The US Office of Management and Budget (OMB) has issued new guidance on when and how federal agencies should collect security guarantees from software vendors.
Building on the cybersecurity executive order that President Joe Biden signed in May 2021, the OMB last year published a memorandum (M-22-18) requiring federal agencies to obtain from software vendors guarantees that the software they provide is secure.
Per M-22-18, federal agencies are required to obtain attestation for all software developed after September 14, 2022, but also for software released prior to that date, if it receives a major update or if it is used as a service and receives constant updates.
At a minimum level, such guarantees should be provided as a self-attestation form, but agencies may also require a software bill of materials (SBOM) and other artifacts, or may require the vendor to run a vulnerability disclosure program.
Federal agencies are also required to inventory all the software that is subject to these requirements, to establish communication channels with the vendors, and obtain the necessary attestation.
In a new memorandum published on Friday (M-23-16, PDF), OMB reinforces the previous requirements and extends the timelines for agencies to obtain attestations.
Previously, federal agencies were required to obtain attestation within 270 days for critical software and within one year for other software.
Per M-23-16, attestation for critical software should be obtained no later than three months after the Cybersecurity and Infrastructure Security Agency’s (CISA) M-22-18 attestation common form is approved by OMB under the Paperwork Reduction Act (PRA).
Attestation for all other software should be obtained within six months after the common form is approved by OMB.
On May 1, CISA opened a draft self-attestation form for public comment, for a 60-day period, and will issue a final version after reviewing the public feedback and incorporating potential changes.
In the new memorandum, OMB makes it clear that federal agencies do not need to obtain attestation for third-party software components, they should assess the risk of using proprietary but freely obtained and publicly available software (such as web browsers), and that attestation is required even for software deployed, configured, or modified by a contractor on behalf of the agency.
Additionally, if a vendor cannot provide attestation for its software, but provides documentation on the practices to which they cannot attest, federal agencies are required to inform OMB on the matter and request an extension of the deadline for attestation. However, they may continue to use the software.
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