that unauthorized access has been addressed, verifying the intended model and configuration, reviewing relevant data pipeline changes, confirming dependent systems are in an acceptable state, and having operations validate behavior in the actual process. Specify who can approve each check and who can stop a restoration that produces unexpected results.
Plan for heightened monitoring after recovery. Assign the teams responsible for watching security events, system behavior, and operational performance; state how long enhanced observation continues according to organizational risk and incident findings. Provide a route for operators to report a recurrence or unexpected effect without waiting for a routine review.
Close the loop
After the incident, hold a review that records the cause or unresolved questions, affected dependencies, operational and service impacts, key decisions, control gaps, and corrective actions. Give every action an owner and a way to verify completion. Update the inventory, contacts, evidence-preservation procedures, containment runbooks, and exercises when findings show they are inaccurate or incomplete.
CISA’s Cross-Sector Cybersecurity Performance Goals frame cybersecurity work through Govern, Identify, Protect, Detect, Respond, and Recover and include both IT and OT practices. Treat that lifecycle as a way to check whether the organization’s plan connects preparation, response, and recovery—not as a substitute for assigning local decision rights or writing procedures for the systems it operates.
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7. Rehearse decisions, not just the document
CISA recommends realistic incident response drills at least annually. Smaller organizations can use a simple rehearsal or spoken walkthrough. CISA also advises involving senior business leaders and board members in major-incident planning and testing continuity for critical business functions. Choose an exercise scale your organization can run, but make participants practice the decisions they would actually need to make.
Build an exercise around an AI and infrastructure combination
A useful scenario can begin with suspected data manipulation or adversarial inputs, then introduce an infrastructure complication: a provider is unavailable, a credential may be compromised, model behavior is uncertain, or an AI-connected OT function may need to be isolated. These are scenario ideas, not claims about a specific attack. The objective is to discover whether the team can assemble the right people, separate evidence from assumptions, protect continuity, and authorize a safe response.
For a tabletop, provide information in stages and ask participants to explain what they would do next, who must approve it, and what information they need. For example, begin with an unexpected change in output; later introduce an identity alert or a provider notification; then ask how the team would protect a dependent operation if the AI service must be restricted. Do not reward a fast answer if it skips operational and safety assessment.
Capture exercise outcomes
- Could participants find the current system owner, dependency map, and after-hours contacts?
- Was it clear who could declare the incident and authorize containment, isolation, recovery, and external sharing?
- Could the team explain how it would investigate the model, data, API, identity, provider, and connected operational layers?
- Did operations and safety personnel assess process effects and a manual or human-supervised fallback before an isolation decision?
- Could the organization maintain critical functions and communicate with providers while normal systems were impaired?
- Were gaps recorded with owners and follow-up dates, then reflected in the plan and the next exercise?
CISA’s 2023–2024 Roadmap for Artificial Intelligence set an objective to “Incorporate cyber defense, incident management, and redress procedures into AI systems and processes.” That is useful strategy context for treating response and redress as part of AI governance; it does not replace current organizational procedures.
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Keep the plan concise enough to use under pressure, with system-specific annexes or runbooks for technical and operational details. A responder should be able to find the activation rule, decision authority, essential contacts, evidence sources, safe containment options, external coordination path, recovery checks, and fallback for critical functions without searching through unrelated policy.
As a final readiness check, ask whether a responder on an after-hours call can answer five questions: what system and functions may be affected; who leads and who authorizes the next action; what evidence must be preserved; how to contain the issue without compromising safe operation; and how to restore service only after validation. If the answer depends on undocumented knowledge held by one person or supplier, record that knowledge and rehearse the procedure.
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