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1Clear out junk files and repair common Windows errors2Fix the driver behind crashes, sound loss and screen glitches3Repair Windows errors before they cause bigger problemsThird-party risk management (TPRM) is the ongoing process of understanding and managing risks created when an organization depends on outside providers for products, services, or other support. Organizations assess vendors by first examining what the relationship involves and what could go wrong, then gathering evidence in proportion to the potential impact, deciding whether and under what conditions to proceed, and monitoring the relationship through its end.
A questionnaire can contribute evidence, but it is not a complete assessment. The work should reflect the service, the data and systems involved, the supplier’s importance to operations, and relevant upstream dependencies. Outsourcing a service does not outsource the organization’s responsibility for managing its own risks.
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What is third-party risk management?
TPRM is a lifecycle for managing the risks that arise from relationships with outside entities. A third party might provide technology, process data, host a system, perform a business function, or supply a product on which operations depend. The risk is not a property of the supplier alone: it depends on what the supplier does, how the organization uses the service, and the consequences of a failure, compromise, or disruption.
Cybersecurity supply-chain risk management (C-SCRM) is a focused part of this work. NIST SP 800-161 Rev. 1, Update 1, dated November 1, 2024, describes integrating C-SCRM into organizational risk management, including strategy, policy, plans, and risk assessments for products and services. It is broader cybersecurity supply-chain guidance, not a universal legal requirement for every organization.
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For banking organizations, the Board, FDIC, and OCC’s June 6, 2023 final guidance sets out a third-party relationship lifecycle. Its stages also offer a useful practical framework elsewhere, but the guidance applies to banking organizations; other organizations should check the laws and rules that govern their sector and jurisdiction.
How do organizations assess vendors?
Assessment begins with the relationship, not a standard questionnaire. The goal is to determine what risks matter in this particular use case, what evidence can help evaluate them, and whether the remaining risk is acceptable to the organization.
1. Describe the relationship and its consequences
Record the proposed product or service, its business owner, how it will be delivered, and what the supplier will be able to do. The assessment should capture relevant data, system connections and privileges, operating locations, subcontracting, and dependence on the service. Consider plausible consequences if the service is unavailable, information is exposed, or the supplier or a component is compromised.
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This context shapes the rest of the assessment. A provider with access to sensitive information or a critical operational function may warrant different evidence and scrutiny from a provider whose failure would have limited effects.
2. Set priority and assessment depth
Establish a risk-based way to prioritize suppliers and activities using factors such as potential impact and the service’s role in operations. Use that priority to decide how early and deeply to assess a relationship and how frequently to revisit it. NIST says prioritization can guide the timing, order, scope, and frequency of assessment; it does not prescribe one tiering model or a fixed review interval for every organization.
For consistent decisions, compare relationships using relevant factors such as service criticality, potential business or customer impact, data sensitivity, system access, upstream dependencies, evidence quality and recency, resilience, and substitutability. These factors are a practical synthesis, not a published universal scoring rubric. Record the method your organization uses and tailor it to the relationship rather than treating a score as a substitute for judgment.
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3. Gather and test evidence
Use supplier responses and documentation as inputs, not as the whole assessment. NIST calls for combining information about the purpose and use case with supplier or source data and all-source information. Depending on the relationship, useful evidence may include relevant independent or public information, and the organization should validate material claims, note gaps, and distinguish verified facts from assumptions.
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- Foreign ownership, control, or influence (FOCI): Consider ownership and control in light of the service and relevant threat context.
- Provenance: Examine where and how the product, service, and important components originate, and how they are developed or integrated.
- Resilience: Evaluate the supplier’s ability to sustain or recover delivery during disruption.
- Foundational cyber practices: Assess baseline cybersecurity practices and the evidence supporting claims about them.
- Supply-chain tiers: Identify important upstream dependencies beyond the direct provider.
SP 1326 is scoped to ICT supplier due diligence; its five dimensions should not be treated as a universal checklist for every kind of third party. The guide’s definition is that “Due diligence research is the investigative process of researching all available, pertinent information about a given supplier or product so that informed decisions can be made on new acquisitions or existing systems.” The full guide provides the detailed procedures to apply to a relevant ICT relationship.
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4. Make and document a decision
Document what evidence was reviewed, the important risks and assumptions, unresolved issues, the accountable risk owner, and the decision. Practical outcomes might include approval, approval subject to conditions, deferral until material gaps are addressed, or declining the relationship if the residual risk is outside the organization’s tolerance. These are examples, not mandatory labels prescribed by NIST.
When proceeding, turn conditions into clear responsibilities and, where appropriate, remediation milestones. Contract terms should address protections and responsibilities suited to the relationship. Regulated arrangements may require legal and compliance review. The banking agencies’ lifecycle expressly places contract negotiation before ongoing monitoring.
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5. Monitor the relationship and plan for exit
Onboarding does not end the assessment. Revisit the relationship at a frequency appropriate to its risk, and reassess when meaningful changes occur—for example, a change in service, ownership, access, an incident, or an upstream dependency. Track remediation and whether important evidence remains current.
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Plan for termination and transition as part of managing the relationship. Depending on the service, that may include continuity arrangements and the handling or return of data. The banking agencies’ lifecycle includes ongoing monitoring and termination as distinct stages.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What lifecycle should a vendor review follow?
The following stages are the sequence in the Board, FDIC, and OCC’s 2023 guidance for banking organizations. The agencies say practices should reflect the relationship’s nature and risk profile and that examples should be tailored to the facts and circumstances. Organizations outside banking can use the sequence as a framework, not as a claim that the banking guidance governs them.
| Stage | What the organization does |
|---|---|
| Planning | Define the need and understand the proposed relationship before selecting a provider. |
| Due diligence and selection | Gather and evaluate evidence, then decide whether the supplier and arrangement are suitable. |
| Contract negotiation | Set responsibilities and protections that fit the relationship. |
| Ongoing monitoring | Review the relationship and relevant changes over time. |
| Termination | Manage the end of the relationship and any needed transition. |
See the agencies’ June 6, 2023 final third-party risk management guidance for its banking-specific scope and lifecycle.
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Guidance is not automatically a binding rule for every industry. NIST’s C-SCRM publications provide risk-management guidance; the 2023 interagency third-party relationship guidance is for banking organizations. Applicable obligations can depend on jurisdiction, industry, data, and the particular relationship, so organizations should identify the requirements that apply to them rather than assume one source resolves every legal question.
Regulatory status can also change. In a September 11, 2026 bulletin, the OCC described proposed guidance coordinated with the Federal Reserve, FDIC, and NCUA to revise and replace existing third-party risk guidance. The bulletin identifies it as a proposal, not a final rule or final guidance. See the OCC Bulletin 2026-46 for that status.
For smaller organizations assessing ICT suppliers, CISA’s April 3, 2023 vendor and supplier assessment fact sheet points to an ICT vendor supply-chain risk template and an accompanying spreadsheet with questions and explanations.
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