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CISA Releases Guidance on Secure OSS Use for Federal Agencies

#cybersecurity #policyandcompliance #regulatory #securityoperations

Originally published on CyberNetSec.

Executive Summary

The U.S. Cybersecurity and Infrastructure Security Agency (CISA) has released a new guidance document, "Open Source Software: Security Principles and Practices," aimed at helping U.S. federal agencies manage the risks associated with using, developing, and publishing open source software (OSS). The document provides a structured framework for evaluating OSS components, emphasizes the importance of Software Bills of Materials (SBOMs), and sets a new precedent by encouraging agencies to default to open source for their own software development projects. This guidance is a significant step in maturing the federal government's approach to software supply chain security.

Regulatory Details

The guidance was developed to fulfill requirements from Executive Orders 14144 and 14306. It is not a binding mandate but serves as a comprehensive set of best practices for federal civilian executive branch (FCEB) agencies. Key components of the guidance include:

  • Risk Evaluation: It asserts that OSS is not inherently more or less risky than proprietary software but requires a different evaluation model based on code transparency.
  • C4 Framework: Introduces the "C4 Framework" (Community, Code, Contribution, and Continuity) to help agencies assess the trustworthiness and risk profile of an OSS project before adoption.
  • SBOM Integration: Reinforces the critical role of SBOMs in providing visibility into software dependencies, building on CISA's previous work on the "Minimum Elements for a Software Bill of Materials."
  • Artificial Intelligence: Advises that AI systems should not be treated as "open source" for risk management unless there is full transparency into their training data and models.
  • Default to Open Source: A forward-leaning recommendation that encourages federal agencies to publish their own custom-developed code as OSS by default, fostering collaboration and community contribution.

Affected Organizations

The primary audience for this guidance is all U.S. Federal Government Agencies, specifically those within the federal civilian executive branch. However, the principles and practices outlined are valuable for any public or private sector organization that develops or consumes open source software.

Compliance Requirements

While not a strict compliance mandate, the guidance establishes a clear expectation for how federal agencies should approach OSS security. Agencies are expected to:

  1. Establish Formal Processes: Implement formal review and approval processes before incorporating new OSS components into their systems.
  2. Conduct Risk Assessments: Use frameworks like C4 to perform due diligence on OSS projects.
  3. Maintain Inventories: Leverage SBOMs to maintain a complete and accurate inventory of all software components, including their dependencies.
  4. Secure Development: Apply secure software development practices to both the consumption of OSS and the development of new government software.

Implementation Timeline

There is no specific implementation timeline or deadline associated with this guidance. It is intended to be an enduring resource that agencies should begin incorporating into their software management and cybersecurity programs immediately.

Impact Assessment

The publication of this guidance will have a significant operational and cultural impact on federal agencies. It will require agencies to invest in new tools and processes for software composition analysis (SCA) and SBOM management. It also necessitates a shift in mindset, moving from viewing OSS as a potential risk to be avoided to a resource to be managed and a model to be embraced. For the broader software industry, this federal endorsement of SBOMs and structured OSS management will likely accelerate adoption in the private sector.

Enforcement & Penalties

As this is guidance and not a regulation, there are no direct penalties for non-conformance. However, agencies' adherence to these best practices will likely be evaluated by oversight bodies like the Office of Management and Budget (OMB) and agency Inspectors General as part of their overall cybersecurity posture assessments.

Compliance Guidance

  1. Adopt an SCA Tool: The first step for any organization is to implement a Software Composition Analysis (SCA) tool to identify all OSS components and dependencies in their software.
  2. Integrate SBOMs: Begin generating and consuming SBOMs as part of the software development and procurement lifecycle.
  3. Develop an OSS Policy: Create a formal, written policy for the evaluation, approval, and use of open source software, incorporating the principles of the C4 framework.
  4. Educate Developers: Train development teams on secure coding practices and the specific risks associated with software supply chains.

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