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3.17.2025 Delegation of Information Integrity Training If an organization delegates the UM and CR information integrity training requirement, must the delegation agreement be updated if it was in place before July 1, 2025, and addresses the system controls requirements under the 2022–2024 standards?

Yes. The training requirement is new and was not included in the systems controls requirement. The organization must update its delegation agreement to include delegation of UM and CR information integrity training.

The organization may add an addendum to include delegation of the new training requirement. The addendum must be mutually agreed on by the organization and the delegate.

ALL 2025